**FACILITY SAFETY (FS)**

OBJECTIVE

**FS.1 -- (Core Requirement 7)** Facility safety documentation in
support of SN process operations,is in place and has been implemented
that describes the safety envelope of the facility. The, safety
documentation should characterize the hazards/risks associated with the
facility and should, identify preventive and mitigating measures (e.g.,
systems, procedures, and administrative, controls) that protect workers
and the public from those hazards/risks. (Old Core Requirement 4)

Criteria

1\. A DSA has been prepared by FWENC, approved by DOE, and implemented
to reflect the SN process operations in the WPF. (10 CFR 830.200,
DOE-STD-3009-94)

2\. A configuration control program is in place and functioning such
that the DSA is consistent with the physical facility configuration, the
equipment and systems are present as described and credited, and the
requirements can be accomplished. (10 CFR 830.200, DOE O 420.1A)

3\. The Unreviewed Safety Question Determination (USQD) process is
approved by DOE and inplace. (10 CFR 830.200)

4\. The characteristics of the safety management programs (including
maintenance, fire

protection, safety, health, and industrial hygiene) necessary to ensure
safe operation of

facility defined in the DSA are implemented. (10 CFR 830.204(b)(5))

**Approach**

**Record Review:** Review the WPF DSA, TSR, Safety Evaluation Report
(SER), and other safetybasis documents to assess whether the safety
basis adequately includes the appropriate hazards/risks associated with
SN process operations. Ensure that the DSA has been approved and
implemented to reflect the operation of the SN process per 10 CFR 830.
Ensure that the DSA and TSR requirements are implemented to consistently
and properly identify the hazards, necessary controls, and safety
systems to prevent or mitigate hazards. Verify that any conditions of
approval identified in the SER have been appropriately addressed. Review
documentation to confirm that the DSA and TSR will be subjected to an
annual review/revision process. Review the configuration control program
that is in place to ensure the DSA is maintained consistent with the
equipment and systems in the facility. Spot-check some of the facility
equipment and systems to be sure that they are consistent with the
description of the physical facility configuration as described in the
DSA. Review the approved USQD procedure and check to see that it is
implemented in the facility. Sample any completed USQDs to verify that
they are being processed according to the approved procedure. Review the
DSA to understand the characteristics of the safety management programs
(such as the maintenance program and fire protection program) that are
implemented to provide administrative controls in support of other
engineered controls. Check to see that the safety management programs
included in the DSA are, in fact, implemented as described.

**Interviews:** Interview operators to determine their understanding of
DSA requirements

implementation. Interview personnel involved in the USQD process to
determine their

understanding and implementation of the process. Interview the
maintenance manager to see if the maintenance program is implemented as
described in the controlling documents.

**Observations:** Observe an operation to see how the DSA requirements
are implemented in operating procedures. Observe a maintenance activity
to evaluate the effectiveness of the maintenance program implementation.

OBJECTIVE

**FS.2 -- (Core Requirement 8)** A program is in place to confirm and
periodically reconfirm the condition and operability of safety SSCs.
This includes examinations of records of tests and calibration of these
systems. The material condition of all safety, process, and utility
systems will support the safe conduct of work. (Old Core requirement 5)

Criteria

1\. A surveillance and maintenance program is in place for safety,
process, and utility systems.

2\. Tests and calibration of instruments are properly implemented and
documented. (10 CFR 830, Subpart A, Criteria 5 and 8)

3\. Completed surveillances and tests are verified and follow-up actions
are documented. (10 CFR 830, Subpart A; DOE O 5480.19, Ch. 1 and II)

4\. Software associated with SN process operations has been developed,
documented, and

controlled in accordance with the QA Project Plan. (10 CFR 830, Subpart
A)

**Approach**

**Record Review:** Review the SN process operations safety requirements
and controls and

determine whether the associated operating, surveillance, and
maintenance procedures adequately implement the TSR controls and the SER
conditions for approval. Verify that the surveillance records of the
Process Building Confinement Ventilation System and at least one other
safety related system associated with the SN process areas are current.
Review instrument test and calibration records. Ensure that the software
associated with the SN process has been developed, documented, and
controlled in accordance with the QA Project Plan. Review a list of
outstanding safety system deficiencies identified through the corrective
maintenance program, preventive maintenance program, surveillance test
program, or other reporting process to assess the condition of facility
systems to support safe operations. Ensure the process to maintain
outstanding deficiencies is adequate.

**Interviews:** Interview personnel assigned to conduct authorization
basis-related surveillance or maintenance activities, and evaluate their
understanding of the impact their activities have on the authorization
basis and facility/system operability.

