# Presentation: 868048

## Hanford Cleanup

**Keith Klein**
**December 4, 2003**

**Project**

**Hanford**

**Closure**

## Oversight Responsibilities

- Office of the Manager

- Independent Oversight

- Assistant Manager for River Corridor

- Assistant Manager for Central Plateau

- Assistant Manager for Safety and Engineering

- Assistant Manager for Administration

-   Project Effectiveness
-   Planning
-   Productivity
-   Cost/Schedule
-   Safety/Engineering
-   Environmental
-   Quality

-   Nuclear Safety
-   Criticality Safety
-   Engineering
-   Radiation Protection
-   Occupational Safety & Health
-   Vital Safety Systems
-   Safeguards & Security
-   Emergency Preparedness
-   Conduct of Operations
-   Training
-   Quality Assurance
- Corrective Action Management
- Independent/Management Assessments
- Software QA
- Suspect/Counterfeit Items

-   Procurement
-   Financial

-  RL Operations Oversight

-   Project Effectiveness
-   Planning
-   Productivity
-   Cost/Schedule
-   Safety/Engineering
-   Environmental
-   Quality

- 2

**Notes:**
 Line Management flows directly from EM to me to FHI (Ron G.)
 I hold the contractor accountable for good safety performance 
 My organization supports me with my line management responsibilities
 I have assigned responsibility for Contractor Oversight
 AMRC & AMCP oversee....
 AMA oversee....
 AMSE provides:
 Programmatic Oversight 
 Fac Reps provide day to day operations awareness and work closely with Mission Elements and SME’s 
 Safety System Oversight of Vital Safety Systems
 AMRC & AMCP support accelerated mission completion
 AMSE provides me feedback regarding SAFE mission completion (no conflict of interest) – I am the honest broker (I am responsible for mission completion and safety)
OIO provides independent oversight of RL operations provides me feedback regarding the effectiveness of RL operations.
Sludge Water System Lessons Learned identified the need to clarify Mission Element responsibility for conducting Project Oversight to determine effectiveness (e.g. scheduling, planning)

## RL Oversight of Contractors

- Program Description document (submitted) defines how RL performs contractor oversight
-   Describes Regulatory Oversight Authority
-   Describes Types Of Oversight
-   Operational Awareness
-   Surveillances
-   Assessments
-   Establishes Oversight Responsibilities
-   Describes Functional Areas To Be Assessed
-   Sets Minimum Oversight Expectations & Frequencies

- 3

**Notes:**
Oversight Program Description (to be submitted) describes approach for conducing oversight..

“Directives that set requirements and expectations” include, but is not limited to, DOE P450.4 (Safety Management System Policy), DOE P450.6 (Line ESH Oversight Policy), DOE O414.1A (Quality Assurance), DOE O470.2B (Independent Oversight and Performance Assurance Program), DOE P470.1 (Integrated Safeguards and Security Management Policy), DOE O151 (Comprehensive Emergency Management System), DOE O470.1 (Safeguards and Security Program), DOE P205.1 (Department Cyber Security Program), DOE O 205.1 (Department of Energy Cyber Security Management Program), etc.  In addition, the EM Project Oversight Policy establishes expectations for Project Oversight.
In general the RL Oversight of Contractors Program description and the processes and procedures in the RL Integrated Management System (RIMS) are consistent with the DRAFT Policy 226.1 (Department of Energy Oversight Policy) and the requirements contained in the DRAFT Notice 226.1 (Implementation of Department of Energy Oversight Policy).  Once promulgated, RL can relatively quickly come into compliance with the Policy and Notice.  
The following exceptions are noted: 
 Oversight PD does not specifically address cyber security (although RL does provide cyber security oversight)
 Oversight PD does not require "effectiveness of contractor assurance system will be determined based on objective criteria agreed to in advance with the contractor."  (Ref. Attach. 4 Section 1.e) 
 Oversight PD does not require the Manager to determine when oversight can be reduced.  (Ref. Attach. 4 Sec. 1.d)

Types of Oversight:
Operational Awareness:  Facility Representatives provide day to day operational awareness
In addition to day to day operational awareness, conduct planned formal oversight.
Surveillance:  More formal than Operational Awareness...planned and documented....narrower scope than an assessment, usually completed by one assessor, usually at one facility/project, usually of relatively short duration (a quick but formal look).
Assessment:  Broader in scope than a surveillance, multiple facilities/projects, more in-depth review, usually more than one assessor, longer duration than a surveillance (a more in-depth formal look).

