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 or other hazardous materials, contaminated with radiological or other hazardous materials, or used to handle radiological or other hazardous materials (specify each)?
What facilities and equipment might be useful (or could be converted to be useful) for maintenance work during and after the transition process?
What equipment (e.g., boilers, reactors, cooling towers, auxiliary fluid systems) will require implementation of layup procedures?
What operational and monitoring instrumentation, alarm, and communications systems will need to be maintained during and after the transition?
What configuration management information (databases and documentation) are in place that may help with maintenance work during the transition or ensure the long-term viability of the systems and equipment that will continue to be needed at the site or facility?
What sanitation, stormwater, and waste management facilities will have to be maintained during and after the transition?
What surveys or controls are in place that identify and manage maintenance-related hazards such as asbestos, lead, hazardous material, and confined space entry?
4.3.2 Interview:
Maintenance program managers
Shop and laboratory supervisors
Planners and schedulers
Preventive/predictive maintenance engineers
Safety system engineers and maintenance personnel
Backlog managers
Interview Questions:
The reviewer should address issues identified during the documentation review and inspection activities with the responsible maintenance program managers and supervisors.
What level of planning and scheduling support will be needed to support maintenance work requirements that will carryover into the transition or impact the long-term facility status?
What maintenance and repair requirements (including TSRs) for critical facilities or safety systems will carryover into the transition or impact the long-term facility status?
Are there any critical repairs which should be completed to either maintain the appropriate safety and environmental protection envelope or to prevent deterioration?
What impacts will critical repair requirements have on costs for long-term deactivation, decontamination, and decommissioning?
What screening has been accomplished so far (and what is planned) for identifying preventive maintenance work requirements that will carryover into the transition or impact the long-term facility status?
What mix of maintenance supervision and technical skills will be needed during and after the transition process?
What training and qualification requirements will be applicable to maintenance personnel during and after the transition process?
What mix of spare parts and supplies will be needed during and after the transition process? How are these parts and supplies procured and controlled?
What equipment will be required to be maintained during and after facility deactivation? What equipment and tools will be needed by maintenance personnel to maintain this equipment? Does this equipment have up-to-date vendor documentation?
What maintenance support functions currently provided will be needed during or after transition?
What procedures or other documents are available that provide maintenance information or guidance on long-term layup or mothballing of buildings, systems, and equipment?
What maintenance related contracts are in place that will impact the transition process?
What maintenance contract funding issues and responsibilities will continue into the transition (i.e., for 3 to 5 years)?
Is facility safety equipment and system configuration management documentation available and used to identify and maintain the design intent of equipment?
What procedures are in place (or needed) that manage the process for physically controlling and labeling equipment with status and disposition information?
What maintenance funding requirements have been identified or need to be assessed for the facility over the next 3 to 5 years?
What are the estimated changes in resources required for maintenance in the production (or facility operational) status and those required after turnover for transition maintenance and deactivation maintenance?
What operations related to equipment disassembly and layup are not clearly included in the existing procedures, and what new equipment may be needed to facilitate this work?
Functional Area 5: Environmental Protection &
Waste Management
5.1 Introduction
A major consideration in the transition process is the degree to which facilities and the environment surrounding them are contaminated with radioactive and hazardous materials. EM will have final responsibility for dealing with a range of remediation requirements in this area, and it is important to avoid or minimize any further contamination problems which might result from the facility deactivation and decommissioning.
This functional area includes both the environmental protection and waste management functions performed at DOE facilities. Environmental protection pertains to activities performed by a facility to monitor the past or present effects of facility operations on the environment. Environmental monitoring is used as a basis for evaluating environmental impacts. Monitoring programs commonly include the following media: air, soil, sediment, biota, surface water, and groundwater. The reviewer is tasked with identifying the current compliance status and the continuing upgrade and remediation requirements that will become the responsibility of EM upon facility transfer. The immediate objective is to ensure the availability of the support programs and resources needed for environmental protection upon facility transfer to EM.
Waste management activities ensure that wastes generated at DOE facilities are managed in a manner that provides protection for the health and safety of employees, the public, and the environment. The generation, treatment, storage, transportation, and disposal of waste from DOE facilities must be accomplished in a manner that complies with all applicable Federal, state and local safety and health regulations. Waste management also includes the minimization of waste generation, and the minimization of the releases of hazardous and radioactive wastes, both of which are regulatory requirements. Proper waste-stream management directly supports environmental protection, so these functions will be reviewed together when feasible.
Understanding the status of both of these critical functions at DOE facilities is crucial to any evaluation of environmental cleanup costs and potential liabilities that affect the transition process.
During the document reviews and site inspection and interview activities, the reviewer should focus on learning as much as possible about past and present waste management and disposal practices; the status of regulatory compliance programs; past, present, and future cleanups at the facility; and the scope of environmental monitoring programs at the facility, including the tracking, control, and management of radioactive and hazardous wastes. The reviewer should then develop an understanding of how EM can most effectively take over these functions and use them as continuing support elements during the decommissioning and remediation processes.
5.2 Environmental Protection/Waste Management Document Review
5.2.1 Facility-Wide Documents:
Examples:
Federal facility compliance agreements (FFCA)
Interagency agreements
Letters of agreement
Annual environmental reports
NEPA documents (e.g., EAs, EISs, FONSIs)
EPA or state noncompliance citations and fines
Waste management plans
These documents provide the reviewer with an overview of the status of environmental protection and waste management issues at a facility. Because they cover an entire facility, these documents offer the reviewer a broad perspective of problems, including critical issues, that may significantly affect the planned transition. Based on a review of these documents, the reviewer should develop an understanding of the facilitys compliance status.
5.2.2 Federal and State Permits & Support Documents:
Examples:
Applicable State Laws and Regulations (copies)
Air Permits
NPDES Permits
Wetland (Section 404 Clean Water Act) Permits
Safe Drinking Water Act standards and permits (for both water systems and underground injection)
RCRA Permits
TSCA-related documents
Toxic chemical release forms
Hazardous material inventory forms
These documents pertain to written materials that address specific permit requirements that must be met. The focus here is on regulatory compliance issues associated with individual programs that affect the transition process. For example, the Safe Drinking Water Act establishes maximum contaminant levels (MCL) and maximum contaminant level goals (MCLG) as standards for cleanups that may be required at a facility. Based on a review of these documents, the reviewer should develop an understanding of the status of compliance with active permits, such as those issued under the CWA, CAA, and RCRA. In many cases, state agencies may have requirements that are more stringent than Federal standards. Additionally, some of the permits and agreements may become unnecessary once the facility is transitioned. The reviewer may also observe that Federal or state permits that appear to be required (based on a review of facility-wide documents) have not yet been obtained.
5.2.3 Documents Relating to Corrective Action Sites and Priorities:
Examples
List of CERCLA/NPL sites
Preliminary assessments
Site investigations
Remedial investigations
Feasibility studies
Remedial design
Records of decision
Title III documents
The reviewer should review documents pertaining to studies or cleanups being performed under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA, also known as Superfund). CERCLA was designed to provide for response to and cleanup of, environmental problems that are not adequately covered by the permit programs of other environmental laws. CERCLA establishes a schedule for cleanup of Federal facilities, a schedule under which many weapons complex facilities are currently operating. The reviewer should determine the number of NPL sites at each DOE facility (if any) and, to the extent possible, expected cleanup costs and residual environmental liabilities that will remain when the facility is transitioned. The reviewer should also become aware of the status of outstanding corrective actions from audits, inspection, self assessments, and other similar reviews that are not related to the CERCLA cleanup process.
5.2.4 DOE Plans & Reports:
Examples:
Assessment reports (e.g., Tiger Teams and others)
Occurrence reports
Deactivation plans
Transition plan
Transportation plans
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) Requests
Issue management system data (printout of corrective action list)
SAR (waste management)
DOE facilities are subject to several Federal laws and regulatory programs, as well as a host of DOE orders which define categories of waste and assign regulatory responsibility to various agencies for these wastes. The reviewer should identify those documents that pertain specifically to DOE environmental requirements and evaluate the extent to which these requirements have been, and are currently being met, including the use of best management practices.
5.2.5 Generic Document Questions
To the extent that the documents listed in sections 5.2.1 through 5.2.4 are available, they should be screened for information potentially applicable to EMs responsibilities following facility turnover. They should also be reviewed for answers to the following questions, with emphasis on how the answers impact the transition process:
What are the biggest environmental problems at the facility? Have any environmental penalties, fines, or cease-and-desist orders been issued to the facility owner or operator?
To what extent has facility characterization already been completed?
What environmental permits have been obtained? What permits are still needed to comply with Federal, state, and local environmental regulations? Are there any other areas of noncompliance that need to be addressed? What permits will need to be changed to accommodate the transition process? Will there be new sources or new hazardous materials in the release that may require new permits or major modifications of permits? Are there permits which can be deleted based on the facility transition?
What media pose the greatest threat to human health and the environment (e.g., soil, surface water, groundwater)?
What contaminants at the facility pose the greatest risks to human health (e.g., organics, heavy metals, radioactive wastes)?
How much uncertainty is there with respect to the current understanding of the magnitude of the problem and anticipated environmental cleanup costs?
5.3 Environmental Protection/Waste Management On-Site Review
The on-site review affords the reviewer an excellent opportunity to pose numerous questions to the assigned escorts. The following list of questions cover many of the topics that will need to be addressed during the transition process. Areas of special interest and questions not adequately addressed during the facility inspection should be further investigated during the subsequent interviews with facility representatives.