**Observations:** Observe completion of a surveillance activity for
implementation of a TSR requirement(s). Observe routine checks to ensure
that safety systems are verified to be in compliance with safety
requirements. Walk down one safety system with the assigned system
engineer to assess operability and condition.

OBJECTIVE

**FS.3 -- (Core Requirement 10)** Adequate safety limits are in place
for operating the process systems and utility systems, and the limits
are consistent with the as-built systems in the facility. (Old Core
Requirements 1 and 18a)

**Criteria**

1\. The TSR and/or operation limits are appropriately implemented for
system operation in order to protect the public, the workers, and the
environment from the safety and health hazards posed by the facility.
(10 CFR 830.200)

2\. The parameters indicating compliance with the safety requirements
can be measured or

physically verified. (10 CFR 830.200)

3\. Safety limits and operational controls reflect the as-built systems
in the facility. (10 CFR 830.200)

**Approach**

Record Review: Select TSR controls relevant to SN process operations and
determine if the associated operating and maintenance procedures
implement the requirements. Review the TSR to ensure that operations
controls are properly identified.

Review the results of the contractor's ORR to check their verification
of the as-built systems. Sample some of the equipment or systems to
verify that the controls reflected in the DSA are consistent with the
actual hardware configuration in the facility.

**Interviews:** Interview personnel assigned to conduct authorization
basis-related surveillance and maintenance activities and determine how
the safety requirement parameters are measured and periodically
verified.

**Observations:** Observe the performance of a surveillance and operator
rounds to determine if the safety system parameters used to verify
compliance with safety requirements are being accurately verified. While
observing evolutions and drill response, assess the activities or
programs in place to ensure compliance with safety requirements.

**OBJECTIVE**

**FS.4 -- (Core Requirements 7 and 9)** Safety SSCs are defined, and a
system to maintain control over their design and modification is
implemented. The SN process operations systems, as built, are consistent
with the facility description and accident analysis included in the
safety basis. (Old Core Requirements 4 and 15)

**Criteria**

1\. An adequate system engineering process has been implemented to
ensure that documentation for safety SSCs to support SN process
operations exists and is kept current. The documentation is available to
management, operators, and support personnel as necessary. (10 CFR 830,
Subpart A, Criterion 4; DOE O 5480.19 Ch. 2, Section VIII)

2\. Drawings and documentation relied on for operations and maintenance
activities are

consistent with the existing configuration of the WPF. (10 CFR 830,
Subpart A, Criterion 4)

3\. The SN process operations systems are consistent with the
assumptions and descriptions in the DSA. (10 CFR 830.200)

4\. A system engineer is assigned to maintain control over the design
and modification of safety SSCs. (10 CFR 830, Subpart A, Criterion 6)

5\. The SN process operations systems are constructed per specifications
consistent with the facility description and accident analysis included
in the safety basis.

**Approach**

**Record Review:** Review safety SSC documents and drawings to be sure
that they are current and available to managers, operators, and support
personnel. Review system and equipment documentation to ensure that any
modifications conducted on the SN process operations equipment since
construction and installation have been accomplished consistent with the
FWENC equipment configuration management process. Review the WPF DSA and
TSR to ensure they are consistent with the physical facility
configuration. Spot-check some of the facility equipment and systems to
ensure that they are constructed per specifications consistent with the
facility description and accident analysis included in the safety basis.
Determine if the equipment and systems as described are part of the
technical baselines for SN processing. Determine whether appropriate
process descriptions exist and that these descriptions are under
configuration control. Determine whether any in-progress modifications
essential to permit operation of the SN process exist. Review the Master
Equipment Lists of the SN process systems to ensure the equipment is
properly graded consistent with the authorization basis and the FWENC QA
Program. Ensure that utility system drawings have been updated, and the
defined boundaries between the SN process systems and the utility
systems are correctly identified. Review dispositioned Unreviewed Safety
Questions (USQs)/USQDs for design changes, special procedures and tests,
and other proposed changes. Determine the status of all ongoing USQs,
and evaluate their implication on operations. Review records for
temporary modifications, and verify that the required actions are
implemented.

**Interviews:** Interview the system engineer(s) assigned to the safety
SSCs to determine how control over the design and modifications of the
systems is maintained. Interview management, operations, and support
personnel responsible for configuration management for SN process
operations to determine if they are familiar with their roles,
responsibilities, and interfaces with the operations organization.

**Observations:** Perform a system walkdown with the system engineer to
determine whether there are uncontrolled modifications to safety systems
supporting SN process operations. This walkdown should evaluate the
accuracy of drawings and other documentation for plant operation and
maintenance. At least one recently completed modification or temporary
modification to an equipment or system should be observed and the
changes verified, including changes to the operating procedures, if
applicable.