Program Description not perfect.  Using and improving it based on Mission Element oversight weaknesses identified from SWS project.

## RL System For Oversight of Contractors

- Crosscutting Processes

- Oversight Performance
- Procedures

- Technical Surveillances

- _RL System For Oversight of Contractors_

- Technical Assessments

- Org-Specific Procedures

- Facility Rep Instructions

- Stop Work

- Program Descriptions

- RL Oversight of Contractors

- Facility Representative Program

- Training and Qualification for
- Personnel Performing Technical Surveillances and Assessments

- Corrective Action Management

- Oversight Planning
- Procedures

- Integrated Evaluation Planning

- Evaluation & Reporting
- Procedures

- Conditional Payment of Fee

- Event Reporting

- Quarterly Evaluation and Reporting of Contractor Performance

- Federal Managers’ Financial Integrity Act

- Federal Managers’ Financial Integrity Act Reporting

- DOE-RL Price -Anderson Amendments Act (PAAA) Organizational Specific Procedure

- Overview of Occupational Safety and Health (OSH) Technical Surveillance and Assessment Guides

- Overview of Quality Assurance (QA) Technical Surveillance and Assessment Guides

- Overview for Radiation Protection Technical Surveillance and Assessment Guides

- Safety System
- Oversight

- 4

**Notes:**
 Integrated Evaluation Plan – Developed Annually; updated Quarterly;   Lists Contractor Assessments (Independent and Management Assessments) and RL Formal Oversight.  Integration, remove redundancy, I know what the contractor is assessing and what my staff is assessing.  Useful in determining if contactor has a rigorous and robust self assessment system (RL oversees contractor independent and management assessments).  
 RL planned assessments in the IEP are based upon: High Hazard Activities (e.g., TRU Waste Retrieval, 233S, PFP D&D, etc), importance of work to site mission, Fac. Rep. day to day operational awareness and their knowledge of potential problem areas, minimum frequencies described in RL Oversight of Contractors Program Description, past performance of the contractor, and Performance Indicators.
Training and Qualification Program 
 I have recently developed a Training and Qualification Program for assessors
 Verifies staff have the necessary educational background,  experience in conducting oversight, and training (e.g., assessor training, root cause analysis, report writing, etc) to ensure effective oversight.
 Qualifies staff as an:
 Assessor - can conduct an assessment under the supervision of a lead assessor
 Lead Assessor - can lead an assessment/conduct an assessment w/o supervision
 Team Lead Assessor - can lead a team of assessors
Also developed an Assessor training class (assessment planning, preparation, performance and documentation) that 76 of my staff have recently attended
 Corrective Action Management process
 Defines our process for corrective action management.  Depending on the significance of deficiencies identified during surveillances/assessments:
 Requires a formal corrective action plan (CAP) and RL verification of corrective action completion (e.g., FY 03 Lockout/Tagout Assessment)
 Requires RL verification of corrective action completion but does NOT require a CAP (e.g., FY 03 Sludge Water System Design Surveillance)
 Does not require a CAP or RL verification of corrective action completion (e.g., PFP Emissions Monitoring Surveillance)

 Fixing to better define Mission Element oversight responsibilities. 