5.3.1 Inspect:
5.3.1.1 Waste Management Areas
Where in the facility process are wastes produced (sources)?
What types of waste are at this facility?
What forms are the waste in (chemical, radioactive; solid, liquid, gas)?
What is the overall level of radioactivity of wastes in terms of curies on site?
What is the amount of waste generated and stored at the facility?
Are waste facilities in compliance with RCRA interim storage requirements?
5.3.1.2 Storage Sites and Burial Sites
Where are wastes stored or buried on site?
Are waste storage sites monitored?
Where are the data on waste burial and storage maintained?
What is the type and quantity of waste stored or buried at the facility?
Are there any wastes generated at other sites that are buried or stored at the facility?
What is the permit status of each storage or burial site?
5.3.1.3 Underground Storage Tank (UST) Locations
Where are the USTs located?
What is the likelihood of finding additional USTs on the site?
Have State authorities been notified about USTs?
What is the permit status of each UST or UST site?
What are the contents and capacity of the USTs?
If contents are radioactive, is it considered low level, high level, or TRU waste?
Do any of the USTs contain, or have they ever contained hazardous materials?
What are the materials of construction (e.g., steel, fiberglass, concrete; double walled tanks)?
Are USTs regularly monitored for leaks?
What type of leak detection is used (e.g., interstitial monitoring, sticking)?
Has there been any groundwater monitoring done around USTs to determine whether they have leaked?
What types of corrosion protection are used, if any (e.g., impressed current, sacrificial anodes)?
What is the status of the USTs? Are any still being used?
Have there been any known releases from the USTs?
What is the status of these releases?
5.3.1.4 Landfills
What are the landfills at this site?
What types of materials have been disposed of in these landfills?
Are these landfills monitored for leaching?
What is the permit status of each landfill site?
Are any of the landfills included in a Federal Facility Compliance Agreement?
Does the facility accept waste from offsite? If so how much and what type?
What procedures are used for the handling of waste materials?
Is there any known surface water or groundwater contamination from landfills at the site?
Are any characterization or remediation efforts already underway at any of the landfills?
5.3.1.5 Discharges to the Atmosphere
Check release points against permits and note any omissions.
Note which release points are monitored, and the nature of the monitoring equipment.
Note the use of scrubbers and any other treatment equipment on atmospheric releases.
Note the secondary wastes produced by such treatment, including scrubber sludge, baghouse filters and dust, contaminated HEPA filters and carbon absorbers, and the method of handling and disposal thereof.
5.3.1.6 Surface Water Discharges
Check outfalls against permits and layout plans, and observe the quality of the discharge.
Observe the treatment plants and note any non-functioning process units and the general condition of the equipment.
Compare actual flows against rated capacity and chemical/biological/radioactivity parameters recorded for effluents against permit requirements.
Check methods of handling and disposal of byproduct sludge, scum, and screenings and any measured quality parameters against those governing its disposal (e.g., lead and cadmium in sludge applied to land).
5.3.1.7 Discharges to Soil
Are any wastes, especially liquids, spread on or injected into the ground?
Observe the discharge operation and compare it with any applicable permit requirements.
5.3.1.8 Miscellaneous
Have transformers been used on the site? Which ones, if any, contain PCBs?
Is there an inventory of the PCBs onsite, and what is their disposition?
Are there any areas of the site that meet the definition of wetlands, based on the Army Corps of Engineers guidelines used to implement the Clean Water Act?
Are any activities planned that will require filling of wetlands on the site?
What plans are there for transportation of radioactive and/or hazardous waste to permanent disposal sites, and is there sufficient disposal capacity available?
5.3.2 Interview:
Environmental compliance officers (ECO) and building managers
Field staff (monitoring personnel)
Radwaste managers
Hazardous waste and mixed waste managers
5.3.2.1 ECOs and Building Managers
What documents and regulations guide your site compliance program? Are they affected by the planned transition?
What are the areas of noncompliance at your facility? What nonconformances will be turned over to EM upon facility transfer?
What are the biggest problems you face at the site? How will these be affected by the facility deactivation and decommissioning?
How would you characterize your relationship with the State and citizen groups? Is there any related information or advise that needs to be communicated to EM managers?
Are you involved with any community outreach programs? What level of involvement should be sustained by EM?
5.3.2.2 Field Staff (monitoring personnel)
What is the program plan for personnel monitoring?
What do you monitor for?
What is the schedule and frequency of monitoring?
What is the level of interaction between the ECO and site managers?
Do people generally comply with EPA and state requirements for releases and monitoring of releases? What are the most significant areas of difficulty that may need to be dealt with by EM following facility transfer?
What are the results of past audits at the facility? What trends would be important for EM to investigate and address?
5.3.2.3 Radwaste Managers
What is the program plan for radwaste? Will this need to be upgraded or changed to support operations during the transition?
Where are the current areas of greatest radioactive hazard in the facility? Will this change with deactivation and decommissioning?
Who has the authority over the movement, handling, and storage of radwaste?
Is there a program for final waste disposal? Is this program adequate to support the needs of the decommissioning process?
5.3.2.4 Hazardous Waste and Mixed Waste Managers
Are the locations and quantities of hazardous waste and mixed waste well known? What exploratory activities are recommended in order for EM to establish comprehensive control or all of the facilitys waste?
Is there a program for cleanup, removal, collection, and storage of hazardous and mixed wastes? What will be this programs status at the time of facility transfer to EM?
Is there a program for remediation of soil and groundwater contamination? What will be this programs status at the time of facility transfer to EM?
Is there a program for transporting hazardous and mixed wastes offsite and for disposing hazardous and mixed wastes? What will be this programs status at the time of facility transfer to EM?
Functional Area 6: Occupational Safety and Health
6.1 Introduction
The occupational safety and health functional area includes industrial safety, industrial hygiene, and control of hazardous and toxic substances (see definitions).
During performance of the range of facility deactivation, decommissioning, and decontamination tasks, it is expected that many occupational safety and health issues associated with unique procedures or transition requirements will have to be anticipated and addressed. If the facility is already in compliance with the numerous occupational safety and health requirements mandated during normal operations, managers will be able to focus their attention on the emergent or unique transitional requirements identified during and after the initial screening review.
Since most facility physical plants being screened for transfer to EM are expected to be in relatively poor condition, it must be assumed that this deteriorated condition will have significant impacts on occupational safety and health. Thus, in addition to physical plant and maintenance inspections, the screening effort must include a comprehensive review of the plant condition for current and potential safety issues that may become important during the transition and decommissioning. Even after the initial screening and turnover tasks are completed, EM will continue these inspections and reviews in order to ensure personnel safety during process system deactivation or maintenance, component removal, area and tank decontamination work, and all other activities associated with final facility disposition.
Some additional complexity is anticipated in these post-operational safety reviews because the nature of the safety requirements associated with each component may change. For example, deactivated components normally requiring protective guards for rotating elements need no longer have such guards, but the lifting hardware associated with the components removal will have to be identified and procured, and this hardware may require load-testing and certification. Likewise, tanks and compartments that are normally full or ventilated during operations (i.e., locations not normally considered a hazard) may require the use of special void-safety precautions and protective clothing during decommissioning. Consequently, the potential for these types of unique requirements needs to be assessed during the screening process and on a continuing basis. In addition, decommissioning procedures may need to be developed that systematically prepare for and meet these requirements in a manner that meets the expected levels of formality for conduct of operations.
6.2 Occupational Safety and Health Document Review
Occupational safety and health records are expected to be an important source of information for establishing the current worker safety status at the facility. Historical data may also establishes the presence of a contaminant having environmental significance. Elevated personnel exposures to toxic chemicals, dusts, and metals in the past may be found in medical records and occurrence reports and may indicate the need for special health and safety evaluations during the transition screening process. Other health and safety records, such as safety committee minutes and job safety analyses, may also suggest areas of continuing or increased liability.
6.2.1 Facility Specific Documents:
Examples:
Health and safety plans
Safety Committee minutes
Hazard communication program documents
Chemical Hygiene Plan for laboratories
OSH Hazard Abatement Management Log
Management plans for specific agents such as asbestos, lead, and PCBs
Hazardous material inventories
Health and safety standard operating procedures
Employee exposure monitoring data
Emergency plans
Confined space inventories
Job/worksite hazard analysis
OSHA inspection reports
OSH compliance reports
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Corrective action list from the issue management system
Annual inspection reports
Hazardous material release and inventory forms
DOE sites are evaluated regularly for compliance with a wide range of regulatory requirements, from OSHA standards to DOE Orders. These reports can provide excellent insight into the problems at the site and the amount of progress made in rectifying the problems. Similarly, Compliance Schedule Approval requests and Exemption requests can provide insights into the specific health and safety requirements the facility managers already know that they were not able to meet during normal operations. The reviewer is likely to find areas in which the same or similar issues apply to the transition and decommissioning processes. Regardless of final decisions regarding such continued applicability, each currently know hazard will have to be assessed across the entire range of conditions expected following facility shutdown and through final disposition.
Some facilities also conduct formal annual inspections which provide a valuable chronology of health and safety problems. The reports from such inspections will provide the reviewer with additional leads regarding potential health and safety issue liabilities that may evolve or reappear during the transition process. Other documentation such as hazard communication programs and chemical hygiene plans will provide detailed information on the current chemical hazards in the facility and how these hazards are currently being controlled. The reviewer will have to extrapolate all of this information into the transition process in order to be able understand the full range and level of the continuing vulnerabilities.
