Standard Operating Procedure
for Conducting
Nuclear Facility Transition Screening Reviews
1.0 Purpose
This procedure establishes responsibilities and methods for conducting facility transition screening reviews. The screening reviews are intended to evaluate the condition, configuration, content, operating commitments (e.g., technical safety requirements, permit requirements), and existing surveillance and maintenance of DOE surplus facilities and identify those actions which need to be taken by the responsible Secretarial Officer before the Office of Environmental Restoration and Waste Management (EM) accepts responsibility for the facilities. The screening reviews also are intended to identify the liabilities that EM will inherit upon accepting responsibility for surplus facilities and the changes needed in facility environment, safety, and health requirements caused by facilities transitioning into the post-operational phases of the facility life cycle.
2.0 Scope
This procedure applies to all DOE surplus facilities scheduled to have screening reviews as part of their facility transition process. Typically, the screening review will be the first appraisal of a surplus facility by EM. However, in some cases, such as when unexpected budgetary/mission changes require the transfer of facilities on an unscheduled basis, a quick look review will be conducted in lieu of a screening review.
This procedure is intended to be applied in a graded manner. The procedure is written comprehensively to address high risk facilities for which detailed facility characterizations and thorough determinations of potential liabilities are required. The level of effort and sophistication of each screening review should be proportioned to factors such as the type and status of the facility being reviewed, the type and magnitude of the facility hazards, and the complexity of the facility.
3.0 Definitions and Assumptions
3.1 Definitions
3.1.1 Control of hazardous and toxic substances: An occupational safety activity or program directed at managing and controlling the use of materials regulated because of their known or suspected toxic or hazardous characteristics. This involves control of the type, quantity, location, equipment, processes, and procedures for hazardous or toxic materials in the workplace.
3.1.2 Deactivation: The process of placing a surplus facility in a safe, environmentally sound configuration requiring minimal surveillance and maintenance during the period preceding decontamination and decommissioning or initiation of an alternate facility use program.
3.1.3 Decommissioning: Actions taken to reduce the potential health and safety impacts of DOE contaminated facilities, including activities to stabilize, reduce, or remove radioactive, hazardous, or chemical materials or to demolish the facilities.
3.1.4 Decontamination: The removal of radioactive or hazardous material contamination from facilities, equipment, or soils by washing, heating, chemical or electrochemical action, mechanical cleaning, or other techniques.
3.1.5 Equipment: The systems and devices used throughout DOE and commonly referred to as equipment are normally divided into three categories. It is the intent of this definition to focus on the installed equipment that can logically be considered as an integral part of real property, distinguishing it from other types of equipment of less interest to transition and deactivation programs. The purpose of this approach is to provide a uniform basis for identification and analysis of the various transition and decommissioning costs. For example, the transfer of installed equipment can be addressed more globally than the transfer of programmatic equipment. The disposition of programmatic equipment and most other equipment can best be addressed on a case basis. The three types of equipment are defined as:
(1) Installed equipment. This category includes the mechanical and electrical systems that are installed as part of basic building construction and are essential to the normal functioning of the facility and its intended use. Examples are heating, ventilating, and air conditioning (HVAC) systems; elevators; and communications systems.
(2) Programmatic equipment. Equipment dedicated for a specific programmatic use. Examples are accelerators, microscopes, radiation detection equipment, gloveboxes, and hot cells.
(3) Other equipment. Some examples in this category are office machines, vehicles and mobile equipment, helicopters, airplanes, and computers and other automated data-processing equipment.
3.1.6 Facility: A plant, building, structure, or complex 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.
3.1.7 Graded approach. By graded approach, DOE intends that the depth of detail required and the magnitude of resources expended for a particular transition-related effort be tailored to be commensurate with the element's relative importance to safety, environmental compliance, safeguards and security, programmatic importance, and/or other facility-specific requirements.
3.1.8 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).
3.1.9 Hazard categories: The categories are based on the consequences of unmitigated releases of radioactive and/or hazardous material.
Category 1 Hazard: The hazard analysis shows the potential for significant offsite consequences.
Category 2 Hazard: The hazard analysis shows the potential for significant onsite consequences (e.g., hazard affects a large portion of the site).
Category 3 Hazard: The hazard analysis shows the potential for significant localized consequences (e.g., hazard affects only the immediate area surrounding the hazard).
Note: Hazards not included under the above categories would fall under the normal industrial hazards addressed under OSH regulations.
3.1.10 Hazardous materials: Any solid, liquid, or gaseous materials that are toxic, explosive, flammable, corrosive, or otherwise physically or biologically threatening to health. Oil is excluded from this definition. Further definition of this term for regulatory compliance purposes can be found in CERCLA sections 101(14) and 102, SWDA section 3001, CWA sections 307(a) and 311(b)(2)(A), CAA section 112, and TSCA Section 7, as well as 40 CFR 261 and 49 CFR 1910, Subpart Z.
3.1.11 Hazardous waste: Those wastes that are designated hazardous by EPA regulations (40 CFR 261).
3.1.12 Industrial Hygiene: Protection of workers from chemical, biological, physical, and physiological hazards, including psychological stress. The associated protection activities include:
controlling the work environment through ventilation and the use of barriers;
protecting individual workers with special clothing and respirators;
training workers on safe procedures for handling hazardous materials; and
educating employees concerning hazards and protective measures.
3.1.13 Industrial Safety: Protection of workers from physical harm from a range of possible sources such as:
electrical systems;
machinery and power tools;
compressed gas and pressure systems;
confined space controls and lock-out/tag-out procedures;
platform, man-lift, and scaffolding usage and work surfaces;
heavy machinery operation;
cutting, welding, and brazing activities;
explosives and hazardous materials (handling, storing, and using);
construction and hoisting, rigging, and material handling;
firearms;
acoustics and noise; and
facility egress obstacles.
3.1.14 Mixed waste: Waste containing both radioactive and hazardous components as defined by the Atomic Energy Act and the Resource Conservation and Recovery Act, respectively.
3.1.15 Nuclear materials: All materials so designated by the Secretary. Presently, these materials are: depleted uranium, enriched uranium, americium-241, americium-243, curium, berkelium, californium, plutonium 238-242, lithium-6, uranium-233, normal uranium, neptunium-237, deuterium, tritium, and thorium. Related regulatory definitions of radioactive materials in such classes as high-level waste, low-level waste, transuranic waste, and byproduct material can be found in 10 CFR Parts 30, 40, 60, 62, and 70.
3.1.16 Radioactive waste: Solid, liquid, or gaseous material that contains radionuclides regulated under the Atomic Energy Act of 1954, as amended, and of negligible economic value considering costs of recovery.
3.1.17 Remedial Action: Activities conducted at DOE facilities to reduce potential risks to people and/or harm to the environment from radioactive and/or hazardous substance contamination.
3.1.x Safety Analysis Report (SAR): That report which documents the adequacy of safety analysis for a nuclear facility to ensure that the facility can be constructed, operated, maintained, shut down, and decommissioned safely and in compliance with applicable laws and regulations.
3.1.18 Shutdown safety: The maintenance of facility safety in a a facility in a safe shutdown or deactivated (non-production) system configuration, whether it is a subcritical condition for a nuclear reactor, a stable chemical configuration for a chemical process facility, or any other shutdown configuration that is specifically intended to ensure provides plant workers, the public, and the environment with an appropriate level of protection from any remaining hazards.
3.1.19 Site: One or more facilities, usually geographically contiguous, operated by or for the DOE under the management and administrative direction of a DOE or DOE contractor organization.
3.1.20 Surplus facility: A facility that is wholly or partly contaminated with radioactive, chemical, or hazardous materials as a result of DOE program activities, is designated as inactive by the responsible program office, and has no intended or planned future mission. Ancillary contaminated and non-contaminated buildings are also considered surplus and can be considered for transition.
3.1.21 Surveillance and maintenance: Those activities necessary to ensure that a deactivated surplus facility is maintained in a condition that protects the safety and health of the worker, public, and the environment prior to the start of facility decontamination and decommissioning activities. These activities should detect in a timely manner any unsafe condition and the degradation of structures, systems, and components which could at a later time result in an unsafe condition. These activities include:
monitoring individual parameters (e.g., facility and surrounding environment radiation and contamination levels) and system status (e.g., radiation alarms, fire alarms and barriers, security alarms and barriers);
performing checks and calibrations of instrumentation (e.g., in-line effluent radiation detectors, ventilation flow rate meters, temperature and pressure gauges);
maintaining, testing, and inspecting structures, systems, and components, especially those that serve as barriers to radioactive or hazardous materials or act to prevent the degradation or failure of these barriers; and
evaluating monitoring, testing, and inspection results.
3.1.x Technical Safety Requirements (TSR): Those requirements that define the conditions, safe boundaries, and the management or administrative controls necessary to ensure the safe operation of a nuclear facility and to reduce the potential risk to the public and facility workers from uncontrolled releases of radioactive materials or from radiation exposure due to inadvertent criticality. A TSR consists of operating limits, surveillance requirements, administrative controls, use and application instructions, and the bases thereof.
