# Presentation: 688247

## Nuclear Safety & the Independent Technical Review (ITR) Process

**Nuclear Safety & the Independent Technical Review (ITR) Process**

- Presented to OECM Project
- Director’s Workshop
- November 14, 2006
- Todd Lapointe,  Energy Central Technical Authority (CTA) Staff

**2006**
**Project**
**Management**
**Workshop**

## Energy CTA Background

***"Maintaining operational awareness of the implementation of nuclear safety requirements and guidance, consistent with the principles of Integrated Safety Management across the DOE ESE/NNSA complex (including, for example, reviewing Documented Safety Analyses, Authorization Agreements and readiness reviews as necessary to evaluate the adequacy of safety controls and implementation);..."***

**April 26, 2005 Secretary’s response to DNFSB Recommendation 2004-1 on CTA Roles & Responsibilities.  Authorities incl:**

**Notes:**
“On December 17, 2004, in response to Defense Nuclear Facilities Safety Board (Board) Recommendation 2004-1 in order to strengthen the Department's focus on preventing high-consequence nuclear accidents, former Deputy Secretary McSlarrow directed that the Under Secretary for Energy, Science and Environment (ESE) and the Principal Deputy Administrator for the National Nuclear Security Administration (NNSA) were designated to serve as the Department's Central Technical Authorities (CTAs) with respect to the activities under their purview.

Secretarial DNFSB Response April 26, 2005 from Secretary Bodman, “As the Department's responsible manager for the 2004-1 Implementation Plan, I am forwarding to you a Secretarial memorandum setting forth the roles and responsibilities of the Central Technical Authorities and Nuclear Safety Research Office. We intend to further describe these roles and responsibilities in our upcoming revision to the Implementation Plan.”

The CTAs are responsible for maintaining operational awareness, especially with respect to complex, high-hazard nuclear operations, and for ensuring that the Department's safety policies and requirements are adequately and properly implemented.

The Under Secretary for Energy, Science and Environment (ESE) serves as the Central Technical Authority (CTA) for those offices that are not part of the National Nuclear Security Administration (NNSA). As CTA, the Under Secretary:
Concurs with the determination of the applicability of DOE Directives involving nuclear safety included in ESE contracts pursuant to DEAR 970.5204-2(b);
Concurs with nuclear safety requirements included in ESE contracts pursuant to DEAR 970.5204-2(c);
Concurs with all exemptions to nuclear safety requirements in ESE contracts that were added to the contract pursuant to DEAR 970.5204-2;
Recommends to the Assistant Secretary for Environment, Safety and Health (EH) issues and proposed resolutions concerning DOE safety requirements, concurs in the adoption or revision of nuclear safety requirements (including supplemental requirements), and provides expectations and guidance for implementing nuclear safety requirements as necessary for use by DOE ESE employees and contractors;
Maintains operational awareness of the implementation of nuclear safety requirements and guidance, consistent with the principles of Integrated Safety Management across the DOE ESE complex (including, for example, reviewing Documented Safety Analyses, Authorization Agreements and readiness reviews as necessary to evaluate the adequacy of safety controls and implementation);
Periodically reviews and assesses whether DOE ESE is maintaining adequate numbers of technically competent personnel necessary to fulfill nuclear safety responsibilities; and,
Provides inputs to, reviews, and concurs with DOE-wide nuclear safety related research and development activities proposed by the Assistant Secretary for Environment, Safety and Health.

## CTA Staff Participation

**Supplement & reinforce existing processes**
**Participate with HQ teams, Field Office and Facility Representatives**
**Accountability to site processes**
**Promote Criteria Review and Approach Documents (CRADs) and consistency**
**Promote questioning attitude**

**Notes:**
“Better focus departmental awareness and management of issues related to nuclear safety.” Secretary Bodman, April 26, 2005. 