Another excellent source of current or baseline hazard information is the OSH Hazard Abatement Management Log which many facilities maintain. This computerized system not only lists the facilitys known health and safety hazards but also indicates the OSHA standard that is violated, the relative risk associated with the hazard, the cost to abate the hazard, and the expected correction date. Such a listing, if available, would provide the reviewer with an additional frame of reference or point-of-departure for determining the likely health and safety hazards that will need to be addressed during the transition and decommissioning processes. Similarly, facility management plans for specific toxins such as asbestos may also be available and will provide initial information regarding the forms of the specific hazard already identified and the current level and extent of the associate hazards that will need to be addressed further during decommissioning and decontamination projects.
Prior to the site visit, the reviewer will assess this site-specific health and safety information relative to the facility descriptive or background information (listed in Section 6.2.2 below). This will provide the reviewer with an understanding of the current health and safety situation at the facility and will allow the reviewer an opportunity to identify additional hazards and physical plant areas to investigate during the onsite visit.
6.2.2 Facility Background Documents
Examples:
Safety Analysis Report (SAR)
Tiger Team reports
Occurrence reports (emergency response, fires, major spills, major accidents, fatalities, evacuation)
Industrial hygiene manuals or guides
Operational safety analyses
Safety and health training requirements
Deactivation plans
Transition plans
These background documents provide facility-wide or plant-wide information that will probably be useful to the reviewer in extrapolating the current occupational health and safety situation to that expected during the transition and decommissioning processes. This is particularly true of the more comprehensive documents like SARs, which often point out potential significant health and safety issues directly, but which also describe the facility process and safety systems and equipment that are supposed to be in place and functional even at the end of design life. Occurrence reports should also always be requested and then be reviewed carefully to ensure that the full health and safety implications of the specific incident have been evaluated, but also to identify the types of hazards for which the systems and the supporting operational or administrative procedures identified in the SAR were not adequate. Also, information on known problems requiring further remediation could be provided. For example, if the incident was a chemical incident primarily involving facility workers, did it also involve a major release to the environment that now requires further review and non-operational acceptance or remediation?
6.3 Occupational Safety and Health Onsite Review
6.3.1 Inspect:
Hazardous material storage areas
Facility areas where equipment or machinery is used, with particular emphasis on large equipment that may need to be moved as part of the decommissioning process
Facility areas where processes are or once were functioning, noting any residual inventories of hazardous materials or equipment
Perimeter of the facility, looking for soil discoloration, distressed vegetation, storm and sewer drain locations, loading docks, and ventilation system filters and plenums
Outside process tanks and lines for general material condition, apparent ability to handle design pressure, and provisions for flushing and removal
Identifying and evaluating health and safety issues requires inspecting facilities, initially focusing on the more obvious areas such as storage areas for hazardous waste and the currently active production areas. It also requires inspecting areas that were in production at one time. There may still be residual chemicals in process lines or tanks, and there may be waste streams that are still potentially active due to effluent lines that have not been fully deactivated. Even in the absence of records, the reviewer should attempt to identify areas that indicate a previous heavy use of chemicals. Settled dust on equipment or surfaces may need to be sampled if there is a paucity of records indicating all of the raw materials used and products made in a specific production area. Also, the reviewer should look for indications such as discolored concrete under transformers that may have leaked PCBs, abandoned storage tanks, asbestos insulation on outside steam lines, distressed vegetation or soil discoloration, and the presence of potential decommissioning process (not yet identified) confined spaces. These and similar types of physical plant issues should all be noted as potential transition issues and high-cost remediation items.
6.3.2 Interview:
Safety and industrial hygiene staff
Building Managers
Present and retired line workers
Personnel responsible for ordering chemicals
Interview Questions:
Interviewing should begin with the industrial hygiene and safety staff and should include facility managers and the personnel directly responsible for the facility maintenance and operations, such as the building. At some sites there are industrial hygienists and safety professionals assigned to specific buildings; other sites have their staff dedicated to specific problem areas, such as asbestos control and removal. The interviews should be conducted in the building or facilities of interest and should include a tour of the facility and its supporting facilities or areas after an initial background discussion.
The lists of questions provided below should be useful in the reviewers preparation for the site visit as well as during the site tours and personnel interviews. The reviewer should use these questions, along with the document review findings to develop specific interview questions before the site visit. Additional interview questions should be developed from the results of the onsite inspection.
Based on the responses of the people interviewed, the reviewer may also determine that it is necessary to interview former employees. It is quite possible that none of the present building staff were in the building from the start, so it may be necessary to call retired workers to get answers to questions about early operations in the building.
General Questions:
What safety and other compliance issues are expected to be most significant to EM upon facility transfer?
What safety related conditions have not been stabilized and may become more significant in the future?
What planning and preparations have already been completed by facility managers to facilitate turnover to EM?
What critical personnel or equipment shortages have been identified that will impact deactivation and decommissioning activities?
Does the current facility meet the original design requirements reflected in configuration management documentation? How will the change control process be affected by turnover to EM?
What additional training and qualifications are needed?
What new procedures are needed for performing deactivation, layup, inspection, monitoring, and control of hazards and hazardous equipment?
Health and Safety Plans
Are there health and safety plans for ongoing remediation activities at the facility?
How many different plans are there? Are they comprehensive and do they correspond to separate or identifiable elements of the facility such that separate plans do not have to be developed to support the transition and decommissioning processes?
Do the descriptions adequately characterize the missions of the site buildings so that the reviewer can extrapolate or modify the plans to meet the decommissioning mission?
Does the hazards assessment clearly identify all of the known chemical, radiological, mechanical, physical, and biological hazards at the site? What changes are needed in order to use the assessment in the transition process?
Do the current safe work practices provide adequate protection from the hazards at the buildings and or site? What safety-related work practices are not documented?
Do the air monitoring requirements address the hazards identified? Are these monitoring requirements consistent with those needed during transition and decommissioning?
What types of personal protective equipment are specified for the work, and what was the rationale for that choice? Is this equipment adequate for personnel protection during decommissioning?
Do the decontamination procedures adequately address the hazards currently identified? Are these procedures adequate for use during decommissioning?
Are there established decontamination level goals for determining when cleanup is complete? Are these unique operational technical specifications or do they apply to the decommissioned condition?
Are there sampling procedures provided for determining when a decontamination effort is complete? Are these procedures adequate to meet decommissioning and decontamination needs?
Health and Safety Standard Operating Procedures
To whom do the health and safety staff report? Do they have authority to stop work? What should be their organizational responsibilities and authorities during the decommissioning process?
Does the site have health and safety standard operating procedures or do they use a combination of OSHA standards, consensus standards, and DOE Orders? What changes are needed to support deactivation and decommissioning?
Who has responsibility for developing and implementing the site-specific operational safety procedures? Will this important assignment need to be changed during or following transition? Will adequate expertise be available to continue operations associated with deactivation and decommissioning?
Are there safety and health management and operating procedures for the full range of hazardous materials, carcinogens, personal protective equipment, decontamination, incineration operations, and confined space entry? Will modifications be required to support deactivation and decommissioning?
Hazard communication program documents
Are material safety data sheets (MSDS) maintained and readily available for each of the chemicals in the facility? Will they continue to be maintained and readily available after facility turnover to EM?
Are carcinogens given special attention? What carcinogens will be present in the facility at the time of turnover?
Chemical hygiene plans for laboratories
Do chemistry laboratories have written chemical hygiene plans as required by OSHA under 1910.1450? Do these need to be modified to support facility decommissioning?
Does each chemical hygiene plan address the handling of carcinogens?
Are areas where carcinogens used separated from other laboratory areas? Will this separation be affected as a result of the decommissioning process?
Does the plan address how laboratory fume hoods are checked to ensure that they are operating effectively? What facility hoods and associated filters and ventilation systems will need to be maintained to support decommissioning and decontamination work?
OSH Hazard Abatement Management Log
Is there a list of all of the nonconformances with OSHA standards? How is this list affected by deactivation and decommissioning activities?
Does this list contain not only the nonconformance but a hazard rating and a proposed date of abatement?
Are the overwhelming number of nonconformances minor items or does the log contain many serious hazards?
Management plans for specific agents such as asbestos, lead, and PCBs
How complete are the asbestos surveys of the facility? Have the buildings and support facilities that are being transferred to EM been characterized?
How extensive is asbestos in the facility? What specific applications are there? Are there any significant amounts of friable sprayed-on materials in the facilities of interest?
Are there cost estimates for the abatement of the asbestos in the facility?
Are there plans for the required removal of asbestos during deactivation, decommissioning, decontamination, or demolition removal?
Have there been systematic surveys for lead-based paint on the interior as well as exterior metal surfaces?
What special requirements and equipment are needed for the safe removal of lead shielding from the facility?
Are exterior painted surfaces routinely sampled prior to oxyacetylene cutting, abrasive blasting, or sanding? What needs to be done to ensure adequate safety coverage during the expected decommissioning and demolition work?
Have all of the transformers been sampled for PCBs? Are all the transformers properly labeled? Which transformers will be used during facility deactivation and decommissioning?
Are there any leaking transformers? What interim corrective actions are already planned? How will decommissioning managers deal with leaking transformers?
Are there current plans and schedules for the removal or disposal of PCB-contaminated transformers? How will these plans and schedules be affected by turnover and decommissioning?
Employee exposure monitoring data
Are there historic records indicating major personnel sampling campaigns for particular agents, such as beryllium or lead? Will similar or additional personnel monitoring be required as part of the planned decommissioning and demolition activities?