3.2 Assumptions
3.2.1 Screening review team members will be experienced in their assigned functional areas and in conducting DOE facility assessments and reviews.
3.2.2 Each screening review will require 2 to 10 personnel for 2 to 10 working days, depending on the size, hazards, and condition of a specific surplus facility.
3.2.3 No physical surveys or sampling will be performed by screening review team members.
3.2.4 EM may accept responsibility for a surplus facility prior to the facility being deactivated.
3.2.5 The information provided by surplus facility, site, and operations office representatives and documents is accurate.
3.2.6 Surplus facility management will make knowledgeable personnel who can adeptly discuss key facility information available to the screening review team.
3.2.7 Preliminary data and information regarding the facility will be made available to DOE Headquarters by the site prior to the screening review facility visit.
4.0 Responsibilities
4.1 Deputy Assistant Secretary, EM-60
The Deputy Assistant Secretary, EM-60, is responsible for:
approving any revisions to this procedure and
ensuring that adequate staff are available to support the conduct of screening reviews.
4.2 Director, EM-62
The Director, EM-62, is responsible for:
establishing the overall schedule for conducting screening reviews;
providing guidance to screening review team leaders and members concerning the overall screening review process;
ensuring that EM-62 staff support the conduct of screening reviews;
approving screening review reports; and
ensuring that screening review reports are distributed to appropriate organizations/personnel.
4.3 Screening Review Team Leader
The Screening Review Team Leader is responsible for:
ensuring the screening review is organized, staffed, and fully supported;
managing the screening review team;
providing policy guidance to the screening review team members;
serving as the primary point of contact with surplus facility, site, and operations office representatives;
making all logistical arrangements with the surplus facility, site, and operations office representatives;
coordinating screening review planning and preparation activities;
acquiring applicable facility documentation sufficiently prior to conducting the on-site portion of the screening review; and
coordinating the preparation of the screening review report.
4.4 Screening Review Team Members
Screening Review Team Members are responsible for:
assisting with screening review planning and preparation activities;
performing document reviews of applicable facility documentation in their assigned functional areas;
conducting facility inspections and interviews in their assigned functional areas; and
preparing assigned portions of the screening review report.
4.5 Site and Field Office Representatives
Site and Field Office Representatives are responsible for:
ensuring that a knowledgeable point of contact and onsite escort are provided to the screening review team;
ensuring that applicable documentation is provided to the screening review team;
providing any necessary site-specific indoctrination and training for the screening review team; and
ensuring that the administrative needs (e.g., office space, photocopiers, facsimile machines) of the screening review team are fulfilled.
5.0 Procedure
5.1 Selecting the Screening Review Team
The Director, EM-62, or designee, shall prepare a schedule for conducting screening reviews and shall assign a team leader and team members for each screening review so scheduled. Each screening review team leader shall be a member of the EM-60 staff. Screening review team members shall be comprised of some combination of EM-60 staff and their support contractors. In selecting the team members, the following considerations should be made:
whether the team member has access to the facility and the ability for a team member to conduct the screening review without a security access;
the size of the team (e.g., using generalists who are familiar with many different functional areas may be preferable when the team is small);
the qualifications, experience, and background of the team member relative to the characteristics of the facility to be reviewed;
whether the team member is knowledgeable of the facility;
whether the team member meets medical requirements and health and safety training requirements; and
if the team member has a potential conflict of interest with respect to reviewing the facility (e.g., an M&O contractor on detail assignment to DOE Headquarters reviewing facilities operated by his or her M&O contractor).
5.2 Planning for the Screening Review
5.2.1 Preparing the Screening Review Plan
The team leader in conjunction with assigned team members shall develop a screening review plan that describes:
screening review scope,
screening review team personnel,
schedule of screening review activities (including a specific on-site screening review agenda),
organizations requiring notification,
administrative activities,
applicable documents (see section 5.2.2), and
review checklists (see section 5.2.3).
5.2.2 Developing the Screening Review Documentation Request
The team leader in conjunction with the team members shall identify the documentation required to conduct the screening review using the document list provided in Attachment 1. The selection of documents shall be based on the type and status of the facility, the type and quantity of hazards (known or expected) at the facility, and the complexity of the facility. After selecting the applicable documents, the team leader shall determine which documents should be forwarded to EM-60 and which documents should be made available at the site. The team leader shall include the facility-specific document list in the screening review plan. Additions to the document list should be made during document reviews and the onsite screening process. It is expected that site personnel will provide additional documents to the team based on requests for information from the team during and following the site visit.
The team will request specific documents when possible; however, site managers should provide the team with updated copies of all documents related to the facility condition, operations, and other facility functions that will be turned over to EM during the transition process. In addition, documentation of the status of current or ongoing issues should be provided.
5.2.3 Preparing the Screening Review Checklists
5.2.3.1 The team leader in conjunction with the team members shall prepare facility-specific review checklists using the functional area generic checklists provided in Attachment 2. The generic checklists are intended to cover the full scope of DOE facility activities and hazards, and could be used, as is, for the most complex and hazardous DOE surplus facilities. The team leader and team members should consider the time allotted for the screening review when developing the review checklists. The team leader shall include the facility-specific checklists in the screening review plan.
5.2.3.2 Facility-specific checklists may be generated from the generic checklists based on the characteristics of the surplus facility to be reviewed. In generating facility-specific checklists, some of the key characteristics to consider are:
type of facility (reactor facility, non-reactor nuclear facility, non-nuclear facility);
types of facility structures, systems, components, and equipment;
hazard category (1, 2, or 3);
material inventory (radioactive materials only, hazardous materials only, both radioactive and hazardous materials); and
expected status of facility once transitioned to EM (operational, shutdown, partially deactivated, fully deactivated).
5.2.4 Preparing the Screening Review Notification Letter
At least six weeks prior to the onsite portion of the screening review, the screening review team leader shall transmit a letter (Exhibit 1) to the surplus facility manager notifying the manager of the impending screening review. This letter shall include the proposed dates for the onsite portion of the screening review, the names of the team members, the draft agenda for the onsite portion of the screening review, and the documentation request developed in section 5.2.2. The documentation request shall indicate the documents to be forwarded to the screening review team prior to the team visiting the facility and the documents to be made available for review during the onsite portion of the screening review. The notification letter also needs to request at least one knowledgeable point of contact and onsite escort.
5.3 Conducting the Document Review
5.3.1 Upon receipt of the surplus facility documentation, the screening review team leader shall initiate and direct the conduct of the document review. The review team shall perform the document review using, as general guidelines, the written checklists included in the screening review plan to ensure that review depth and continuity are achieved. The team leader shall coordinate the availability of generic documents (those documents that apply to more than one functional area) to ensure that each team member has access to these documents.
5.3.2 During the document review, the review team shall attempt to determine the following:
The preliminary baseline facility condition;
The current level of maintenance being performed and the surveillance and maintenance activities that will be required after transitioning the facility to EM (including surveillance and maintenance funding requirements);
The facility's material inventory;
Potential liabilities to EM (e.g., priority corrective action projects; noncompliances that will remain applicable after facility transition; safety hazards; and commitments from permits, orders, Federal Facility Compliance Agreements (FFCA), memoranda of understanding (MOU), and consent orders, as well as ongoing fines);
Overall document quality;
The current resources required to operate and maintain the facility and the resources required to operate and maintain the facility after transitioning the facility to EM;
Order of magnitude cost estimates required to manage the facility;
Listing of security interests and current level of security activities; and
Whether additional documents are needed to conduct the screening review.
5.3.3 The review team shall document its review findings for use in updating the onsite screening review checklist and preparing the screening review report. Updating the onsite screening review checklist shall involve:
Ensuring that conditions that are identified or have potential to be liabilities to EM are investigated in sufficient depth;
Revising questions/areas of review to make them facility specific; and
Adding/deleting questions/areas of review.
5.4 Performing the Onsite Screening Review
5.4.1 At the onset of the onsite portion of the screening review, a pre-screening review meeting with cognizant DOE and M&O contractor management of the surplus facility shall be conducted by the screening review team leader. The purpose of the meeting is to describe the review scope, present the screening review plan, introduce review team members, meet counterparts, discuss the schedule of review activities, and establish channels of communication.
5.4.2 The review team shall perform the onsite screening review using, as general guidelines, the written checklists included in the screening review plan to ensure that review depth and continuity are achieved. In conducting the review, the review team shall use the following review techniques:
interview members of the surplus facility organization;
inspect facility structures, systems, components, and common areas; and
review any documentation and records associated with facility activities not previously received and reviewed.
