# Presentation: 471818

## Upgrade of the Pantex Site Safety Basis

- Lessons Learned from Validation of  the Site Integrated Implementation Plan

## History/Background

- In February 2001, 10 CFR 830 Part 200 Subpart B passed into law Safety Basis Requirements for Hazard Category 1,2,3 DOE Nuclear Facilities
- The existing Pantex Safety Basis did not meet the new CFR requirements.
- In response, NNSA Pantex Site began the task of upgrading the Pantex Safety Basis.
- The CFR set a deadline for compliance of April 10, 2003.

**Notes:**
Pantex had a TSR with very little basis for controls.  Expert based approach/Process history

## Pantex Safety Basis

- AB

**Notes:**
Authorization Agreement is AB plus additions for start ups, restarts of nuclear operations

## Requirements for Rule Compliance

- Identify and Analyze the Hazards
- Categorize the Facility Consistent with DOE-STD-1027-92 and DOE Order 5480.23
- Prepare Documented Safety Analysis
- Establish Scope of Work At the Facility
- Establish Hazard Controls
- Incorporate Changes Annually
- Implement rule compliant USQ program

**Notes:**
Contractor/Labs and DOE worked to develop analysis
Implemented site procedures to categorize facilities
DOE Guide 421.1-2 Interpretation Guide for use in developing DSA to meet subpart B of 10CFR830

## Pantex Response	

- Pantex Developed Basis for Interim Operations (BIO) and rule compliant Safety Analysis Report (SAR) modules to meet CFR deadline.
- All Rule Compliant SAR Modules DOE Approved by the CFR deadline.
- Hazard Analysis Reports  (HAR) Upgraded Over Time By Exemption as per the CFR

## Pantex Response

- Implement Technical Safety Requirements (TSR). Effective February 2000
- Annual updates to Documented Safety Analysis (DSA) approved by PXSO
- Unreviewed Safety Question (USQ) Determination Program Approved by PXSO

## DSA Implementation

- All DSA’s approved, Hazard Controls Established
- What about implementation?
- Integrated Implementation Plan Developed to systematically assure implementation of Hazard Controls
- Why?

## Why IIP?	

- Two obvious approaches:
- Shut down all nuclear operations, retrain all affected personnel, rewrite all affected standards, perform ORR to restart operations after all controls implemented
- Implement controls in phases and require DOE validation of implementation
- Pantex Site Office Management selected second option to support national defense commitments

## Pantex IIP Process

- Contractor submits IIP
- Plan approved by DOE
- Hazard Controls are implemented in phases by contractor
- Hazard Controls defined in the DSA, implemented by TSR

## Pantex IIP Process

- Contractor Readiness Assessment Conducted
- PXSO Systems Engineering Validation
- TSR Controls Made Effective
- Hazard Control Implementation validated by PXSO

**Notes:**
Formal CRA report and readiness to proceed letter submitted to PXSO
Controls officially turned on in Applicability Matrix

## Hazard Controls - 10 CFR 830.200 Subpart B, Appendix A Sets forth acceptable TSR Hazard Controls:

- Safety Limits
- Operating Limits
- Limiting Control Settings

- Limiting Conditions for Operations
- Surveillance Requirements
- Administrative Controls
- Design Features

## IIP Scope - Two Hundred and Twenty Two New Controls

- 113 Administrative Controls (AC)
- 84 Design Features (DF)
- 4 Limiting Conditions for Operations (LCO)
- 21 Controls deemed Important to Safety Not TSR level controls

## DOE IIP Validation Approach

- PXSO management required validation documented comparable to a NNSA Readiness Assessment
- Nuclear Engineering group developed a PXSO Plan of Action/Team Lead named
- FRs were selected to perform validation
- Implementation Plan developed

**Notes:**
Wanted a formal validation
FRs lead and/or participate in majority of PXSO Readiness Assessments
FRs selected because we have facility expertise,know plant work control processes, know the people at floor level, know the SB and how it was developed
Also FRs have experience in conducting performance based assessments

## DOE IIP Validation Approach

-  CRADs were developed
- Validation was conducted from top tier document (DSA) to floor level implementation.
- Improperly Implemented Controls TSR violations
- Final Report Submitted to PXSO Management

**Notes:**
Team lead was assigned
The Nuclear Engineering group developed a PXSO Plan of Action for the assessment
The team Lead developed a PXSO Implementation Plan
Since the controls were effective immediately, any findings would be TSR violations (mostly)

## Contractor Lessons Learned

- Prioritize Resources
- Integration of Implementation and DSA development
- Careful Planning of Training in support of implementation
- Mature Systems Engineering Program eases implementation
- Prioritize Controls – Work the worst first
- Tracking of Controls

**Notes:**
Proper implementation takes more resources than you would expect (Plan then X3)
If you do not plan with the end in mind you get controls that look good on paper but don’t work at the shop floor level
Figuring out who to train, when, how often and to what depth is important.  You can waste time and money (resources) overtraining on a simple control or end up having to retrain because people didn’t get it on a complex one.
Systems engineering must be involved in implementation if you do not have systems control and status you cannot assure implementation.  All the controls, the people and facilities and systems have to be on the same page
Formal tracking of controls during implementation has to be done. One person has to own this to make sure nothing slips through the cracks.  Everyone owns implementation so it is easy for no one to own a single control.  Mention evidence files

## NNSA Lessons Learned

- Accept only completed work
- Group the Hazard Controls
- Expect Roadblocks
- Hold the Line on Administrative Controls
- Prioritize Resources
- Develop well thought out CRADS

**Notes:**
Approve only controls that are implementable. Have a questioning attitude.  Make the contractor commit to the fact that the control can be put into practice and is proven.  Implement controls immediately on approval if they can’t be then don’t approve them.  Validate them real time
Certain controls work together and it is much easier to validate them in groups of similar controls both from the perspective of assuring complementary controls work together and from a logistics and resource allocation standpoint
There will be controls that get through the approval cycle, have wonderful analysis associated with them, have been validated by the contractor, get to the floor level and just don’t work.  The complexity of the process almost assures this.
Administrative controls can begin to overtake the process.  It is easy to say we will just control this or that administratively but you don’t want to overwhelm your operators with too many responsibilities.  Work toward engineered controls or change an admin control to an LCO with clear concise steps and instructions
Validation of control implementation takes a lot of time and research, interviews and coordination with contractor personnel Estimate about 15hrs per control.  This can eat up time of the most technically skilled staff in the office for significant amounts of time over the course of a year  Think about whether a sampling approach might be more efficient with minimal loss of effectiveness
Had to develop CRADs that defined the Hazard Control.  Looked at the elements of the hazard control from the top down.  This streamlined the review