“I expect safety to be fully integrated in the project.  Specifically, by the start of the preliminary design, I expect a hazard analysis of alternatives to be complete and the safety  requirements for the design to be established.  I expect both the project management and the safety directives to lead project on the right path so that safety issues are identified and addressed adequately early in the project design.” Deputy Secretary Clay Sell’s memorandum dated December 5, 2005

Authorities
5.  Maintains operational awareness of the implementation of nuclear safety requirements and guidance, consistent with the principles of Integrated Safety Management across the DOE ESE complex (including, for example, reviewing Documented Safety Analyses, Authorization Agreements and readiness reviews as necessary to evaluate the adequacy of safety controls and implementation);

## ITR Background

**Energy CTA staff participated in the Savannah River Site (SRS) Salt Waste Processing Facility (SWPF) ITR**
**SWPF is intended to remove & concentrate the radioactive Strontium, Actinides, and Cesium from the bulk salt waste in the high-level waste tanks**
**DOE chartered an ITR team to review the preliminary design of the SWPF**
**ITR commenced in late-August with the final report due mid-November**

**Notes:**
DOE chartered an Independent Technical Review (ITR) Team to review the Preliminary Design of the SWPF.  This independent review focused on evaluating the technical sufficiency of design to support development of a baseline cost and schedule (Critical Decision-2 [CD-2]) per DOE Order 413.3. 

The scope of the ITR was defined in the form of Lines of Inquiry (LOI) that served as the framework for review team activities and for selection of review team members.  The LOIs were grouped into three categories:  (1) Civil/Structural Design, (2) Facility Safety, and (3) Engineering.  The ITR Team focused their attention on the specific subjects identified by the LOIs.

## ITR Goal

**Sufficient to support baseline cost and schedule**
**Mature enough to request Critical Decision 2 per DOE Order 413.3, *****Program and Project Management for the Acquisition of Capital Assets***

**Well defined goals from the outset critical to review success - For SWPF, is the design...**

**Notes:**
This independent review is focused on evaluating the sufficiency of design to support development of a baseline cost and schedule (Critical Decision-2 [CD]-2) per DOE Order 413.3.  As such, the design should be mature enough to support development of “detailed, resource loaded schedules and cost estimate for the entire project...”  In addition, the Performance Baseline “shall account for risks and mitigation strategies...”.
The results of the review will be used to see if the current design is mature enough to request CD-2.

## Responsibilities

_**DOE-HQ**_** facilitates communications with the Program Office**
_**DOE-Field**_** interfaces between the ITR and the contractor**
_**ITR team**_** performs a professional review**

**Clearly defined responsibilities are a must**

**Notes:**
Environmental Management Headquarters (EM HQ) - EM HQ will review and approve the SWPF ITR charter and team members.  They will also assure necessary communications with other EM entities that have an interest in the progress and outcome of the review and will arrange for necessary briefings or meetings that may be required.
DOE-SR - The Senior Project Manager will provide input to EM HQ on the SWPF ITR charter and team members.  He will also manage the interface between the SWPF contractor and the ITR.  This includes facilitating technical presentations, supplying technical information and providing general logistics support.
ITR Team - The ITR Team is responsible for conducting a professional review, resolving internal technical differences of opinions, organizing the final report, resolving comments on technical drafts, communicating with the Senior Project Manager concerning issues/needs of the ITR team in a timely fashion and producing a high quality review report.
The ITR Lead will be responsible for
being the single point of contact for the ITR team
assure the ITR teams meets the milestones identified in the attached schedule
being responsible for the final assessment report
keeping the ITR team effort focused on the LOIs

## Approach

**Kick-off meeting**
**Studies of preliminary design products**
**Sub-team meetings**
**Final meeting**

**Notes:**
Kick-Off Meeting for Project Overview, Engineering Discipline Reviews, and Site Tour
Studied Preliminary Design Products Via Hard Copies and EPC “Livelink” Internet Site
Sub Team Meetings for Detailed Presentations, Discussions with EPC Points of Contact, and Writing
Final Meeting Focused on Validation of Findings, Sub Team Discussions, and Report Writing