5.4.3 During the onsite screening review, the review team shall attempt to determine the following:
baseline facility condition;
conditions requiring immediate actions;
the current level of maintenance being performed and the surveillance and maintenance activities that will be required after transitioning the facility to EM (including surveillance and maintenance funding requirements);
preliminary cost estimates for surveillance and maintenance and total liability;
the facility's material inventory;
potential liabilities to EM (e.g., priority corrective action projects; additional documentation required; safety hazards; commitments from permits, orders, FFCAs, MOUs, and consent orders, as well as ongoing fines; and unexpected resource requirements);
current condition of safeguards and security systems to protect all security interests; and
whether additional facility documents need to be reviewed after the facility visit.
5.4.4 Conditions that are apparent liabilities to EM shall be further investigated in sufficient depth to determine whether a liability actually exists and to preliminarily characterize the extent and effect of the liability.
5.4.5 At the conclusion of the onsite portion of the screening review, a post-screening exit briefing shall be held by the team leader to present preliminary results of the screening review to appropriate site personnel. Additionally, the screening review team shall request any documentation not available during the facility visit be forwarded to the screening review team.
5.5 Preparing the Screening Review Report
5.5.1 The screening review team leader shall coordinate the preparation of the screening review report. Any additional documentation not received prior to or during the facility visit shall be reviewed before completing the screening review report. A draft screening review report in the format shown in Attachment 3 shall be prepared and submitted to the Director, EM-62; the screening review team members; and the applicable DOE and M&O contractor surplus facility managers within two weeks following the screening review. The facility managers shall be given one week to review and comment on the draft report.
5.5.2 The screening review team leader shall prepare the final screening review report which takes into account the comments received on the draft report. The final report shall be signed by the team leader; approved by the Director, EM-62; and issued within four weeks following the screening review. The final report shall be transmitted to the Deputy Assistant Secretary, EM-60; the Director, EM-62; the Director, EM-63; the Director, EM-64; and the appropriate DOE and M&O contractor management.
6.0 Records
Documents associated with the conduct of facility transition screening reviews shall be retained as records by EM-62. These documents include:
screening review plans,
screening review notifications,
draft and final versions of screening review reports,
comments and responses to draft screening review reports, and
documents related to surplus facilities.
7.0 Attachments
7.1 Attachment 1. Document List
7.2 Attachment 2. Functional Area Checklists for Performing Screening Reviews
7.3 Attachment 3. Screening Review Report Outline
LIST OF ATTACHMENTS
Attachment Page
Attachment 1: Document List A-2
Attachment 2: Functional Area Screening Review Checklists A-7
Administrative Planning
1. Budget, Schedule, and Manpower Management
A-7
Surveillance and Maintenance
2. Shutdown/Deactivated Facility Operations and Safety A-11
3. Physical Plant A-21
4. Transition Maintenance A-26
Environment, Safety, and Health
5. Environmental Protection and Waste Management A-30
6. Occupational Safety and Health A-36
7. Radiation Protection and Safety A-43
8. Radiological and Hazardous Material Inventories A-48
Facility Protection
9. Safeguards and Security A-51
10. Fire Protection A-58
Attachment 3: Screening Review Report Outline A-65
Attachment 1
DOCUMENT LIST
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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Organization chart (with names and phone numbers) |
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Manpower plan |
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Contractor/subcontractor plans |
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Union contract |
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SAR |
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Future site plans |
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Facility maps* |
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Facility photographs, aerial and ground level |
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Training plan |
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Deactivation plan* |
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Transition plan and procedures* |
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Strategic plans |
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Public relations information |
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DOE Order Compliance Program assessment reports |
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Compliance Schedule Approval (CSA) and Exemption (EX) requests |
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Non-compliance citations and notices and associated fines/penalties and schedules |
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Print out of issue management system (corrective action list)* |
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Occurrence Reports |
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Assessment Reports (Tiger Teams, TSAs, NS, EH, IG) |
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TSRs/OSRs |
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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Hazards analysis* |
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Administrative procedures on staffing S/D modes |
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Emergency preparedness plans |
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Quality assurance plan |
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Surveillance and maintenance plan* |
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Operational procedures (Conduct of Operations documents) |
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Facility work backlog* |
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Facility physical inspection results (including Condition Assessment Survey (CAS) information)* |
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Configuration management documentation status |
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List of S/D facilities/systems/equipment* |
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Master equipment list for safety systems* |
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Maintenance backlog* |
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List of out of service or decommissioned equipment* |
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Maintenance Implementation Plan |
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Long term lay-up procedures* |
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Maintenance manning requirements* |
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List of CERCLA/NPL sites* |
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List of Federal Facility Compliance Agreements* |
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State laws/regulations |
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Activity Data Sheets |
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NEPA documents/EAs/EISs* |
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Title III studies |
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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Preliminary Assessments (PAs) |
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Remedial Investigations/Feasibility Studies (RI/FS)* |
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RCRA Facility Assessments |
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Records of decision* |
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Annual Site Environmental Report (includes number and locations of USTs and monitoring cells)* |
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Annual Waste Generation Report |
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Monthly monitoring report (air, waste water, groundwater, surface water, etc.) |
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Environmental monitoring plans |
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Documents on sanitary and industrial waste water collection systems and stormwater and process water drainage systems, including layout plans and any text, photographic or video tape records from examinations of their physical condition |
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NPDES permits* |
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Air permits* |
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Transportation plans |
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Interagency agreements* |
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Letters of agreement* |
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Waste management plan |
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Health and safety plan |
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Health and safety standard operating procedures |
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Hazardous waste shipping manifests |
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Job/worksite hazard analysis reports |
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Hazard Communication Program documents (for laboratories, Chemical Hygiene Plan) |
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Employee exposure monitoring data (air sampling and biological monitoring)* |
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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OSH Hazard Abatement Management Log |
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Hazardous material disposal permits |
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Safety Committee minutes |
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Management plans for specific agents (e.g., asbestos, lead, PCBs) |
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Bulk storage tank inventories and management plans |
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Field data sheets for industrial hygiene sampling |
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Hazard inventories |
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Confined space inventories |
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Industrial hygiene manuals or guides |
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Operational safety analyses |
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Safety and health training requirements |
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OSHA inspection reports and citations* |
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OSH compliance reports |
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Safety and health annual inspection forms |
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Safety inspection reports |
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Radiological Controls Manual Implementation Plan* |
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Building specific radiological procedures* |
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Occupational exposure reports |
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Radiological surveys |
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MSDSs |
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Radioactive material accountability system/source control |
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SNM plans (inventory, management, and survey)* |
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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Site Safeguards and Security Plan (includes MSSA, FDOP, RP) including facility and system S&S plans and procedures* |
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Vulnerability analysis |
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Physical protection plan |
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Materials control and accountability plan |
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Operations security plan |
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Information and computer security plans |
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Classified material inventory and inventory/consolidation plan* |
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Most recent Inspection and Evaluation (OSE) Report |
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Communications security plan |
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Fire Protection Hazards Report* |
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Historical fire protection records |
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Fire protection plan* |
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Layout of fire protection water supply system and other fire protection systems |
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Special fire protection requirements |
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On-site/off-site fire protection resource requirements |
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Maintenance procedures for fire protection equipment |
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Documents on utilities and their related treatment or supply systems, such as potable and non-potable water, electricity, natural gas, steam, compressed air, and chilled liquids (for air conditioning) |
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List of hazardous chemical inventories and toxic chemical releases, as required by CERCLA/SARA Sections 312 and 313* |
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Annual Work Plan/Operating Plan* |
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Mid-Year Review Reports |
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Project and Contractor Work Breakdown Structures* |
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Document Request List for Screening Review |
Forward to EM-60 |
Make available at site |
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Monthly Performance Reports for current fiscal year |
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Change control procedures |
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Most recent internal and external management assessment reports |
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Manpower planning documents |
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Attachment 2
FUNCTIONAL AREA SCREENING REVIEW CHECKLISTS
Functional Area 1: Budget, Schedule, and Manpower Management
1.1 Introduction
Budget, schedule, and manpower management refers to some of the management functions that are needed to support the technical activities performed at a site. Although budgeting, scheduling, and staffing activities are still needed within each technical discipline, this functional area pertains to management activities that are performed for the entire facility, with a focus on transition activities.
Budgeting involves preparing program budget proposals and requests that are consistent with approved plans, and allocating resources in accordance with the authorized budget. Scheduling involves managing and directing resources to ensure that critical program deadlines and commitments are met. Scheduling requires close interaction with both DOE personnel and contractors in order to allocate resources as efficiently as possible. Manpower management refers to determining the number and nature of positions available and/or required within each organizational unit, determining the qualification and training/retraining requirements for each staff position needed, and assigning responsibilities and authorities accordingly.