Did the results of previous personnel exposure monitoring efforts indicate acceptable levels? What levels can be expected during the planned decommissioning and demolition activities?
Is there a confined space program at the facility? Are modifications to this program needed to support the deactivation and decommissioning processes?
Is there a comprehensive list of confined spaces at the facility? How should additions to the list be identified and controlled after turnover?
Are the actual confined spaces marked with warning signs? What should be done to ensure continued posting of current confined spaces and posting of post-turnover confined spaces, which may be more transient or short-term issues? Do facility work control procedures address confined spaces, or are new procedures needed?
6.2.2.1 Safety Analysis Report (SAR)
Does the SAR meet the decommissioning and decontamination planning requirements specified in DOE 548.23?
Are any significant issues identified in the SAR regarding health and safety or hazardous materials? What additional or increased hazards can be anticipated based on system descriptions in the SAR?
Tiger Team Reports
What specific recommendations were made by previous independent inspectors, and were they carried out?
Occurrence reports
Is there an emergency response plan for each facility hazard? Will such plans require revision to support decommissioning?
Have there been any emergencies which required execution of the plans? Could these same emergencies develop after facility transfer to EM? If so, will the response resources needed be available?
Have there been any fires that involved chemicals, hazardous wastes, or radiation? If so, what residual contamination is possible, and what are the most likely locations?
Have there been any major spills of chemicals? If so, what residual contamination is possible, and what are the most likely locations?
Have there been any major accidents that involved the hospitalization of workers? Will these accidents have an increased probability of recurrence during deactivation and decommissioning?
Do occurrence reports indicate root causes and schedules for corrective actions? What corrective actions are not yet completed? Do they need to be modified as a result of decommissioning plans?
Have there been any fatalities at the facility? Is it possible that similar fatalities will occur during deactivation and decommissioning?
OSHA inspection reports
Has OSHA ever conducted an inspection at the site?
If so, what problems were reported? Were any of the problems significant, and are they likely to reappear following facility transfer??
Were the problems corrected or will they remain for further action following facility transfer?
6.2.3.2 OSH compliance reports/DOE order compliance reports
Is there a part of the organization that regularly conducts inspections to determine compliance with OSHA standards and DOE health and safety orders? Will this element of the organization continue to monitor compliance following facility transfer, or will another organization be needed?
Do plant managers routinely publish reports that track and manage corrective actions? Will this practice continue after facility transfer?
What are the current major OSHA issues reported that will need further work after the transition?
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Does the facility currently have a large number of CSAs or EXs approved or pending? How will the associated corrective actions and compensatory measures be affected by the transfer to EM?
Do the requests reflect significant issues or a lack of manpower or funding?
Annual inspection reports
Is there an annual health and safety inspection conducted at the facility?
Are similar findings being reported year after year such that a chronic problem can be identified?
Does management have ideas regarding approaches to correcting problems that may carryover into the transition and decommissioning processes?
Functional Area 7: Radiation Protection and Safety
7.1 Introduction
At the time of deactivation or transition, a nuclear facility is likely to be at the most radiologically contaminated condition of the facility life cycle. Moreover, the radiological hazards associated with the transition, decontamination, decommissioning, and restoration will include activities involving significant quantities of various radioactive isotopes, possibly exceeding previous experience at the facility. Also, these hazards will often be more challenging due to the unique nature of the work involved and the many concurrent activities that may be undertaken. Finally, routine support programs such as housekeeping and contamination surveys could be disrupted at a time when their efficient operation is most important. Therefore, it is necessary for the current facility managers to anticipate radiation protection and safety needs systematically and comprehensively in order to ensure that the radiological protection program can continue to be effective during the transition period.
During the transition and turnover process, the current level of control over radiological safety hazards will be assessed by EM. Since facility shutdown and deactivation do not necessarily result in reduced levels of radiation and radiological contamination, it is expected that the need to meet the highest standards of radiological protection will continue. All areas of the facility must conform with DOE radiological control guidance prior to turnover, or approved Compliance Schedule Approval (CSA) and Exemption (EX) requests must be in place. In addition, the resources needed to continue the required level of control must be identified and available. It is also anticipated that general and radiation worker training programs will continue and that few, if any, elements of the radiological control program will be eliminated prior to or during the transition process.
The elements of radiation protection and safety include establishing and marking radiation areas for control of personnel access; establishing physical barriers and special procedures to limit the location and movement of radioactive materials; performing routine measurements and tests to determine or to confirm the levels of radiation or amounts of radioactive material in designated locations; maintaining personnel dosimetry and bioassay programs, including accurate radiation-exposure records; establishing shielding requirements for radiation sources; maintaining and calibrating radiation detection and measurement instrumentation; and educating employees concerning radiation hazards and protective measures. These activities must be maintained and effective during the transition process due to the potential increase in radiation exposure associated with the non-standard activities involved in deactivation of a facility. Most of these activities will continue after the facility deactivation efforts are completed.
The facility normal or routine radiation protection activities frequently involve interfaces with the maintenance and operations organizations. Therefore, EM radiation protection reviewers will coordinate their review activities with those in the operations and maintenance areas. They will also independently consider site descriptive information (provided in the physical plant review area) and radioactive material inventories and control records (provided under the radiological and hazardous materials area).
7.2 Radiation Protection Document Review
In preparation for the site visit, EM reviewers will become familiar with the site-specific radiation protection program documentation and records. These include program implementation guidance and records for normal operations, safety analysis and emergency response documentation, and radiation protection issues previously documented or addressed. The review should focus primarily on identifying:
The general radiological conditions of the facility
The radiological commitments of the facility
Type and frequency of radiological surveys currently performed and expected upon deactivation
Current and future radiological staffing needs
Equipment that may be needed in the transition process
7.2.1 Radiation Protection Program Implementation Guidance and Results:
Examples:
Site-specific radiological control manual
DOE Radiological Control Manual (DOE N5480.6) implementation plans
SAR (radiation protection and safety system sections)
Technical design basis documents for facility radiation protection features (e.g., placement of radiation detection and monitoring equipment; placement of dosimetry; shielding design; ventilation flow paths and filtration)
Site-specific safety analysis report and associated radiological requirements and procedures
Radiological protection organization charts and staffing information
Radiological protection equipment inventory lists
Listings and use information regarding sealed radioactive sources
Recent contamination survey results
Radiological control area performance indicator reports
Occupational radiation exposure reports, including trends
Radiological protection information in the deactivation plan
Reports of unplanned releases and incidents
The reviewer will scan this routine program information in order to determine the general scope and effectiveness of the radiation protection program and the level of radiation safety routinely achieved at the facility. From these documents, the reviewer should be able to determine whether the radiological protection program meets minimum DOE standards. If this determination is favorable, the EM reviewers will be able to proceed with the comprehensive site visit. In the absence of an effective radiological protection program, compensatory measures will have to be identified, agreed to, and implemented prior to the EM site visit. For example, additional personnel might need to be assigned to perform manually some normally automatic monitoring or managers might be assigned to supervise control point functions.
7.2.2 Facility Radiological Protection Open Items:
Examples:
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Printout of issue management system (corrective action list)
Assessment Reports (DOE Field Office, Tiger Teams, TSAs, ORRs, NS, EH, IG, QA, M&O Internal Assessments)
Occurrence reports related to radiation protection
The EM radiological protection reviewer will assess the overall implications of the open issues in this area. In addition, the reviewer will identify those open items which require additional inspection and assessment during the onsite visit. Open items must be systematically addressed in terms of their impacts on facility transfer and the transition process.
7.3 Radiation Protection On-Site Review
7.3.1 Inspect:
Radiological control areas (RCA)
All radiation postings
Ventilation systems, monitoring equipment and filters
Housekeeping effectiveness
Vulnerability of radioactive materials to fires and fire fighting
Radiation monitoring equipment operability and condition
Locations and types of radioactive materials
Radiation protection records and records storage areas
Inspection Questions:
During the radiation 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.
Are radiation surveys, postings, and other routine activities current?
Is the ventilation system operating with a sufficient flow rate for facility conditions? Is the ventilation system equipment expected to be adequately reliable to ensure radiological safety during the transition process, or will EM need to consider temporary ventilation system upgrades or backup systems?
Where are HEPA filters located and how often are they tested and replaced?
Is the monitoring and sampling equipment adequate to detect the radionuclides of concern, including those associated with decommissioning and decontamination activities?
Is routine maintenance performed on radiation monitoring equipment, and will instrument calibration and maintenance capabilities be available throughout the transition process until final facility cleanup is completed?
What type of equipment is used for conducting internal dose assessments? Will this equipment be adequate to support decommissioning and decontamination?
Are the radiological control areas clearly identified and controlled to prevent inadvertent access? Will upgrades be required to support deactivation and decommissioning operations?
Is temporary shielding used at the facility? Is the amount of available temporary shielding adequate to support transition activities?
What types of respiratory equipment are available at the facility? Is the respiratory equipment adequate to support transition activities?
Are laboratory fume hoods and sample sinks operable and properly maintained? Are they adequate functionally to support transition activities safely?
Are gloveboxes operable? Is the integrity of gloveboxes adequate functionally to support transition activities safely?
What types of radiological sources are used at the facility? Are they appropriately stored and controlled? What disposition of the radiological sources is planned?
Are radioactive material storage areas adequate? Are the designated storage areas adequate to support decommissioning or will additional areas need to be identified? What impact will additional storage area requirements have on the SAR source-term assumptions and accident scenarios?