## Fiscal Year 2003Planned & For Cause Oversight

- Sludge Water System Design/Startup
- Lockout/Tagout Program
- Unreviewed Safety Question process
- Hazard Identification & Controls
- K-Basins Safety Culture
- PFP Criticality Safety

- Radiological Work Practices
- Corrective Action Management
- FHI System Engineer Program
- Conduct of Operations
- Procedure Content and Use
- Hanford Fire System

- _192 Completed - Key Areas Reviewed_

- 5

**Notes:**
SWS Design/Startup:  Multiple surveillances have been completed against the SWS design, authorization basis, and SNFP management systems resulting in the suspension of the contractor ORR and identification of multiple broader scope issues (USQ, Eng., etc...) that are being evaluated and addressed by the contractor.
LOTO:  A surveillance was completed at each of the FHI projects resulting in the identification of programmatic weaknesses that required substantial corrective actions and programmatic compensatory measures.
USQ:  An assessment of USQ program implementation across FHI identified a number of programmatic problems and weaknesses in program implementation
Hazard Identification &Controls:  A surveillance completed at each FHI project and a paretto analysis of radiological contamination events identified weaknesses in FHI Hazard identification and control particularly during changing field conditions
K-Basin Safety Culture:  A verification surveillance of K-Basin corrective actions designed to improve safety culture and address employee concerns resulted in the identification of shallow and incomplete corrective actions
PFP Criticality Safety:  A surveillance was completed against the program and field implementation of criticality safety at PFP resulting in a number of minor findings and opportunities for improvement.
Radiological Work Practices.  A surveillance completed at each FHI project identified a few isolated non-compliances
Corrective Action Management:  A surveillance completed at each FHI project identified programmatic weaknesses in the FHI CAM program and field implementation.
FHI System Engineer Program:  Surveillances and assessments of FHI’s System Engineer program identified numerous programmatic weakness in processes, procedures, and implementation, that required substantial corrective actions 
Conduct of Operations:  Each project and facility receive periodic oversight of the various aspects of Conduct of Operations to validate implementation.  Minor noncompliances were identified across FHI throughout the year.
Procedure Content and Use:  A surveillance completed at each FHI project identified minor noncompliances at some FHI projects.
Hanford Fire System:  An assessment of Fire Protection program and implementation identified a number of fire protection findings requiring resolution by FHI.

## RL Safety Indicators4th Quarter Fiscal Year 2003

| 
Near Misses | 
Lockout/Tagout
 | 
Procedure
Noncompliance | 
Personnel 
Contaminations |
| --- | --- | --- | --- |
| 
Radiation Exposure
 | 
Safety Basis
(+USQ’S) | 
Criticality Safety | 
OSHA Recordable Case Rate |
| 
Days Away for Work Case Rate | 
DOE Safety Cost Index | 
Corrective Action Management | 
Shipping Noncompliances |
| 
Environmental Events | 
Readiness Reviews |  |  |

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- Quarters

- Year end

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- 4

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- 4

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- 4

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- FY02
- 28

- FY03
- 57

- FY02
- 24/15

- FY03
- 28/6

- FY02
- 2/12

- FY03
- 2/28

- FY02
- 1.6

- FY03
- 1.44

- FY02
- 9/12

- FY03
- 5/22

- FY02
- 2

- FY03
- 2

- FY02
- 8.0

- FY03*
- 11.13

- FY02
- 0.11

- FY03
- 0.11

- FY02
- n/a

- FY03
- 3

- FY02
- 0

- FY03
- 1

- Clothing/Skin

- occur/infracts

- Viol/+USQs

- FY02
- 5

- FY03
- 7

- FY02
- 13

- FY03
- 15

- *SNF=44.69

- 6

**Notes:**
As part of my oversight, I use 14 key performance indicators to routinely monitor safety performance.  

I take into consideration contractor data as well as input from my staff.

I meet with Contractor senior management routinely (monthly/quarterly) to review performance metrics and discuss actions that the contractor has taken or will take to improve performance.  I take contract actions as warranted.