1.2 Budget, Schedule, and Manpower Management Document Review
1.2.1 Budget, Cost, Schedule, Manpower, and Contract Information:
Examples: Budget summaries for current year and two previous years
Budget projections based on best available information
List of current contracts issued by DOE and M&O contractors
List of contractors and subcontractors and authorized budgets
Work breakdown structures
Union contracts and related information
Ongoing or existing fines
Current Annual Work Plan/Annual Operating Plan
Monthly performance reports for current fiscal year
Change control procedures and records
Selected cost account and work packages (current and next fiscal year, if available)
Most recent internal and external management assessment reports
Manpower planning document
Performance indicators
1.2.2 Facility Information:
Examples: Future site plans
Activity data sheets and backup documents for transition activities
Transition plan
Deactivation plan
Surveillance and maintenance plan
Project management plans
Training and retraining plans
Proposed staffing levels and plans
DOE Compliance Program assessment reports
Compliance schedule approval & exemption requests
Issue management system (printout of corrective action list)
DOE CAMP reports
Occurrence reports
Assessment reports
1.2.3 Other Information Needs:
Examples: Organization charts
Telephone directories
Public relations information
Areas of Review:
Effective performance and compliance with requirements depend on the quantity and quality of resources, both human and capital, which are devoted to the facility. The determination of resources to be allocated to a facility should be based on the existing and anticipated transition mission, the existing and transition-related hazards, the risks associated with the hazards, and the applicable operational and safety requirements. The reviewer should examine facility plans, particularly the transition and deactivation plans, to ensure that they clearly identify the needed resources and link the resources with the activities that will maintain (or achieve) compliance and minimize risk, as determined by the facility's continuing mission and objectives at the time of facility transfer to EM. During the review of these plans, the reviewer also should ensure that the transition and deactivation plans clearly outline the differences in facility mission and requirements before and after facility transition. To the extent feasible, the plans should also discuss how these differences affect facility resource requirements during the deactivated condition that precedes final decommissioning and decontamination. The reviewer should determine if the timing of resource allocations is consistent with achieving specific goals within specified time frames.
The appropriate level of resources needed to meet DOE environmental, safety, and health requirements can be determined in part by assessing the safety concerns that apply at the facility and by studying instances where resources were not satisfactory to ensure safety in the past. The reviewer should determine if funds are formally requested and appropriated in the budget process to meet environmental, safety, and health requirements, and there should be a correlation between a facility's short- and long-term environmental, safety, and health plans and the budget requests and appropriations. These requests and plans should take into account the historical difference between the requested budgets and actual appropriations in order to develop realistic projections of achievable progress toward compliance and risk minimization.
Additionally, the reviewer should search for answers to the following questions. These questions also form the basis for interview guidelines for facility personnel:
What are the organizational units, functions, and relationships that form the overall organizational structure of the facility? What are the principal organizational changes anticipated during the transition process that will impact the budget processes?
How many people will be needed at the facility during the transition, what will be are their functions and staff levels, and what will be the breakdown between DOE employees and contractors?
What is the overall budget for the facility, how has the budget changed over time, and what is the current projected budget? What are the bases for the transition budget?
Do budget requests associated with the transition and decommissioning period reflect a detailed analysis of resources required to meet environmental, safety, and health requirements?
What are the resource requirements (i.e., budget and FTEs) required for deactivation activities and current and anticipated transition-related surveillance and maintenance activities?
Do the safety issues that arise at the facility reflect resource deficiencies that may impact the facility decommissioning?
What are the current personnel training and qualification requirements that should be sustained to support the new transition mission?
What new personnel qualifications and training programs are needed for the transition period?
To what extent can the existing labor force be retained during transition activities?
Does the existing labor force need to be retained to meet transition-related activities?
What activities are on the critical path to meet the proposed schedule for transition?
What are the long term job qualification requirements for facility staff, and how will these change as the final facility disposition is achieved?
Have any alternative uses for the facility been considered? How do these alternative uses affect budget and resource requirements?
What facility technologies are suitable for technology transfer, and what is the current status of the transfer program?
Are transition and other activity milestones being met?
1.3 Budget, Schedule, and Manpower Management Onsite Review
1.3.1 Inspect:
N/A
1.3.2 Interview:
Site Manager
Facility Managers
Transition Team Managers
Budget Manager
Administrative Managers (personnel)
Contractor Contacts & Contract Managers
Union Representatives
DOE Operations Office facility oversight personnel
Interview Questions:
What organizational changes will be needed in light of the upcoming transition process to EM-60?
What types of personnel skills will be needed to perform deactivation, cleanup, and transition activities?
How do the expected changes related to deactivating and/or transitioning the facility affect manpower requirements?
To what extent are existing manpower resources able to be applied to transition-related surveillance and maintenance and decontamination and decommissioning activities?
What problems have already been identified for transition and deactivation manpower requirements?
When do existing contracts expire, and which ones should be renewed?
Do you expect that the facility budget will grow or shrink during and after the transition; how will this anticipated change be met?
What is the facility track record for meeting budgets and schedules? What areas of the budget appear to be under funded or over funded?
Are any contractor procurements planned or required to obtain specialized services relating to deactivation or surveillance and maintenance activities?
Is the budget for supporting transition and deactivation period surveillance and maintenance activities adequate to maintain the facility in a condition where environmental, safety, and health risks are acceptable?
Are contractor, site, and facility budget objectives and funding requirements during the transition and deactivation period consistent and complementary? Will this balance change significantly as a result of the transition process?
Are job qualification requirements for facility staff periodically reviewed and updated, and do plans exist to revise the job qualification requirements before the facility is deactivated?
Are major upgrades to facility structures, systems, or components required? Has the cost of these upgrades been budgeted? Does the facility have the necessary resources and skills to perform these upgrades?
Is there an action-tracking system implemented that will be available to support the transition and decommissioning process or will a new approach or system be needed?
What are the major outstanding action items for the facility that may have to be completed after facility transfer to EM?
Are the long term implementation plans for resolving open assessment findings funded?
Is the contractor responsive to DOE requests, directives, and recommendations, including financial constraints and budget instructions?
Are appropriate tools, processes, and software used to develop budget estimates? Will these tools be available and applicable following facility transfer to EM?
Is there an organized plan for retraining personnel to retain them during transition?
Is there an established public outreach program? Is it successfully involving the workers, community, and local government organizations? Is it included in the budget?
Functional Area 2: Operations and Safety
2.1 Introduction
Shutdown safety is defined as the maintenance of facility safety in a shutdown or deactivated (non-production) system configuration, whether it is a subcritical condition for a nuclear reactor, a stable chemical configuration for a chemical process facility, or any other shutdown configuration that is specifically intended to ensure plant workers, the public, and the environment an appropriate level of protection from any remaining hazards. Shutdown safety can only be ensured if the transition of operational responsibility is comprehensively planned and executed in an orderly, responsible manner. Shutdown operations and safety at surplus facilities are important because the facility may still have various radioactive or hazardous materials for storage or further disposal operations. Safe, efficient shutdown operations are required in order to protect the health and safety of the workers and the public and to ensure protection of the environment.
Deactivated facility shutdown operations include any continued requirements for system and equipment operations and maintenance testing while in a complete non-production status, including continued activities required for mechanical, electrical, chemical, or nuclear processes. The transition period prior to and after reaching the non-production status may be characterized by either a gradual decrease in production operations or an abrupt decrease, depending on the nature of the facility and its production operations. Thus, each structure, system, and component must be considered in terms of its relationship to supporting the phase out of production operations.
In addition to addressing phase out of production operations, the facility managers must consider the restoration and possible conversion operations planned for the facility. For example, it is probable that the availability of many support systems will continue to be required. Although it will generally not be the direct responsibility of the vacating program managers to support post-transition activities, significant savings to the Government may be realized with even a modest amount of planning and coordination. In some cases, it may also be advantageous to vacating managers to identify structures, systems, and components that can be systematically placed in a safe, low-maintenance condition (mothballed) rather than continue to operate and maintain them at a reduced capacity. This approach can be taken for installed equipment and for programmatic equipment being held in reserve for possible future use at another facility. Properly undertaken, such systematic asset management plans will allow long-term preservation as well as short-term savings.
Since operations are generally managed from a central control area or other such locations, the preferred plant status after transition will generally include the continued functioning of those control stations or the ready reactivation of those systems that may be needed in an emergency. Instrumentation, control, and communication systems used during production operations may be of continuing utility for ensuring the safety of the deactivated plant. These systems should be identified for turnover during the transition.
Facility deactivation does not necessarily mean that the facility hazards are reduced. In fact, a reduced level of manning and technical expertise may result in a net increase in risk. Therefore, during deactivated facility shutdown operations, performance of continued operational and maintenance activities is expected to be in accordance with the same level of formality as expected during normal facility operations. This formality of operations includes control room activities, nuclear material criticality safety operations, operability of shutdown related safety systems, monitoring plant conditions, use of testing and other procedures, event/transient investigations, and performing any required radiological/chemical work in accordance with the principle of as-low-as-reasonably achievable (ALARA).
Finally, the process of turning over operational responsibility for a facility, even if it is to be placed in a permanent shutdown condition, is a joint responsibility of the production managers and the managers who are taking custody of the facility for restoration and conversion. The operational control of structures, systems, or equipment can be transferred only through mutual consent as documented during the turnover and transition process.