7.3.2 Interview:
Health physics and radiological protection staff
Operations and maintenance workers
Building or facility managers
DOE Operations Office personnel responsible for radiological controls matters
Interview Questions:
What are the current radiological hazards and concerns associated with this facility? What impacts will they have on EM following facility transfer?
What is the degree of radiological contamination in the facility? Is this expected to change prior to facility transfer to EM?
What radiation surveys and routine activities are currently performed in the facility? What surveys and activities will be required during and after facility deactivation?
What operations contribute to occupational exposures? Will these operations and associated exposures cease upon deactivation of systems and equipment?
What will be the overall radiological impact of deactivating the facility?
Have there been incidents involving the release of radioactive materials within the facility or to the environment? What issues and cleanup requirements are likely to be passed on to EM?
Has an acceptable contamination limit for unrestricted release of material been established for this facility?
What has been the estimated volume of radioactive waste generated at this facility each year? What volume should be anticipated as a result of decommissioning and decontamination work?
Where and under what circumstances is criticality safety a concern? Is the criticality safety program required to support deactivation and decommissioning activities?
Are building specific radiological procedures established for this facility? Are these procedures adequate to support radiological activities anticipated after transfer to EM or are supplementary procedures needed?
What is the status for implementing the requirements of the Radiological Control Manual at this facility?
What radiological work is planned, in progress, or deferred that is related to the facility deactivation process?
Does the facility have any provisions for performing outdoor air monitoring? Are these suitable and adequate to meet the needs of the deactivation and decommissioning processes?
Are there radioactive materials accumulations in work area ventilation ducts? What will be the status of the associated remediation work at the time of facility transfer to EM?
What are the current and future radiological staffing needs? Are the trained personnel going to be available?
What mix of radiological control technicians, radiological control workers, health physicists, radiation health officers, and radiological control officers will be needed during and after facility deactivation?
What interfaces exist between radiological personnel and operations, maintenance, and waste management personnel? Are these interfaces adequate to ensure coordination of complex decommissioning procedures?
Are there any radiological systems or components that may be of future use in the transition process?
Are radiological training and qualification requirements documented? How will they change as the facility undergoes deactivation?
Do plans exist for the use of temporary shielding during deactivation activities?
What decontamination facilities will be required during and after facility deactivation?
What is the process for shipping radioactive material offsite?
What routes exist for conducting onsite radioactive material transfers?
Will facility deactivation activities require radiography?
What plans exist for responding to radiological emergencies? How will these plans change as the facility undergoes the transition process?
Functional Area 8: Radiological and Hazardous Material Inventories
8.1 Introduction
DOE facilities often store and process large amounts of radioactive and other hazardous materials, resulting in significant inventory management requirements. Upon facility deactivation, these materials may be turned over to EM custody prior to final disposition. The materials may each be in different forms, requiring different assay methods that are often not precise. In order to provide adequate levels of control and security, it is important to ensure that the best possible inventory programs are in place throughout the transition and deactivation process. These programs must be in place until final disposition of the materials to permanent storage facilities, to production or other user facilities, or to radiological and hazardous waste disposal facilities.
These radioactive and hazardous material inventory and accountability requirements significantly expand basic radiological control and security requirements to address unique vulnerabilities, resulting in the need for management programs specifically created to provide an additional layer of controls. These controls are expected to be particularly important during the transition and deactivation processes since particularly hazardous activities may be performed for the first time and may involve large quantities of poorly defined materials.
Thus, the radioactive and hazardous material inventory program reviewer should determine the extent to which the current and planned material inventory and related management processes ensure continued control of all radioactive and hazardous material inventories. This assessment involves evaluating the level or quality of identification, quantification, and control programs for the radioactive and hazardous materials in storage as well as in the workplace, in process lines, or in the ground. These activities are important to consider during the transition process due to the potential increase in risks from radiological and hazardous material inventories associated with the deactivation of a facility. In some cases, these radioactive and hazardous materials will continue to be a threat after the facility deactivation is completed.
The material inventory reviewer should examine the Environmental Protection and Waste Management, Occupational Safety and Health, and Safeguards and Security Functional Area checklists for additional review guidance related to radiological and hazardous material inventory control.
8.2 Radiological and Hazardous Material Inventories Document Review
8.2.1 Facility-Specific Material Inventory General Information:
Examples:
Copies of facility material safety data sheets (MSDS)
Facility nuclear material control and accountability procedures
Types and forms of materials inventoried, process monitoring equipment, automated inventory aids, data management systems
Descriptions of facility non-destructive assay equipment
Descriptions of site and building special material containers, storage areas, vaults, and receiving/shipping facilities
Performance indicator reports regarding inventory program effectiveness
Material inventory staffing, organization, and budget information
Surveys of floor and ground contamination by either radioactive or hazardous materials
The EM material inventory reviewer should become knowledgeable regarding all of the facility radiological and hazardous materials and how they are managed and controlled. The transition and turnover process in this area cannot proceed until all aspects of the facility material control and accountability processes are understood and determined to be effective. Where applicable, there may be several inventory support systems or aids that could be of significant value after the transition process is completed, especially to the extent that they are needed to maintain assay continuity and optimize measurement accuracy and consistency. For some facilities, these processes are staffed with highly skilled technicians whose skills will continue to be required, so the future staffing needs in this area should also be assessed.
8.2.2 Facility Material Inventory Open Issues:
Examples:
DOE Order Compliance Program assessment reports
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Print out of issue management system (corrective action list)
Assessment Reports (DOE Field Office, Tiger Teams, TSAs, ORRs, NS, EH, IG, QA, M&O Internal Assessments)
Material inventory-related occurrence reports
The EM reviewer should identify all open items or issues involving radioactive and hazardous materials inventory procedures, equipment, and facilities. This may include issues related to verifying material quantities in process systems, materials inadvertently accumulated in fabrication facilities or ventilation exhaust systems, radioactive and hazardous materials on floors and in the ground, and the optimal approaches to recovery or final disposition. Until this area is well understood in terms of compliance with DOE orders and the overall inventory status and verification methods agreed to, the turnover process may need to be delayed. Where applicable, plans and funding for recovery and disposition of some of the materials will require additional development and coordination.
8.3 Radiological and Hazardous Material Inventories On-Site Review
8.3.1 Inspect:
All storage areas and locations of inventoried materials
Inventory and assay equipment operability
Forms and containment of radioactive and/or hazardous materials
Inventory, survey, and assay data management and control systems and records
Inspection Questions:
During the material inventory 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.
Are storage areas and other locations of hazardous and/or radiological materials clearly identified, hazard communications postings in place, and access controlled?
Is the monitoring and sampling equipment adequate to detect the movement of the hazardous materials and at the appropriate levels? Will they be adequate to support the deactivation and decommissioning processes?
What are the physical and chemical forms of the hazardous materials?
How are the hazardous material inventory records maintained current? Will these procedures be adequate for use by EM?
8.3.2 Interview:
Health physics, material inventory, and industrial safety and hygiene staff
Facility managers responsible for material control and inventories
Operations and process line workers
Interview Questions:
Will hazardous and/or radioactive materials be need to be stored in this facility during or following the transition?
What is the estimated volume of hazardous, radioactive, and mixed waste generated and/or stored for this facility?
Does the facility generate or contain mixed waste? If so, what controls are used to minimize the volume of mixed waste and what methods are used to reduce the volume of mixed waste?
Were there any previous operations involving hazardous and/or radioactive materials within this facility that have been abandoned or shutdown?
Are MSDSs for all hazardous materials available?
What will be the impact of deactivating the facility on the hazardous material inventories?
How are the hazardous material inventories monitored?
Are operations that generate radiological and hazardous waste designed to permit efficient segregation, monitoring, treatment, storage, and disposal of the wastes? How might this situation change during deactivation and decommissioning operations?
Have allowable inventory limits for radiological and hazardous material been established for this facility?
What are the current and future hazardous material management organization staffing needs?
What systems or components will be of use for controlling material inventories during the transition process?
Are additional equipment or facilities needed to control material inventories properly?
Functional Area 9: Safeguards and Security
9.1 Introduction
Safeguards and security (S&S) measures at DOE nuclear facilities consist of an integrated approach that encompasses principal facility functions including design, analyses, construction, and operation. The facility S&S program functions to (1) deter or prevent the loss or attempts of unlawful possession of special nuclear material (SNM), (2) prevent willful acts of sabotage (industrial and radiological) against a facility, and (3) protect classified information and personnel security. These activities are designed to provide protection from postulated hostile acts which would cause adverse impacts on national security, the safety and health of the workers or the public, or the DOE mission in general.
Several information types of security are generic for all DOE facilities. These include matters of information security, computer security, personnel security, operations security, and security training. On the other hand, S&S aspects for the protection of SNM and against deliberate and willful acts of sabotage at the facility require specific considerations depending upon the nature of the operations. These are addressed more fully in the areas of physical security and material control and accountability (MC&A).
Physical security involves applying methods to prevent malevolent acts against DOE S&S interests (e.g., SNM, vital systems and equipment, classified matter, and DOE property and unclassified facilities), detecting such acts as they occur, and responding to such acts. MC&A involves performing actions to detect or deter theft or diversion of nuclear materials and to assure that all nuclear materials are present and accounted for.