Performance Indicators are also used to identify areas where increased oversight is necessary.  Example:  SNF high OSHA recordable rate, Safety Cost Index....RL OSHA Subject Matter Expert (CIH/CSP) and Fac. Rep. providing additional operational awareness and formal oversight at SNF.

I continue to assess the usefulness of each of these metrics and make the necessary changes.  I also continue to look for more leading indicators.

FY 03 assessments and performance indicators are used in planning FY 04 assessments.

Green - Above established minimum performance expectations and positive trend
Yellow - Above established minimum performance expectations and Negative Trend
Red - Below established minimum performance expectations (potential for CPOF)

## Fiscal Year 04 Planned Formal Oversight

**Fiscal Year 04 Planned Formal Oversight**

- Total Planned:    255
-   -  Assessments: 29
-   - Surveillances: 226

- 7

**Notes:**

Note:  255 Planned (More Oversight not less than FY 03 [192] – does not include For Cause/Reactive Assessments)
Reason for more oversight:  TRU Waste Retrieval beginning, PFP D&D will soon begin, 233S demolition in progress, increased oversight of BHI (contract extension), Mission Elements providing more oversight, and increased oversight at SNF due to poor past performance.

Summary of Key FHI Oversight for FY-04
FHI-Wide:
- Independent Assessment Process (Assessment)
- Configuration Management (Assessment)
- Management Assessment Process (Assessment)
- USQ Process (Assessment)
- Lockout/Tagout Process (Core Surveillance/Assessment)
- Corrective Action Management Process (Core Surveillance/Assessment)
- ISMS Maintenance (Core Surveillance/Assessment)
SNFP
- Verification of AB
- Sludge Water System Oversight
- Transportation Safety Documentation
- Chemical Safety (Surveillance)
- Conduct of Operations
- OSHA/Worker Safety (Surveillance)
- Radiological Controls
- Work Planning
PFP:			TRU Retrieval:
- 241-Z D&D Startup		- Headspace Gas Sampling
- Verification of AB/TSR		- TRU Retrieval Startup
- SST Shipment Preparations		 - Radiological Controls
- Radiological Controls/Planning	 - Retrieval Process Evaluation
- Conduct of Operations
- Job Hazard Analysis (OSHA)
- Waste Disposal

## Technical Staffing

- Office of the Manager

- Assistant Manager River Corridor
- 21

- Assistant Manager Central Plateau
- 25

- Assistant Manager Safety & Engineering
- 52

- Assistant Manager for Administration

-   14 BS
-     7 MS
-     1 STSM
-   19 TQP
-     4 PEs

-    37 BS
-    11 MS
-      1 PhD
-      3 Non-degreed
-      5 STSM
-    31 TQP
-    18 Facility Representatives
-      6 System Engineers
-      8 PEs
-      2 CIHs
-      2 CSPs
-      1 CHP

- 3 BS
- 2 MS
- 2 PhD
- 2 STSM
- 6 TQP

-   10 BS
-   14 MS
-     1 PhD
-     2 STSM
-   21 TQP
-      5 PEs

-   15 BS
-   10 MS
-     1 PhD
-     3 STSM
-   22 TQP
-      3 PEs

- Project Management
- Support Division
- 26

- Independent
- Oversight
- 7

- 8

**Notes:**
I have the necessary technical staff to provide effective oversight.  I have no additional needs.

Will qualify additional staff as STSM (e.g., 8 Project Directors).

Improving competencies in software quality assurance (recent complex wide issue with the Board, Shiv Seth [who is well qualified is our designated SME).

As we move to D&D, emphasis will shift from Nuclear Safety (protecting the public and environment) to Construction (or Destruction) Safety (even more emphasis on worker safety).

Note/FYI:  RL subject matter experts assist ORP with oversight upon request.  RL Certified Industrial Hygienist recently assessed CHG Industrial Hygiene Program (in response to Tank Farm “Vapors” issue).  Last year RL Radiation Protection personnel assessed CHG Rad Con Program; Fire Protection and Criticality Safety Assessments have also been completed on behalf of ORP.