In preparing the facility for turnover and deactivation, facility managers have a number of information sources available to them that need to be considered, both by departing managers and by the managers assuming responsibility. In addition, even if significant personnel changes are not needed, there are many regulatory and safety analysis issues that may apply during and after the transition process. No operational requirement can be assumed to be non-applicable after facility transfer to EM. In the following sections, several potential sources of information regarding the continuing operational obligations are identified. The documents listed are only intended to be representative, and the facility managers should identify additional or alternative documents that may apply to their specific facilities. These documents should be identified and provided to EM in a timely manner in order to ensure an efficient turnover process.
2.2 Shutdown/Deactivated Facility Operations and Safety Document Review
2.2.1 Facility Operational Safety Technical Documents:
Examples: Safety analysis reports (SAR) and other accident analysis, operational safety, emergency preparedness, and criticality protection documentation
Technical safety requirement (TSR) shutdown surveillances
Hazards analyses
Operating, test, and maintenance procedures, including vendor technical manuals
Safety, instrumentation, and control system diagrams used for operations and testing
It is probable that the plant or facility safety documentation already contains a significant amount of information relevant to the safe operation of the facility even in the deactivated condition. This documentation should be reviewed in some detail with cognizant plant personnel in order to determine the safety issues and requirements that need to be considered as part of the transition and following deactivation. For the more complex facilities, personnel training and supervision requirements may also be continued, although modified to accommodate the general deactivated or converted condition.
In particular, for those facilities having a comprehensive safety analysis report (SAR), each aspect of the accident analysis section of the SAR must be assessed for continuing facility vulnerabilities and related emergency preparedness requirements. The reviewer should determine if the SAR is up-to-date and appropriate for the facility activities to be conducted upon transfer of the facility to EM. In addition, it is possible that deactivated-facility shutdown operations will involve unusual support system configurations and hazardous material evolutions not currently identified in the SAR but requiring the consideration of additional accident scenarios or deletion of existing accident scenarios. It is likely that the associated accident scenario hazards can be significantly reduced if vendor technical documentation has been maintained up-to-date. For example, even though installation, removal, or layup information contained in vendor documentation has not been used in many years, it is very likely needed to support the transition and deactivation process, but it would require updating and validation in order to be used for plant deactivation and decommissioning.
TSRs may or may not be included in the available SARs. At some facilities, TSRs may still be referred to as operational safety requirements (OSR). TSRs for systems, components, and instrumentation that are needed for extended shutdowns should also be reviewed. In each case, those TSRs that are required to be met for the current and future configuration of the facility must be identified and provided for turnover, perhaps in the deactivation plan. Those aspects of TSRs that are no longer applicable or required should also be formally closed out by the responsible facility managers. Documentation of this closeout should be accomplished for turnover, even if this documentation consists only of a marked up master copy of the applicable TSRs. For those TSRs which will carry over to the deactivated condition, the remaining facility staff or available work force must be consistent with meeting all of the remaining aspects of the TSRs.
A comprehensive hazards analysis may also be found in the SAR, or hazards may be documented elsewhere for some facilities. The EM reviewer will develop a list of expected or potential hazards (e.g., radioactive isotopes, toxic chemicals, flammables) expected at the facility based on its operational missions and available plant documentation. Some new hazards may be created because of decontamination and decommissioning activities. The reviewer should identify any documented hazards and study the basis of the hazards analysis prior to the site visit. Some hazards will very likely continue to exist because the source materials are expected to be turned over for processing as part of the site restoration and conversion process. Personnel safety and environmental protection measures will continue to be needed to address those hazards. All structures, systems, and equipment needed to support these measures must be demonstrated (physically or through test documentation) to be functional as part of the turnover process.
Finally, safe operation of the remaining functional systems in the deactivated facility require the availability and use of up-to-date operational information. System operating procedures and support documentation such as system diagrams must conform to the as-built configuration. Thus, system turnover must include a documented status of system changes and the associated documentation updates. At the time EM assumes operational control of the facility or parts of the facility, all applicable system design change or modification information and the status of its documentation must be provided. For most facilities, this will require managers to review their current management information data for impacts on the operation of the deactivated plant. The documentation and presentation of this type of information is expected to be unique for each facility since it is dependent on the management and data systems currently used.
2.2.2 Facility Operational Safety Plans:
Examples
Deactivation plans
Transition plans
Emergency preparedness plans
Quality assurance plans
Surveillance and maintenance plans
DOE orders require a number of facility plans to be in place, some of which contain procedures or information directly related to the transition and decommissioning process. These plans must be carefully assessed for applicability to the turnover and deactivation process. If a deactivation plan has been developed (e.g., under the requirements of DOE 5480.23), it may already include comprehensive and applicable information. If the deactivation plan is not available or has not been recently updated, then significant effort may be needed in order to develop a credible approach to deactivating the facility. Whether this plan is developed before or after the turnover process is a matter to be addressed by the responsible managers.
The deactivation plan, when complete, should provide the operability and facility safety requirements of the physical plant needed to support the decommissioning and decontamination process, even if this process is delayed for several years. The EM reviewer will assess the current facility configuration, the deactivation plan timetable, and proposed interim configurations, verifying that the plan describes in sufficient detail the resources and processes needed to achieve a status of complete deactivation from the current facility configuration, including decontamination or restoration. The deactivation plan should also detail the surveillance and maintenance activities needed to ensure continuously high levels of safety during shutdown operations until completion of the applicable decontamination and restoration programs.
Scenarios related to shutdown operations that cause the implementation of the emergency preparedness plan during and after the transition process should also be identified for EM review. Each such scenario for each affected facility or building must continue to be supported operationally by the emergency plan, emergency facilities, and emergency personnel. Transition and deactivated plant emergency scenarios should be identified and assigned to an appropriate manager responsible for the implementation of the applicable emergency plan. The level of emergency preparedness for a transitioning facility should be identified in the emergency preparedness plan and should be based on the actual configuration to be turned over to EM.
The facilitys quality assurance policy statement commits the facility to implement a formal QA program (QAP) in accordance with DOE 5700.6C. The extent of a QAP is based on the level of risk involved in the facility processes and equipment. The EM review should include a determination of which of the 10 criteria in DOE 5700.6C are applicable to the transitioning facility in its current configuration and planned configuration. Facility QAP managers must be prepared to turnover a well defined and ongoing QAP that is operationally current and implemented at a level consistent with the facility status at the time of turnover. EM will determine whether the established QAP covers the future needs of the facility with sufficient scope and with sufficient resources. A key part of the QAP management plan is the criteria for identification and verification of transition and turnover QA documentation, which should be developed by the facility managers in preparation for initiating the turnover process.
Surveillance and maintenance plans for turnover, transition, and continued safe operations in the deactivated condition should be developed and made available. The normal surveillance and maintenance activities observed for outage or shutdown operations will be reviewed to identify potential areas requiring additional attention. Also, a plan may be needed for developing and implementing a phase-in approach to the identification and incorporation of new surveillance and maintenance requirements applicable to the deactivated condition. In many cases, surveillance and maintenance requirements will be significantly reduced, but some situations will require the establishment of new management and oversight activities. In addition, the budget elements related to current and newly identified surveillance and maintenance activities required during the transition and deactivation phases must be identified and assessed.
2.2.3 Facility Operational Safety Administrative Procedures:
Examples
Administrative procedures related to shutdown operations and management
Procedures required for meeting regulatory requirements and interfacing with regulatory agencies
Shutdown operating and surveillance procedures related to regulatory requirements
Health and safety plans and standard operating procedures
The TSRs will normally have administrative staffing requirements for facility operation in the shutdown mode. The current operations department administrative procedures may require modifications in order to continue to meet TSRs, especially for staffing in the shutdown mode. All administrative procedures should be reviewed to determine whether they can provide support to the deactivated-facility operational environment, whether they can be modified to provide support, or whether they are no longer applicable to any expected operational requirements. In particular, this review should identify staffing requirements for special evolutions or conditions anticipated in the shutdown mode. Each administrative procedure must be assessed for regulatory implications and regulatory interface requirements. Where applicable, actions required for facility deactivation or turnover should be initiated with regulatory agencies and any required final inspection or closeout activities identified and planned.
Shutdown operations and surveillance procedures, particularly for structures, systems, equipment, and components needed for extended shutdowns, should be assessed by the EM reviewer to ensure they are current and reflect the applicable regulatory requirements and industry standards.
2.2.4 Facility Operational Safety Open Issues:
Examples:
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Notices of regulatory noncompliance or citations
Print out of issue management system (corrective action list)
Assessment reports (Tiger Teams, TSAs, NS, EH, IG)
Occurrence reports (OR)
Before reviewing applicable parts of facility TSRs and SARs, the EM reviewer should evaluate the latest order compliance assessments and related documentation and determine the status of facility order compliance. The schedule for attaining order compliance may be contained in CSAs or in composite facility schedules and should be considered to be of continued validity for the transition process. In many cases, budgets and resource allocation plans may have already been initiated for meeting CSA requirements. Deviations from approved CSAs and EXs must be addressed in a formal and comprehensive manner. The responsible facility managers should prepare for the transition process by assessing the impacts of outstanding CSA and EX requests as well as the associated corrective action commitments and compensatory measures proposed to DOE or agreed to by DOE.