9.2 Safeguards and Security Document Review
9.2.1 Facility Design Related Documents:
Examples: Site Safeguards and Security Plan (SSSP) (includes Master Safeguards and Security Agreement (MSSA), Facility Descriptions and Operational Plans (FDOP), and Resource Plans (RP))
Vulnerability Analysis (VA) (includes vital areas and vital equipment)
SAR (safety/S&S interfaces)
Areas of Review:
These documents provide the reviewer with an understanding of the protective measures and systems used by the facility to protect security interests. Typically, facilities are protected in a graded manner such that increased levels of protection are provided for more important S&S interests. The reviewer should identify the current S&S risk ratings of the facility and determine if the risk ratings will increase or decrease when the facility is transitioned to EM. Risk ratings are used to determine if a protection system is acceptable or if enhancements are needed.
The reviewer should examine the general site layout, paying particular attention to the area immediately surrounding the protected area or limited area fencing to ensure that appropriate measures have been or will be taken to allow observation of approaching personnel and traffic, and to provide vehicle staging areas for traffic control, if appropriate. The reviewer should determine if the layout provides adequate physical protection and control of activities onsite. The reviewer also should assess whether features of the facility pose problems in providing adequate S&S measures.
In addition, the reviewer should determine whether the layout of structures and systems of particular importance for accomplishing the S&S mission (such as the Central Alarm Station (CAS), Secondary Alarm Station (SAS), primary and emergency power sources, and communication facilities) is described in sufficient detail to determine if the S&S mission would be compromised by a single event or accident occurring onsite or offsite.
The reviewer should examine the facility protection strategies to ensure that they assist in mitigating adversarial acts involving the theft or diversion of SNM and acts involving industrial and radiological sabotage. In particular, the reviewer should analyze physical, procedural, system, and protective force strategies.
The reviewer also should perform the following activities:
Review the documents that pertain to the overall SSSP with consideration to required approvals of the plan. Give attention to any unique facility layout aspects for the S&S program.
Review documents to trace compliance with the applicable DOE Orders especially with regard to statements on S&S policy.
Review the VA for the facility to identify threats and targets, protection strategies, protection system performance ratings, consequence values, and accepted risks.
Review sabotage scenarios to ensure that all accident sequences covered in the SAR are properly considered.
Review SAR sections dealing with S&S issues to ascertain safety interface considerations (such as entry to vital areas) in the facility design and operation.
Review the S&S electrical power system, including backup power sources, to ensure that it provides a reliable source of electrical power to the protection system equipment.
Review special documents that pertain to S&S procedures for physical protection and material control and accountability.
Review plans for D&D which involve temporary or permanent changes or destruction of security barriers or systems, and the justification for such actions.
9.2.2 Facility Information:
Examples:
Physical protection plan
Materials control and accountability plan
Operations security plan
SNM plan
Interim compensatory plans
Deactivation plan
Transition plan
Information security
Computer security
Security training plans
Areas of Review:
These documents provide the reviewer with an overall understanding of the facility S&S program. The reviewer should determine whether equipment is of sufficient cost or importance to require S&S protection against industrial sabotage. As a general rule, the cost of protection should not exceed the cost of the protected equipment.
The reviewer should identify the location, purpose, and physical composition of facility barriers and verify that they meet DOE Orders and S&S standards and criteria. Types of barriers that may be used include fences; grates; walls, ceilings, and floors; doors and windows; and other human-made or natural obstacles that could help channel, deter, delay, and deny unauthorized access to the facility. The reviewer should identify the location of material access areas (MAA) and vital areas and the configuration of the protected areas to determine the role barriers play in denying unauthorized access to those areas.
Additionally, the reviewer should study the facility surveillance and assessment systems to ensure that they can provide rapid assessment of an alarm or alarm zone. The reviewer should determine if the surveillance and assessment measures are coordinated with safety and health physics activities to maximize the use of equipment and reduce redundancy. The reviewer should ensure that there are criteria for such technical provisions as line supervision, tamper-indicating signals, visual and audible alarms, and integration of alarms with video surveillance equipment. The reviewer also should determine whether a maintenance and testing program and an acceptance test plan have been provided for surveillance and assessment systems.
The reviewer should identify the locations of all intrusion detection systems and determine if the systems can accurately and rapidly communicate alarms when the intrusion detection sensor identifies a valid intrusion and display the alarms at the CAS and SAS. The reviewer also should examine any lighting plans to ascertain the rationale for the selection of both interior and exterior lighting used within security-related areas. A well-planned lighting system will provide safe illumination of the facility, allow the protective force to adequately observe secure areas, and permit proper performance of the assessment and surveillance systems.
The reviewer should examine the security-related communications plan to determine the use of mobile and fixed radios on site; redundancy of communication through the use of commercial and plant telephones; intercoms, public address system, and duress alarms; offsite communications capability to contact local and national law enforcement agencies; emergency power sources for communications equipment, and the use of repeater stations or satellite receiver stations to extend the capability of portable radios.
Positive control of nuclear materials during storage and handling is essential to prevent the loss or diversion of that material and to maintain MC&A standards. The reviewer should identify and evaluate the design criteria that provide for the positive control of nuclear materials during storage and handling, and evaluate the design features that permit the facility and its equipment to meet those criteria. An effective MC&A system requires the ability to measure the nuclear material content of waste and scrap, and to control, process, and dispose of the waste and scrap. The reviewer should examine and evaluate the design criteria that minimize the generation of waste and scrap and enable measurement of the nuclear material content of waste and scrap for control, processing, and disposition. Additionally, since it is not possible to clean out all nuclear material contained in a process system, the reviewer should examine the design features that minimize nuclear material holdup, the methods used to determine the process systems and equipment susceptible to significant nuclear material holdup, the difficulty of cleaning out the equipment and systems susceptible to significant nuclear material holdup, and the capability for measuring the holdup that remains.
Classified matter must remain within limited, exclusion, or security areas unless those using the matter can guarantee its protection against unauthorized access outside of such areas. The reviewer should identify the facility's limited, exclusion, or security areas and determine the types of classified matter that the facility possesses. The reviewer also should assess computer security elements such as software and hardware controls, access controls, and physical security measures.
The reviewer also should perform the following activities:
Identify all documents including backup documentation that constitute the SSSP including the 3 major subparts.
Review documentation that pertains to the transitioned facility status on S&S matters giving attention to any necessary S&S procedure modifications.
Review documents that pertain to the general subject of information security.
Verify that the SAS has the same capabilities as the CAS.
Determine what is unique about the facility with regard to the VA and the identification of requirements for vital areas and equipment.
Determine what documentation exists that records the history of S&S related occurrences at the facility.
Review the testing and maintenance records for S&S equipment and determine if the testing and maintenance has been effective and if all S&S equipment is included in the testing and maintenance program.
Determine whether special considerations will be afforded to the transitioned facility status.
Determine the SNM category level currently at the facility and the expected level when the facility is transitioned to EM.
Review the organizational charts and functional statements to ensure that responsibilities are clearly established and plans are, or will be, in place for the transition of responsibilities as the facility transitions to a deactivated condition.
Are documents available for the S&S organization showing which positions remain open; noting any changes for the transitioned facility status? Are lines of authority clearly defined for the overall S&S program?
Review any documents pertaining to meetings where S&S matters were discussed and issues resolved including changes for the transitioned facility status.
Review the program for onsite and offsite assistance for physical protection with consideration for any changes due to the facility transitioned status.
Ensure that plans are in place to establish liaisons with both internal and external oversight groups.
Identify the types and storage locations of classified documents and equipment.
Determine how classified information is physically protected from unauthorized disclosure.
Review the Critical and Sensitive Information List (CSIL) and the Essential Elements of Friendly Information (EEFI) to determine those classified or unclassified aspects of a program technically most important to protect from adversaries and the adversaries with pathways or indicators that may lead to this information.
Review the agreements that have been made with other site organizations and outside agencies to ensure that adequate support will be available in the event of an S&S incident or emergency.
9.2.3 Facility Compliance:
Examples:
DOE Order compliance program assessments
- Program Management (DOE Order 5630 series)
- Personnel Security (DOE Order 5631 series)
- Protection Program Operations (DOE Order 5632 series)
- Nuclear Materials Control and Accountability (DOE Order 5633 series)
- Surveys and Facility Approval (DOE Order 5634 series)
- Information Security (DOE Order 5639 series)
- Independent Inspection and Evaluation (DOE Order 5630.12A)
Results of security inspections and surveys
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Documentation on facility S&S corrective action program
Print-out of issue management system (corrective action list)
Assessment Reports (Tiger Team, Technical Safety Appraisals, NS, EH, IG)
S&S occurrence reports
Areas of Review:
These documents provide the reviewer with an overall understanding of how well the facility implements its S&S program. The reviewer should examine all unresolved S&S-related deficiencies and noncompliances and determine if these deficiencies and noncompliances will need to be resolved before the facility is transitioned to EM. The reviewer should examine how issues are identified and tracked to ensure that resolution is responsive and complete. The plans for resolving issues that arise as a result of S&S reviews, inspections, assessments, and appraisals should provide a structured, disciplined means for formally identifying such issues, assigning responsibility for issue resolution, tracking the status of resolution, and ensuring that resolution is complete. The reviewer should determine if appropriate compensatory measures are taken in the event of S&S system or component failure. Additionally, the reviewer should examine any root cause analysis studies resulting from S&S occurrence reports or assessment findings.