## Corrective Action Program	

- Problem Identification
-  Contractor Independent & Management Assessment
-  DOE Line Management Oversight
-  Accidents/Incidents
- Quality Improvement
- Deficiency Evaluation and Causal Analysis
- Corrective Action Identification
- Corrective Action Tracking and Trending
- Corrective Action Completion and Verification
- Neither are adequately robust or mature at this time to reduce DOE oversight

- Integrated
- Evaluation
- Plan

- 9

**Notes:**
Information on slide describes process:

Basis for saying neither is adequately robust or mature...:

  During Fiscal Year 2003, RL conducted an assessment of FHI Corrective Action Program, identified several deficiencies and required corrective actions

 Improvement has been seen but I do not yet consider the system to be mature.

  September 2002, I directed FHI modify their Quality Assurance Program Description to strengthen:

Management Assessment 
 Add detail to ensure manager’s routinely and effectively assess processes, identify issues, and correct identified problems
 Identify frequency of management assessments
 Include use of performance data & other feedback mechanisms to identify areas to be assessed

 Independent Assessment
 Ensure true independence
 Include frequency of project and functional area (e.g. rad protection) independent assessments
 Include verification/validation follow-up of corrective actions
 Evaluate effectiveness of management assessments

  February 2003 – RL re-approved FHI Quality Assurance Program Description

  Fiscal Year 2004 – December 2003 RL will be conducting an assessment of FHI Independent Assessment process

  Fiscal Year 2004 – Feb/March 2004 RL will be conducting an assessment of FHI Management Assessment process

## Columbia Accident Lessons Learned

- Lack of independence/checks and balances in organizational structure.  Budget/schedule pressures reduced technical capability of oversight organizations
- Taken deliberate steps to achieve independence in safety oversight in my organizational structure
- Problem Identification
- Improving the Mission Element oversight of 8 Projects (STSM qualification)
- Improving corrective action system
- Developed project metrics for cost/schedule and safety

- 10

## Columbia Accident Lessons Learned

- Attitude/Safety Culture.  Lack of intellectual curiosity/skepticism.  Focused on why SAFE vs. analyzing why UNSAFE.
- Completed Project Risk Assessments (asks the “what ifs”)
- Challenging contractor/RL staff at Monthly and Quarterly Project Reviews
- Encouraging differing opinions (don’t shoot the messenger)
- Decision makers not hearing the facts on technical issues (rolled up/dummied down)
- Holding Plan of the Day meetings to hear first hand from Project Directors and Facility Representatives key issues that affect the projects

- 11

## RL’s Self Assessment Activity

- RL Quality Assurance Program Description requires each organization, as a minimum, to conduct one management assessment annually
- Issued memo further defining expectations for management assessments
- The RL Office of Independent Oversight performs independent assessments of RL organizations and functions

- 12

**Notes:**
During FY 03 several self assessments were conducted (e.g., Fac Rep., AMRC, RIMS, etc.) however I feel that our performance in this area is not yet adequate.

During FY 03, OIO conducted eight organizational assessments, six special assessments, and the ISMS assessment
24 findings, 43 observations, 21 criterion 5 deficiencies, 17 criterion 3 deficiencies

## Fiscal Year 04 Self Assessment Plans

- Each organization will perform a management assessment during the first quarter
- OIO will perform:
- 14 functional assessments
- FY 03 RL ISMS corrective action verification
- FY 04 annual ISMS assessment
- Special assessments as requested

- 13

## “Manage the Contract”

- Have good contracts
- Know the contract
- Enforce the contract
- Monitor end points
- Monitor processes
- Monitor compliance
- Report deficiencies to RL line manager
- Take contract action when indicated

- Only the Manager (or CO) gives direction – not the monitors
- Contractual requirements versus individual preferences
- Relationship is cordial but “arms length”
- Scrupulous avoidance of conflicts of interest
- Know what is going on daily at the floor level

- 14