The corrective or compensatory actions for specific order compliance and their schedules should be identified and assessed by the EM reviewer in preparation for the subsequent on-site review. Outstanding issues related to maintaining a safe operational configuration of the facility should be included on a comprehensive corrective action list, with the expected disposition under the transition process identified or proposed. If the corrective action list is extensive and available in an electronic database, this information should be made available to EM in electronic form to facilitate the review process and to ensure a continuing management capability upon turnover.
Assessment reports from independent third parties and regulatory agencies normally result in findings and corrective actions requiring long-term corrective actions of importance to safe operations and the protection of the environment. Open issues from all previous facility assessment reports must be made available prior to the site visit and their relevance to shutdown or deactivated plant conditions formally established and verified prior to turnover.
Occurrence reports often reflect significant vulnerabilities, some of which may indicate the need for special measures to be taken during the transition process or that need to be established or maintained in the deactivated condition. The ORPS database of occurrences for the facility should be accessed by the reviewer to obtain reports on facility occurrences for the past couple of years. In particular, the EM reviewer should identify applicable performance trends and recurrent problems related to operations and safety (e.g., criticality safety ORs, shutdown incidents) that may require continued followup and management attention.
2.3 Shutdown/Deactivated Facility Operations and Safety Onsite Review
2.3.1 Inspect:
2.3.1.1 Current control area operations
Are activities in the control room or at the operations station conducted in a formal manner or have operational standards been relaxed in anticipation of plant deactivation?
Is the administrative workload minimized for those operators responsible for monitoring instrumentation and operating the controls or are personnel distracted by transition or plant deactivation activities?
Are control room consoles, instrument panels, and computer consoles being maintained and operated by shift operating personnel using approved procedures or have operations been compromised as a result of diminished levels of production operations?
Are control area logs still being reviewed periodically by operations supervisors and managers or has this oversight activity been abandoned?
2.3.1.2 Equipment areas for general condition and current status.
Is the overall facility housekeeping condition adequate to support safe transition and decommissioning?
Are combustible materials and debris promptly cleaned up and removed from the facility?
Is the current status of equipment being recorded and tracked (e.g., the status of equipment that is tagged for maintenance or repair is recorded by some central control function), or has attention in this area been affected by the anticipation of facility shutdown and turnover?
Are equipment and components labeled adequately to meet shutdown and decommissioning requirements?
Is information on component or equipment labels consistent with information found in facility procedures, valve lineup sheets, and piping and instrument diagrams, or has the updating of configuration management documentation been neglected?
Are proper safety precautions taken for areas around equipment under maintenance (e.g., routine electrical safety precautions observed, hazardous areas or open equipment roped off to prevent access), or is safety being neglected because of a relaxation in management expectations and performance standards?
Are changes in equipment status appropriately documented and communicated to appropriate operating personnel in a timely manner, or has status control been lost?
Are activities that affect the safety or operational status of installed systems and equipment authorized by appropriate operations personnel, or have unqualified personnel assumed that such activities no longer require formal approval and close management?
Do personnel properly align or check for proper alignment of individual components before placing equipment or systems into operation, or has operational formality been compromised?
2.3.1.3 Operating tags and turnover status sheets.
When there is a possibility for equipment damage or personnel injury due to inadvertent actuation of equipment, is the lockout/tagout program being used or has control in this area been lost?
Are lockout/tagout devices applied and removed only by qualified and authorized personnel or have unqualified personnel assumed this responsibility?
Is the lock and tag status periodically reviewed to ensure:
- the scope of the lockout and tagout is still applicable;
- the locks and tags are still needed;
- each tag is placed on the proper component;
- tagged equipment is in the proper position;
- only authorized tags are present on components; and
- the information on tags and tagout sheets is accurate, complete, and legible.
For those facilities that conduct operations for only one shift per day, is an effective means in place to ensure that equipment is placed in a safe condition and that back shift security, custodial, or maintenance personnel can properly respond to abnormal conditions?
Are inspection deficiencies addressed and resolved promptly (e.g., large oil leak on an operating pump, large flange leak on a piping flange, or any unplanned leaks of radioactive or hazardous materials, however small, should be given prompt attention) or are deficiency lists increasing?
2.3.1.4 Operating schedules and plans
Does the plan of the day (or similar document) reflect major and critical surveillance and maintenance items that are scheduled in the facility master schedule or the surveillance and maintenance plan, or will this type of document need to be developed and implemented by EM after the facility transfer.?
Is the actual performance of work tracked and compared against the published plan, or will Em need to establish such tracking systems?
2.3.1.5 Shutdown Surveillance Management and Activities.
Is a master schedule used for shutdown surveillance testing? Does it include:
- frequency for each test;
- facility group responsible for performing each test; and
- surveillance test status?
Is the master schedule updated to reflect revisions to TSRs or are requirements no longer managed in a formal manner?
Do surveillance procedures in use include:
- prerequisites and preparations for the test specified;
- acceptance criteria for the test specified; and
- instructions to ensure systems or components are restored to operation following testing?
Are tests performed only by qualified operators, or are nonqualified personnel having to perform tests?
Are formal methods and responsibilities established for the review and evaluation of surveillance test data. How will the test data review process change following facility transfer to EM?
Is the special test equipment required by procedures properly calibrated and in service? Is the calibration program funded adequately to support shutdown operations?
Is effective corrective action taken for unusual data points, trends, or sudden changes identified during a surveillance or are deficiencies rationalized due to impending deactivation?
Are the actions taken for test failures or out-of-specification conditions performed in accordance with TSRs, approved procedures, and DOE reporting requirements; or have corrective actions been neglected due to facility deactivation and decommissioning plans?
Is there adequate consideration of the safety of operators and equipment, or have routine safety procedures been neglected?
2.3.1.6 Control of the plant configuration and status.
Are policies and procedures for determining facility status implemented and scheduled for continuation at an appropriate level following transfer to EM?
Are there provisions for special situations, such as the deactivation and layup of unused equipment or control and correction of abnormal conditions that may be unique to the deactivation or decommissioning processes required for the facility?
Are alignment check sheets or other comparable aids used to ensure that proper conditions are established to support operations, and will these aids be available and adequate to support EM activities? What other aids might be useful to support EM in the performance of deactivation and decommissioning operations?
Are procedures implemented and consistently used to control the placement, removal, and periodic review of temporary modifications (e.g., electrical jumpers, mechanical jumpers, hoses, pipe blanks, and spool pieces); or will such procedures need to be developed or upgraded by EM?
Does the equipment status log clearly identify equipment deficiencies, or will EM need to develop and implement this type of status log?
Do procedures include a requirement to note the type, number, and identification of temporary modifications in the log book for each shift, or will these procedures need to be implemented by EM?
Are comprehensive shift briefings conducted for each shift involved with complex evolutions, or will EM need to upgrade this type of shift routine?
2.3.2 Interview:
Operations Manager
Operating personnel
Personnel performing surveillances
2.3.2.1 Operations Manager
What outstanding operations or safety issues are most critical to the facility in its current configuration and its future configuration (e.g., as described in the deactivation plan)?
What are the proposed approaches to resolve these operations or safety issues?
Are the proposed solutions implemented and successful?
What operations staffing requirements have been identified to support the current deactivation plan?
What are the current operations organization responsibilities? Will the transition process require significant reorganization and downsizing of the facility operating because of reduced workloads, or will the deactivation and decommissioning requirements require significant support by qualified operators and shift sections?
What is the normal level of daily operational activity and workload? How significant are the expected changes in this workload to meet the deactivation and decommissioning requirements?
2.3.2.2 Operating Personnel
Examples:
Supervisors
Operators in control area
Auxiliary operators
What current duties are being performed routinely?
In what ways will these duties change as the facility is deactivated?
What is the most critical function that you perform in your position for this facility? Will this function be needed after the facility is transferred to EM for deactivation and decommissioning?
What is the most important equipment or processes that you operate? Will this be needed following facility transfer?
What types of problems are encountered when operating the equipment or process?
What are the current hazards and hazardous areas in the facility? How will this change following facility transfer to EM?
Describe which TSRs are applicable to your current configuration. Will these TSRs apply following facility transfer to EM? What initiatives have been taken to revise TSRs?
Which operating procedures are applicable to the current operating configuration? Will these procedures be adequate to support deactivation and decommissioning of your systems and equipment?
What types of administrative controls are in place that effect operation of the equipment? Will these administrative controls apply following facility transfer to EM? What modifications might be needed?
What are the current types of problems being encounter during equipment operation (e.g., equipment malfunctions, potential design problems, oil leaks, excessive pump seal leakage, or any leakage of hazardous material)? How significant will these problems be for operations following facility transfer to EM?