## Lines of Inquiry (LOI)

**Civil/Structural Design**
**Facility Safety**
**Engineering**

**Scope defined in the form of LOI.  For SWPF grouped by:**

**Notes:**
Scope defined in the form of Lines of Inquiry forming the basis for Team Selection and Activities

Civil/Structural Design LOIs
Central Processing Area (CPA)
Support Facilities
Subsurface Design
Risk Management

Facility Safety LOIs
Radiation Protection
Material Handling
Integrated Safety Management (ISM) 
Quality Assurance (QA)

Engineering LOIs
Process Design
Mechanical Equipment/Piping/Tank Design/ Heating, Ventilation, and Air Conditioning (HVAC)
Electrical Design
Instrumentation and Control (I&C)
Limited Construction 
Operations / Maintenance / Decontamination & Decommissioning (D&D)
Risk Management

## Team Structure

**Experts with extensive experience in:**
- Design
- Engineering
- Chemical Processing
- Radioactive Waste Management
**Expertise commensurate with established LOI**
**Free of conflicts of interest**

**Notes:**
Total of 22 team members selected & organized into 3 Sub Teams Matching Charter. Sources Included:
EM-21 Resume Database
Recommendations from DOE-SR, DOE-HQ, and Team Leader
Previous ITR Reviews (WTP Best & Brightest Review)

COI with Parsons or Washington Savannah River Company

Harry Harmon, Team Lead

Civil/Structural Sub Team
Peter Lowry, Lead
Carol Costantino
Robert Kennedy
Loring Wyllie
John Christian
Les Youd
Tom Anderson
Facility Safety Sub Team
James Langsted, Lead
Chuck Negin
Jerry Evatt
Richard Stark
Todd LaPointe
Norman Moreau
Engineering Sub Team
George Krauter, Lead
Art Etchells
Oliver Block
Tim Adams
Stephen Gosselin
Patrick Corcoran
Ken Cooper
Kari McDaniel

## SWPF ITR Preliminary Results

**SWPF project ready to move to final design pending a management plan for the mitigation of significant technical risks**
**Future, focused ITRs recommended for critical ongoing activities**
**Final report pending**

**Notes:**
Specific future ITR recommendations for SWPF included:
Geotechnical Studies
Air pulse agitator testing
Large-scale cross flow filtration
Caustic Side Solvent Extraction centrifugal contactor testing

## Lessons Learned

**Facility safety needs to focus more on the Preliminary Hazards and Documented Safety Analyses (PHA/PDSA)**
**ITR sponsors need to have a plan to move forward based on the results**

**CNS and CTA staff reviewed the outcome of and made the following observations:**

**Notes:**
Facility safety needs to focus on the PHA/PDSA
Review and agree/disagree with the PHA results
Pass judgment on the appropriateness of the controls to mitigate identified hazards
Especially critical during the earliest design stages (CD-1)

ITR sponsors need to have a plan to move forward
Need to understand how the gaps will be resolved
Clear and meaningful support toward resolution

Specific CTA AB Staff Feedback:
Section 4.0 of the ITR report talks about Facility Safety.  It should focus much more on PHA/PDSA and commenting on the appropriateness of the engineered safety design features, especially at this stage of the project (CD-1, CD-2 and in between).  Once they have selected the process they should be able to do a complete job on PHA and a fairly good job on PDSA.
In other words, there is no excuse for an incomplete PHA or PDSA at this time.  The ITR report did not say much on PHA and PDSA.  Shielding design/calculations, radiation protection, lab design, ALARA and material handling are kind of secondary in importance.  The key element of ISM is the identification of hazards.
The ITR should “independently” review and agree/disagree with the PHA results and pass judgment on the appropriateness of the controls to mitigate the hazards.  I see very little discussions on this subject (in section 4.3.2, totals half a page).  The basis for agreement or disagreement was not provided.  If later on (in CD-3) someone identified a missing control it will be too late to implement any changes.  I believe this is a significant deficiency of this report.