9.3 Safeguards and Security On-Site Review
9.3.1 Inspect:
Physical security systems
SNM storage facilities
Safety/critical equipment interfaces
MC&A areas (material balance areas (MBAs) and item control areas (ICAs))
Non-interruptible power supplies
Surveillance, assessment, detection, and alarm systems (including CAS and SAS)
Vital areas and vital equipment
Material access areas
Safety/S&S interfaces
Inspection Areas:
Conduct a general walkdown of the facility locating strategic S&S features (such as the CAS and SAS, vital areas and vital equipment, MAAs, and MC&A areas).
Inspect areas of vital importance to S&S including safety interface areas.
Identify and depict relative locations of all significant terrain and human-made physical features at the facility.
Examine the terrain surrounding the security fence to ensure it is relatively flat and cleared of any trees and undergrowth or human-made structures that could conceal an adversary.
Determine if the road network adjacent to the facility is sufficient to support protective force activities and possible assistance from local law enforcement agencies but restricted enough to deter casual approach to the facility by unauthorized personnel.
View SNM storage areas including MBAs and ICAs.
Review the physical arrangement and protection requirements necessary at each entry and exit portal.
Verify that appropriate security signs have been posted at the facility perimeters and entrances.
Examine the placement and type of barriers used to determine if their purpose has been achieved.
View changes that will take place for the transitioned facility status that affect S&S matters.
Review S&S procedures for overall quality and completeness noting any updating activities.
Review plant surveillance and maintenance procedures to ensure that sabotage is properly considered, both from the standpoint of minimizing the potential for acts of sabotage and identifying possible sabotage when it occurs.
Review a selected number of systems identified in the sabotage scenarios to ensure that each piece of equipment, including supporting piping, cabling, instrumentation, and support systems, is properly identified and located.
Identify any systems or equipment items that are subject to nuclear material holdup.
Review area monitoring as an integrated system (such as lighting, communications, motion detection, surveillance methods, and security staff areas).
Verify that closed-circuit television (CCTV) monitors providing surveillance and assessment capabilities are displayed in the CAS and SAS and that sufficient personnel are available at the CAS and SAS to continuously operate and monitor surveillance and assessment equipment.
Verify that the isolation zone is free of any buildings, laydown materials, standpipes, vegetation, trash, or other obstacles that could restrict surveillance.
Determine if illumination levels for normally unoccupied MAAs and vital areas are sufficient to allow surveillance by either the unaided human eye or CCTV.
Verify that the computer security area is contained within clearly defined perimeter barriers, and the means of access to the area is limited to entry portals, which are controlled.
9.3.2 Interview:
Personnel to be interviewed should be knowledgeable in the S&S areas at both the contractor and DOE Operations Office management levels. However, because of the nature of S&S, a single person may not be sufficiently knowledgeable to cover all aspects.
Attention should be directed to changes in S&S features that would result as the facility is deactivated and transitioned to EM. In instances where SNM will be removed, the scope of the S&S program would be more directed toward the protection of property.
Consideration should be given to coordination with onsite and offsite resources that would provide backup for overall physical protection; therefore knowledgeable persons in this aspect should be included in the interviews.
Specific personnel to be interviewed should include:
Physical security officer
MC&A manager
Facility manager
Protective force personnel
MC&A personnel.
Interview Questions
What are the responsibilities and authorities of the S&S management in carrying out the S&S policy?
What is your overall familiarity with the documents that make up the facility SSSP and the supporting documents as to how such documents are used in implementing the facility S&S program?
What are the contents and findings of the facility specific VA and how was the document developed (modeling, assumptions, design basis threat, and the conservative treatment of any uncertainties) and used in carrying out the responsibilities of the S&S staff.
What is the SNM category level currently at the facility and what is the expected level when the facility is transitioned to EM?
What type of protection strategies are used and how will these strategies change as the facility is deactivated?
Are there written S&S procedures, including procedures for testing and maintenance, operations, and training? Are procedures reviewed periodically? How will the procedures change as the facility is deactivated?
What processes and methodologies exist to maintain the configuration of the facility's S&S-related hardware and software up-to-date?
What onsite and offsite resources are available to the physical protection staff, how are these solicited, and on what basis would such resources be called upon?
What contractual arrangements exist with the protective force contractor?
Describe the S&S training program including retraining? Are there special training requirements for deactivating the facility or transitioning the facility to EM?
What are the training and qualification requirements for the S&S staff and will they change when the facility is deactivated?
How often are training drills conducted?
How often does the facility manager or shift supervisor inspect S&S areas (such as the CAS and SAS) or observe maintenance and testing of the facility S&S protection system?
Will the SAR information on vital areas and vital equipment and safety/S&S interfaces be applicable once the facility is deactivated?
Will there be special types of protection/detection/surveillance systems used during the facility deactivation process?
What changes will be made in the physical protection program when the facility is deactivated?
Is there a formal system for informing S&S personnel of all proposed facility changes during transition, so they can change their plans, equipment, and procedures to accommodate each change without unnecessary interference with the D&D work?
Are any S&S compliance-related, risk-reduction, or cost-effective enhancements planned prior to transitioning the facility to EM?
What physical protection specialists are included in the facility S&S program? Have you met and discussed S&S protection matters for deactivating and transitioning the facility?
What security-related communications links exist between the facility and offsite law enforcement agencies and site emergency operations centers?
Are S&S planning and budget submittals consistent with the commitments made in the MSSAs?
Is there a schedule for MC&A functions? What changes will be made when the facility is deactivated and transitioned?
What are the authorities and responsibilities for SNM accountability and control functions (such as records, measurements, inventories and audits)?
Does the facility have the capability to perform accurate measurements of nuclear material receipts, shipments, and inventories?
How is the nuclear content of waste and scrap measured?
What process systems and equipment are susceptible to significant nuclear material holdup?
Are S&S requirements integrated with facility safety requirements?
Functional Area 10: Fire Protection
10.1 Introduction
DOE facilities are required to provide comprehensive and systematic protection against the effects and related perils of fires. The objectives of an effective fire protection program, as stated in DOE 5480.7A, "Fire Protection," are to (1) minimize the potential for the occurrence of a fire; (2) ensure that the fire would not cause an on-site or off-site release of radiological or other hazardous material that would threaten public health or the safety of the environment; (3) establish requirements for life safety to DOE and contractor personnel and that there are no undue hazards to the public from fire and its effects in DOE facilities; (4) ensure process controls and safety systems are not damaged by fire or related perils; (5) ensure that vital DOE programs will not suffer unacceptable delays as a result of fire or its effects; and (6) ensure that property damage from fire and related perils does not exceed acceptable levels. The institutionalization of these objectives includes provisions for authorities in the organization to implement the various fire protection responsibilities and requirements and outline the basic plans for fire protection, fire detection, and suppression capability, and the limitation of fire damage.
The fire protection program functional area includes all activities for fire prevention and mitigation to ensure worker and public safety and the protection of the environment against the effects of fire that may occur at DOE facilities. Fire prevention and mitigation initiatives start with a comprehensive and systematic fire protection system design based upon the results of a comprehensive and systematic facility fire hazards analysis. Subsequently, the fire protection program is maintained and upgraded where necessary, throughout the facility lifetime in terms of its operational readiness and effects through a program of maintenance activities, and staffing by trained personnel. As part of this programmatic approach, qualified fire protection staff are expected to provide oversight and management of required inputs and assistance from several functional areas including engineering, maintenance, occupational safety, operations, and training. This involves the operating staff to be aware of changing requirements for fire protection as facility changes are made along with an ongoing reassessment of the overall facility fire hazard.
This orderly system of comprehensive fire protection is likely to be significantly disrupted throughout facility deactivation and decommissioning processes. The reviewers principal objective during the screening review is to ensure that the current level of facility fire protection is adequate and that continued support for fire protection programs will be available at least until the completion of site restoration. This review should be conducted by a fire protection engineer, who should become intimately familiar with the changes that will be identified for all of the other functional areas and then assess whether the level of planned fire protection support is adequate.
10.2 Fire Protection Document Review
10.2.1 Facility Design Related Documents:
Examples:
Facility SAR
Fire Hazards Analysis (FHA)
Technical Safety Requirements
Special Fire Protection Requirements
Areas of Review:
These documents provide the reviewer with an understanding of the protective measures and systems used by the facility to protect equipment and personnel from the danger of fire. The foundation of the DOE fire protection program is the ability to rely on properly designed automatic suppression systems and passive construction features. Design, review, and verification of hazards; testing and maintenance; regular assessment by qualified fire protection professionals; and frequent inspection with prompt corrective action by facility staff are key to ensuring this objective. During renovation or demolition of facilities, which may occur during facility deactivation, a fire hazard analysis (FHA) and strict design review procedures must be implemented. Even changes in process equipment can influence the effectiveness of existing protection. Therefore, the reviewer should examine the overall facility layout to understand how changes in the facility will drive changes in the fire protection system and program. Additionally, the reviewer should identify the current fire risks for the facility and determine whether the risks will increase or decrease when the facility is transferred to EM.
The reviewer should also perform the following activities:
Review the overall FHA report for completeness and approval, and review plans for periodically updating the FHA as the facility is deactivated.
Identify the major fire hazards at the facility and determine whether they will change as the facility is deactivated.
Determine whether the SAR includes fire protection safety matters and whether it addresses facility deactivation.
Review the SAR to identify safety class equipment that must be protected from the effects of fires.
Verify that fire scenarios identify and analyze important safety equipment where radioactive release would occur, and determine whether further scenarios need to be developed to address unique situations which may arise during deactivation and decommissioning operations.
Identify changes in the fire protection program, including changes to applicable TSRs and operating procedures, that will be necessary as the facility is deactivated.