Do you feel that you have the proper training, tools, and personal protective equipment to deal with any possible emergencies that may arise? What additional training, tools, and protective equipment will be needed to deactivate and decommission facility systems and equipment?
What is the best approach to deactivating and decommissioning your programmatic equipment? How about the facility installed equipment and systems that support your programmatic equipment?
2.3.3.3 Personnel performing surveillances.
What shutdown surveillances are currently being performed? Which ones will be needed following facility transfer to EM?
Describe the administrative controls for conducting surveillances and testing. Will these be needed following facility transfer to EM? Will changes be needed?
What maintenance and test equipment is required to perform the required shutdown surveillances? What changes will be needed following facility transfer to EM?
What are the reporting requirements for failed surveillances, and where is this guidance defined?
Are there any surveillances that are past due?
Are there any currently required surveillances that cannot be completed due to equipment problems or facility configuration?
Functional Area 3: Physical Plant
3.1 Introduction
The physical plant includes all buildings, facilities, grounds, roads, bridges, underground tanks, and supporting auxiliary, sanitary, stormwater, and utility systems. While some parts of the physical plant may be deactivated and retired prior to or as part of the transition process, those parts of the physical plant that remain in operation following the transition will require continued management and maintenance attention.
3.2 Physical Plant Document Review
3.2.1 Physical Plant Descriptive Information:
Examples:
Site maps and physical plant diagrams
Plant diagrams of the following systems:
- electrical distribution
- ventilation ducts, filters, and fans
- process piping
- fire water distribution
- portable and sanitary water piping
- stormwater piping
Site master plan documentation
Configuration management program documentation
Master equipment list for safety systems
List of operating facilities and operating schedules
List of shutdown facilities and maintenance and surveillance requirements
Inventories and locations of radioactive and other hazardous materials
These documents provide the EM reviewer with a general understanding of the facility's operating capabilities and status from the perspective of the physical plant. The reviewer will use the applicable portions of these and similar documents to develop an understanding of the use of each affected facility and the interdependencies among the affected as well as unaffected facilities. In particular, the reviewer should note those aspects of the facilities that may require special attention for environmental monitoring and remediation. In this regard, any production-oriented systems or facilities that may be appropriate to maintain during and after the transition to facilitate environmental monitoring or remediation should be identified for later discussions.
Additionally, the reviewer should identify those elements within the physical plant which will require modifications of hardware, upgrades in personnel support, or procedure changes in order to accommodate the planned transition. For example, utility and auxiliary systems may need to be terminated physically, the associated operating procedures and maintenance strategies may need to be changed, and the personnel required to operate and maintain systems may need to be reconsidered. There may be underground conduit and piping tunnels, firemain loops with buried crossconnect and isolation valves, and sewer and stormwater systems that will be impacted by transition and deactivation processes. This type of information should be identified and assembled by facility managers in preparation for the turnover process. While turnover information for some of the physical plant may be assembled on a system basis or on a building-by-building basis, it is expected that the more complex facilities and systems will require detailed documentation and planning at the component level.
Besides physical plant information expected to be directly applicable to the transition and decommissioning process, there may be additional reference or record documentation that should be identified and turned over. These documents may contain information regarding landfills, wells, mines, historic sites, airspace restrictions and flight patterns, topographic and hydrologic data and charts, and site buffer zone information. Transportation related documentation may be particularly valuable and should include all available information on roadway and railway design. Information regarding critical physical plant design criteria or features for protection against wind, earthquakes, tornadoes, floods, landslides, and subsidence should be identified and turned over to EM.
3.2.2 Physical Plant Open Issues:
Examples:
Work schedules and budgets
Current work backlog listings
Inspection results and corrective actions
Occurrence report corrective actions
DOE Order Compliance Program assessment reports, with corrective actions and schedules
Compliance Schedule Approvals and Exemption Requests
EPA and OSHA noncompliance citations and fines
Print out of issue management system corrective action lists
Assessment Reports (e.g., Tiger Teams, TSAs, NS, EH, IG)
These documents provide the reviewer with a more detailed perspective of the physical condition of the plant, its current equipment and management problems, and its compliance status. The reviewer should attempt to determine whether specific issues have already been identified that need to be addressed as part of the physical plant transition process. Some issues may be eliminated as a result of program elimination or facility retirement; others may remain after the transition. A general appreciation for the magnitude of resources and effort required to resolve the remaining issues should be developed.
3.2.3 Physical Plant Long-Term Plans:
Example:
Safety Analysis Report
Deactivation plans
Transition plans
Emergency preparedness plans
Each facility should have a formal decommissioning or deactivation plan that conforms with the life cycle safety requirements contained in DOE 5480.23, "Nuclear Safety Analysis Reports" (SAR). Specifically, this order requires that, "Final SARs for new and existing facilities should include conceptual plans for decontamination and decommissioning. These plans should demonstrate care in the planning of operations and the evaluation of vulnerabilities to a spectrum of events, including accidents, to avoid unnecessary burdens, to minimize site or environmental contamination that would conflict with EPA requirements and complicate decommissioning or otherwise limit the ultimate effectiveness of environmental restoration, and to prevent an increase in residual risks during or after decommissioning." The reviewer should study such information in detail. If it does not currently exist, it may need to be developed as part of the physical plant transition process. The reviewer should also compare the physical plant long-term plans with the criteria contained in draft DOE Order 5480.NNFDC, "Non-Reactor Nuclear Facility Design Criteria," and DOE Order 6430.1A, "General Design Criteria," as appropriate.
3.3 Physical Plant On-Site Review
3.3.1 Inspect:
Major building material condition (see Transition Maintenance review): foundations, roofs, ventilation systems, electrical systems, I&C equipment, preservation (paint)
Heavy loads movement-related features: cranes, elevators, access roads, bridges, rail support, rigging gear
Facilities already shutdown, obsolete, or retired in place
Safety systems and plant and environmental monitoring systems
General facilities and power plant support: diesel generators, boilers, steam distribution, auxiliary systems (including potable, sanitary, and stormwater systems)
Landfills, wells, mines, utility tunnels, outdoor storage areas, underground storage tanks (UST), transformer yards, aviation facilities, buffer zones, and security facilities
Note: The items specified above should only be inspected or assessed in detail if they are part of the facilities proposed for transition or support facilities needed for the associated decommissioning process.
Inspection Guidance/Questions:
The reviewer should conduct a thorough inspection of the physical plant being transferred to EM. This inspection should involve touring exterior areas, especially in the areas of highly exposed systems such as circulating water intakes and pumps; interior areas that are not within contamination control areas, including control rooms, store rooms, and rooms containing facility systems and equipment; and any contaminated control areas and radiation areas. During the inspection, the reviewer should note the following and assess the possible impacts of the current physical plant material condition on transition activities:
the amount of corrosion (rust) on facility equipment
deteriorated or inaccessible equipment or any structural damage
housekeeping deficiencies due to the presence of stray or loose parts, tools, or equipment
valve stems or other components that are painted improperly, making them inoperable or likely to cause damage during operation
fluid system pressure gages that are out of calibration or have no calibration stickers
water or other liquids in unexpected or non-design locations, caused by leaks, spills, or condensation
poorly maintained or missing labels, brackets, insulation, paint, and valve handwheels and stems
storage areas that are inappropriate, not orderly, or not sufficient for all storage needs
improper use of temporary power lines
Additionally, during the physical plant inspection process, the following questions should be addressed on a preliminary basis by the reviewer in discussions with assigned escorts. Areas of concern and those questions not adequately addressed as part of the facility inspections should be followed up on during the subsequent interview process.
What major physical plant work is in progress, planned, or deferred that is related to the transition, decontamination, decommissioning, or the long-term viability of the physical plant?
What buildings or facilities are currently shutdown, abandoned, or not in use? Do they represent significant vulnerabilities?
What inspection or assessment activities are ongoing or should be undertaken to establish and maintain control of the physical plant through the transition process?
Which areas or buildings of the physical plant are currently used to contain or handle radiological or other hazardous materials? Which areas or buildings of the physical plant are contaminated by radiological or other hazardous materials? What changes in these conditions are expected prior to turnover, during the deactivation process, and during the decommissioning process? What will be deferred and done as part of the final decontamination process?
Which areas or buildings have containments or control areas for controlling the release of radiological or other hazardous materials? What are the expectations for maintaining the continued integrity of these containments through the transition process?
Which areas or buildings are expected to be used to contain or handle radiological or other hazardous materials following the decommissioning and transition process? Which areas or buildings are expected to become contaminated by radiological or other hazardous materials following the decommissioning and transition process?
What facilities currently have human-entry restrictions (e.g., storage areas and tanks), and what are the reasons for these restrictions? What facilities will have to be added to the list as a result of deactivation and decommissioning?
On a facility or building basis, what physical plant activities are planned to prepare the site for turnover?
What decontamination facilities are available for personnel, laundry, and equipment? Will these be adequate to support transition activities?
What waste management and processing facilities are available? Will these be adequate to support transition activities?
What emergency and shelter facilities are available for personnel? Will these be adequate to support transition activities?
What is the status of lightning and flooding protection systems for the site? Will upgrades be needed?
What areas, buildings, systems, and equipment need to be inspected more formally (details documented) as part of the transition process?
What physical plant areas or conditions need to be photographed or otherwise documented for future reference?
What facilities, systems, or buildings may pose safety or environmental problems during demolition?
What instrumentation, alarm, and communications systems could be useful during and after the transition? Are there plans in place to ensure their availability?
What auxiliary and utility systems will be needed during and following the transition process?
Can the site or portions of the site be completely deenergized and unmanned? Would this be an advantage to EM?
What facility equipment will be or should be transferred to another site for continued use?
- Contaminated tools and equipment
- Uncontaminated tools and equipment
- Movable major equipment (e.g., gloveboxes, vehicles, tanks, metal buildings)
- Process or experimental system components
- Auxiliary system components (e.g., diesel generators, transformers, air compressors, pumps, valves)
3.3.2 Interview:
Responsible managers or directors for each building or facility to be turned over
Physical plant maintenance support managers
Capital equipment/physical plant maintenance supervisors
Auxiliary system and utility managers and points of contact
During the interviews, the issues raised during the inspection process, any remaining inspection-related questions, and the additional questions that follow should be addressed:
What configuration management procedures and information (databases and documentation) are in place that may help in the transition, support decontamination and decommissioning, or ensure the long-term viability of the physical plant?
What support functions currently provided will be needed during or after transition?
What facilities and equipment might be useful (or be converted to be useful) during the transition and deactivation phases for transition administration activities, including document storage and review. What facilities and equipment might be used to support facility deactivation and disposal work?
What sanitation and waste management facilities will be needed during and after the transition?
What procedures or other documents are available that provide physical plant information or guidance on long-term layup or mothballing of buildings, systems, and equipment?
What facility equipment should be sold as part of the transition and deactivation processes?
What obsolete or other unique equipment or facilities require special attention (e.g., hot cells, reactors, accelerators, laboratory sink drain systems, underground tanks, contaminated tanks, gloveboxes) regarding their current or eventual disposition?
What postings and signage will be needed during and following the transition?
What agreements have been made with local utilities regarding ownership and maintenance interfaces? How will these agreements and the associated hardware be affected by the decommissioning of plant systems?
How will the transition process impact the current physical plant management and operating contracts?
What current physical plant support-contract funding issues and responsibilities will continue into the transition (i.e., for 3 to 5 years), and what effects will the transition to a decommissioned condition have on them (e.g., if they are no longer needed, how and when can they be terminated or otherwise modified to be consistent with the changing support needs)?
What physical plant regulatory requirements (e.g., TSRs, permits, and monitoring) will require continued attention during and after the transition?
What civil engineering issues (e.g., related to roads, bridges, seismic design, and storm drainage) will remain upon turnover or develop (within 5 years) following turnover?
What procedures and plans are in place to render safe (e.g., blank flanges on steam lines where steam driven equipment is removed) those plant systems (mechanical and electrical) or facilities that are partially disassembled (cannibalized) currently or in the future?
What physical plant periodic deficiencies (e.g., OSHA-related, roof leakage, electrical faults) will continue or will recur during the transition or after transition?
Functional Area 4: Transition Maintenance
4.1 Introduction
It is very important to determine the nature of the maintenance and surveillance program requirements and capabilities needed prior to, during, and after the transition process. The reviewers minimum objective is to determine (at least) the changes in the level of effort and areas of emphasis needed for maintenance and surveillance during the transition and deactivation periods. One way of accomplishing this is on a component-by-component basis, where the maintenance requirements for each item are considered in terms of the item's current state and final disposition. Since this may be an unmanageable or extremely difficult task, it may be appropriate to use a prioritized or graded approach. To facilitate these activities, a database can be established for tracking service status, movement, maintenance, and eventual disposition of the individual components. Ideally, the current automated maintenance program procedures can be used to support decommissioning. Once this basic planning has been done and appropriate support equipment identified, the transition maintenance program that will ensure a successful transition between the current state and final disposition can be identified for each component and consolidated for systems and facilities. High priority (i.e., safety related) or resource intensive requirements should be identified and scheduled, as appropriate, but a balance also needs to be established between short and long term requirements.
For some equipment, the transition process may include removal from the facility, temporary changes of custody during multiple storage and transportation environments, and eventual installation and maintenance at a new location. Such equipment is likely to be of high value and should be maintained during the transition process such that it remains functional for future use at other facilities. From the perspective of transition maintenance activities, each piece of equipment being stored in place or being moved requires an appropriate level of continuing maintenance program support, including assignments of responsibilities, provision of the appropriate resources, and planning and scheduling of the needed maintenance activities. For some equipment, special layup procedures and vendor support may be needed.
During the EM review of the current and planned transition maintenance programs, the reviewer should verify that the facility managers have identified and planned for any unique maintenance requirements. This review should include ensuring that facility managers have identified any additional equipment that may be needed to accomplish the disassembly of major facility systems and equipment and that they have planned for its acquisition and use. Also, the reviewer should assess any plans and available resources for meeting routine maintenance requirements following the transition.
4.2 Maintenance Document Review
4.2.1 Maintenance Program Descriptive Information:
Examples:
Current and projected maintenance organization charts
Current and projected maintenance facility resources (e.g., shops, equipment, and personnel)
Current and projected master equipment lists for installed equipment safety systems and for programmatic equipment being transferred to EM
SAR (safety system functional and maintenance-related information)
Maintenance related TSRs
Lists of out of service or decommissioned equipment
Lists of high value equipment being relocated
Prior to the site visit, the reviewer will review maintenance-related facility documentation and develop an understanding of the current facility maintenance program requirements and resources. Some of these resources will be needed to support continuing facility maintenance requirements following turnover. In addition, the plans for transient maintenance requirements associated with decommissioning and equipment relocation should be evaluated. To the extent feasible, the EM reviewer will identify the transition and post-turnover safety system requirements and the associated maintenance requirements independently from information provided by the current facility managers. During this independent review, potential areas of difficulty will be identified for further discussion as part of the site visit.
4.2.2 Maintenance Deficiencies and Issues Information:
Examples:
Maintenance backlog
Maintenance related occurrence reports and corrective actions
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Noncompliance citations related to EPA and OSHA regulations
Printout of applicable issue management system corrective action lists
Applicable portions of independent assessment reports (e.g., from Tiger Teams, TSAs, NS, EH, IG)
The reviewer should scan deficiency lists for maintenance related issues to identify safety related or long-term items that need to be discussed with maintenance managers. For those items that could require significant planning or resources, responsibilities and turnover requirements should be discussed during the site visit.
4.2.3 Maintenance Long Term-Plans:
Examples:
Maintenance Implementation Plan
Surveillance and maintenance plans
Long term lay-up procedures
Maintenance manning requirements during transition
Deactivation plans
Transition plan
In addition to developing an understanding of general maintenance requirements and issues, the reviewer should assess currently available maintenance program information and procedures that directly affect the post-transition maintenance program. The current plant maintenance managers and supervisors should apply their specific knowledge and experience to revise long-term maintenance plans and schedules based on the expected impacts of the transition and turnover process. Information provided for maintenance should be consistent with that provided for operations. The respective EM reviewers should review information for consistency and provide mutual support in addressing their areas of concern.
4.3 Transition Maintenance On-Site Review
4.3.1 Inspect:
In the field:
The general condition of the physical plant (see also the Physical Plant review section)
Shops and laboratories (e.g., electrical, mechanical, instrumentation, and calibration)
Parts warehouses and storage
Safety system condition
Effluent and in-plant monitoring systems for both radioactive and hazardous materials
Principal technical references and records:
Technical library/records
Preventive maintenance records and automated administrative support
Material history and deficiency records
Inspection Guidance/Questions:
The reviewer should conduct an inspection of the physical plant, identifying potential maintenance needs and resource issues that may impact the transition process. For major equipment that will be turned over, the reviewer should verify the availability of technical information and assess the completeness of maintenance records. For all equipment, the reviewer should determine the general effectiveness of the current preventive maintenance program. The reviewer should then assess the plans for the modification and continued use of the preventive maintenance program following the transition.
During the maintenance program inspection process, the following questions should be addressed on a preliminary basis by the reviewer in discussions with assigned escorts. Areas of concern and those questions not adequately addressed as part of the inspection process should be addressed during the subsequent interview process.
What inspection or assessment activities are ongoing or should be undertaken to establish and maintain control of maintenance requirements?
What maintenance activities are resource intensive and require tradeoffs in the planning and scheduling process over the short term and long term?
What maintenance work is in progress, planned, or deferred that is related to the transition or the long-term viability of the systems and equipment that will continue to be needed at the site or facility?
What buildings or facilities are being maintained (inspected, repaired, or serviced by utility or auxiliary systems) that are currently shutdown, abandoned, or otherwise not in use?
Which areas or buildings requiring routine maintenance are currently used to contain radiological o