Determine whether special fire protection requirements will be required during and after facility deactivation to address special materials or systems used for decommissioning and decontamination.
10.2.2 Facility Information:
Examples:
Interim compensatory actions
Fire Protection Program
Historical fire protection records
On-site/off-site resource requirements
Staffing and qualification requirements
Maintenance procedures for fire protection equipment
Transition plan
Deactivation plans
Areas of Review:
These documents provide the reviewer with an overall understanding of the fire protection program. A fire protection program is an ongoing process consisting of prevention and protection approaches to control and mitigate losses. These approaches are a combination of human element programs and physically engineered features and systems. The reviewer should examine the Fire Protection Organization to ensure that it has a sufficient mix of qualified personnel to conduct training; perform procedure development, construction, and facility design reviews; conduct hazards analysis and assessment; and maintain and test fire protection systems. The reviewer should determine how organizational resources will change as the facility is deactivated. Resources are not limited to trained personnel but include equipment, tools, and funding adequate to upgrade and maintain facilities.
The reviewer should also perform the following activities:
Determine whether procedures are being prepared or are in place for facility deactivation including any necessary interim compensatory actions (such as additional fire watches).
Review the overall fire history for the facility as to the number and severity of fires that have occurred and what was done implement lessons learned.
Identify the property damage limitation for the facility and determine how the property damage limitation will change as the facility is deactivated.
Review the organizational charts and data readily available and accessible that clearly identify the fire protection staff and levels of authority as to responsibilities and reporting. Determine required changes during and after facility deactivation. Identify the "authority having jurisdiction" for the facility.
Identify onsite and offsite fire protection resources especially as to whether there may be conflicting priorities for fire protection, safety and operation, and any changes during and after facility deactivation.
Review the overall maintenance program for the fire protection systems and ensure that it has been effectively carried out. Determine what changes will be required to the maintenance program and staff during and after facility deactivation.
Identify any fire protection systems (both active and passive) for which formal fire protection reviews, documentation, and acceptance are not completed or are missing.
Identify automatic and redundant fire protection systems or features needed to protect critical equipment or buildings.
Review recent results of water flow loop tests and fire pump tests.
Examine fire protection features or systems which are required to mitigate or prevent loss of important safety equipment and verify that a high degree of reliability is maintained through implementation of formal procedures and surveillance.
Evaluate fire protection procedures and preplans to ensure proper application of NFPA Codes to fire department personnel, maintenance and testing of fire protection equipment, emergency organization charter and preplanning, and interface agreements among fire protection support organizations.
10.2.3 Facility Compliance:
Examples:
DOE Order Compliance Program Assessment Reports (DOE 5480.7A and DOE 6430.1A)
Compliance Schedule Approval (CSA) and Exemption (EX) requests
Print-out of issue management systems (corrective action list)
Occurrence reports
Assessment reports (Tiger Teams, TSAs, NS, EH, IG)
Areas of Review:
These documents provide the reviewer with an overall understanding of how well the facility implements its fire protection program. The reviewer should examine work backlogs and determine whether there is a need for additional resources to restore adequate fire protection reliability.
The reviewer should analyze exemptions for instances where an equivalent level of protection cannot be achieved and future corrective action is not feasible, either due to the nature of the process involved, or physical plant structure requirements. The reviewer should assess the compensatory measures instituted to limit, control, or mitigate the hazard potential of the exemptions.
The reviewer should also perform the following activities:
Where a safety analysis is required in accord with DOE Order 5480.23, identify the documents that constitute the Fire Hazards Analysis and that reflect the risk from fire with emphasis on any special fire safety matters.
Review documents that set forth the codes and standards for the facility fire protection system design including changes for the facility transition status; especially NFPA guides, manuals, and recommended practices.
Review the results of Assessment Reports (Tiger Team, TSAs, NS, EH and IG) on any oversight activities (such as inspections, evaluations, fire protection surveys, self assessments, and GAO audits) as they pertain to fire safety and assess the corrective actions planned or taken relative to the changing mission imposed by the transition program.
Identify if any fire protection equipment is missing from test or maintenance tracking lists.
Identify areas where fire protection requirements cannot be met for deactivation and decommissioning activities and determine whether any additional compensatory actions are being taken.
10.3 Fire Protection On-Site Review
10.3.1 Inspect:
Active and passive aspects of the fire protection system
Independence of systems
Separation as a means to enhance fire protection and ensure redundancy
Manual systems
Automatic systems
Facility specific hazards
Status and alarm display
Testing and maintenance practices
Areas of Review:
Conducting a physical inspection of a facility is key to evaluating the effectiveness of a plant fire protection program. The inspection should establish fundamental information regarding facility process, construction, hazards, and protection features and is a strong indicator of management interest in fire protection and prevention. Beyond an examination of basic housekeeping and site conditions, the inspection should examine how the physical fire protection features are integrated into the operation and plant construction to control the spread of combustibles. Poorly designed fire protection features or changes in occupancies from the time of original installation can result in a fully sprinklered building being essentially unprotected.
During the fire protection inspection process, the following areas should be addressed on a preliminary basis by the reviewer in discussions with assigned escorts. Areas of concern and those areas not adequately addressed as part of the facility inspections should be followed up on during the subsequent interview process.
Conduct a general walk-down of the overall facility fire protection system including water sources and distribution systems. During the walk-down, inspect and evaluate the following:
- Location and exposures
- Construction
- Utilities and emergency power supplies
- Occupancy
- Special hazards
- Water supplies
- Protection
- Vital programs
- Safety class systems
- Maximum Possible Fire Loss (MPFL)
- Maximum Credible Fire Loss (MCFL)
- Liquid run-off and contamination potential
- Facility process interruption potential.
Inspect areas where special fire protection features are provided to prevent and mitigate the consequences of facility fires; especially areas where safety class equipment is provided.
Inspect piping for markings to ensure that the fire system will not be inadvertently disrupted during deactivation and remodeling of other systems.
Verify that fire protection system control valves and supplies are secured in the open position.
Determine if any fire protection systems are out of service and which out of service systems do not have active work orders in place.
Determine if any portions of the fire protection system can be isolated and shutdown once the facility has been deactivated.
Determine if fire detection or suppression system nozzles are obstructed, fire doors and dampers are damaged or inoperative, fire extinguishers are inaccessible or out of service, combustible areas are without automatic fire suppression, openings exist in fire barriers, and fire suppression system control valves are shut improperly.
Verify that adequate fire separations exist among redundant safety trains, high-valued areas, critical process areas, or special hazards.
Verify that adequate containment or confinement capabilities exist to control the spread of contamination and liquid damage during a fire.
Review the fire alarm display status system and identify special area monitoring requirements.
Review changes to the fire protection system as to any new features or deactivated portions of the fire protection system due to the facility being deactivated.
Review the facility protection against inadvertent criticality from operation of the facility fire protection system.
Review any features to prevent inadvertent operations of the facility fire protection system that may have an adverse effect on normal facility operations or members of the operating staff.
Review several operating procedures for the facility fire protection system.
Consider any special features for alternate safe shutdown of the facility in the event of fire damage.
10.3.2 Interview:
Personnel to be interviewed should include the person in charge of facility fire protection and personnel knowledgeable about pending changes being made as the facility undergoes transition. In addition, the personnel who are involved with training should be interviewed. The availability and utilization of the qualified fire protection specialists (DOE and contractors) should be considered in the interviews in so far as acceptable codes and standards adopted for the facility fire protection design.
Specific personnel to be interviewed should include:
Facility fire protection engineer
Facility fire equipment maintenance personnel
DOE Operations Office fire protection engineer
Facility manager
Interview Topics/Questions:
Discuss the onsite and offsite resources available to the facility fire protection staff and estimate their effectiveness for the transition period.
Are there written procedures for testing and maintenance of the fire protection systems? Are procedures reviewed periodically? Will they adequately support transition operations?
What changes will be incorporated in the fire protection program during and after facility deactivation?
Is there a formal system for keeping fire management informed of upcoming changes in facility configuration during the transition?
Are fire watches used at the facility? If so, under what conditions are they used (such as for interim protection measures until permanent changes are implemented)?
Are there special fire protective features provided at this facility?
Does the fire safety program conform to all applicable DOE requirements?
What fire hazards are most proximate to nuclear materials, hazardous materials, and nuclear safety systems?
Are the facility water supplies and fire main systems reliable, operable, and maintainable?
What arrangements are in place to obtain support from local area fire departments, especially with regard to nuclear facilities?
What role does the Fire Protection Organization play in the plant emergency response organization?
For secure areas of the facility, what ensures prompt access by the fire protection brigade?
Attachment 3
SCREENING REVIEW REPORT OUTLINE
1.0 Introduction
1.1 Background
1.2 Purpose/Objectives
1.3 Scope
1.4 Review Team/Method
2.0 Summary of Results
2.1 Administrative Planning
2.2 Surveillance and Maintenance
2.3 Environment, Safety, and Health
2.4 Facility Protection
3.0 Administrative Planning
3.1 Budget, Schedule, and Manpower Management
4.0 Surveillance and Maintenance
4.1 Shutdown/Deactivated Facility Operations and Safety
4.2 Physical Plant Condition
4.3 Transition Maintenance
5.0 Environment, Safety, and Health
5.1 Environmental Protection and Waste Management
5.2 Occupational Safety and Health
5.3 Radiation Protection and Safety
5.4 Radiological and Hazardous Material Inventories
6.0 Facility Protection
6.1 Safeguards and Security
6.2 Fire Protection
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