# Presentation: 692569

## BWXT Y-12

- Operational Readiness Process
- General Overview (Q 50493656)

## Why is Readiness Required?

- DOE O 425.1, *Startup And Restart Of Nuclear Facilities,* requires “Contractors must establish procedures as necessary to manage startup and restart actions in accordance with this Contractor Requirements Document (CRD).”
- National Nuclear Security Administration (NNSA) Y-12 Site Office (YSO) has issued a Contractor Requirements Document, YSO-CRD-03-01, *Start-Up and Restart of Operations, Activities and Facilities at Y-12,* that provides further guidance for implementing DOE O 425.1 at Y-12.  The BWXT Y-12 contract includes DOE O 425.1 and YSO-CRD-03-01 as a contractual requirement.
- This requirement is flowed into the Standards/Requirements Identification Document (S/RID) as Sub-element 01.07, *Operational Readiness Reviews and Readiness Assessments*

## What is Readiness? 

- Y15-190, *Readiness Manual*, defines Operational Readiness as “*A state that is achieved only when facilities, personnel, equipment, and procedures are in a condition that would allow the FACILITY, ACTIVITY or OPERATION being started or restarted to be conducted, i.e. actual material processing could be safely and compliantly performed without additional FACILITY, personnel, equipment, or procedure changes if requested.  Preparing for the readiness confirmation review, rather than preparing for unrestricted operations, is not achieving operational readiness*...”.

## What is Readiness?

- In other words,
- _Safety Bases Implemented_.  Identification of the hazards and determination of a sufficient set of controls which gives preference to engineered controls.
- _Equipment and Facilities are Ready. _ Structures, Systems, Components are prepared, tested and ready to start operation of the facility or process within the bounds of acceptable risk.
- _Procedures are Validated_ and have been field demonstrated to support operations, maintenance and surveillances of process and support equipment.
- _Personnel are trained and proficient_.  Understand Processes and Safety Bases and are proficient in using procedures for operations and support requirements.

## How is Readiness Implemented at Y-12 ?

- Policy Y12-052, *Operational Readiness*, defines the Y-12 policy on Readiness.
- Procedure Y15-190, *Readiness Manual*, defines the Y-12 process for the preparation, conduct, and support of readiness assessments and reviews that confirm that a FACILITY, ACTIVITY, or OPERATION has achieved a satisfactory state of operational readiness and can be safely, securely, and compliantly started or restarted.

## In What Facilities Does Y15-190 Apply? 

- Y15-190, Readiness Manual, applies to Startups or Restarts of FACILITIES, ACTIVITIES or OPERATIONS that either are or are located in hazard category 2 and 3 nuclear FACILITIES or hazardous non-nuclear FACILITIES.

## When is Readiness Invoked?

- A project or task should be reviewed for Readiness Process applicability when:
- developing a PEP for new projects/activities;
- developing a Change Request in accordance with Y15-187, Integrated Safety and Change Control Process, that substantially alters the operation of an existing process or adds a new process;
- restarting Operations/ Processes/ Equipment that has been idle for more than 6 months without a YSO approved Continued Operations Plan; and
- restarting equipment that has been shutdown by YSO direction or after an abnormal event driven shutdown.

## Terms used in Readiness

- FACILITY
- The term FACILITY refers to buildings and other structures, their functional systems and equipment, and other fixed systems and equipment installed therein.  Individual activities will only be considered facilities when a separate Documented Safety Analysis exists for the individual activity.
- ACTIVITY
- A group of related operations that support a particular element of production or program work.  Activities are typically a higher level grouping of operations identified in the Authorization Agreement for the facility where the activity is conducted.

## Terms used in Readiness

- OPERATION
- A specific process or a series of tasks performed in the accomplishment of program work.
- Task:
- Well defined components of program work that collectively constitute an OPERATION. The components are usually associated with operation of equipment, or handling/manipulating a work piece.  Each component of program work will usually have hazards associated with the actions being performed.

## Terms used in Readiness

- Operational Readiness Review (ORR)
- A disciplined, systematic, documented, performance based examination of facilities, equipment, personnel, procedures, and management control systems to ensure that a facility will be operated safely within its approved safety envelope as defined by the facility safety basis.

## Terms used in Readiness

- Readiness Assessment (RA)
- A review that is conducted to determine a facility's readiness to startup or restart when an Operational Readiness Review is not required or when BWXT Y-12’s standard procedures for startup are judged by BWXT Y-12 management or NNSA management to not provide an adequate verification of readiness.

## Terms used in Readiness

- Standard Operations Checklist
- When a startup/restart does not require an RA or ORR then it is considered a startup/restart that uses the Y-12 standard startup process (i.e., standard operation checklist). Confirmation of the satisfactory attainment of operational readiness for standard operations is achieved by using _[UCN-21050](https://www-internal.y12.doe.gov/forms/UCN-21050.doc)__, _*Standard Operations Checklist*.

## Terms used in Readiness

- Responsible Manager
- The line manager directly responsible for the FACILITY in which an ACTIVITY or OPERATION will be started or restarted.
- For certain startup or restarts a Project Manager may be assigned as an “agent” for the Responsible Manager with the responsibility to bring a specific project to a state of operational readiness.

## Terms used in Readiness

- Startup Authority
- Startup/Restart Authority for ORRs is determined in accordance with DOE O 425.1 and Memorandum from Linton F. Brooks to Principle Deputy Administrator and Deputy Administrator for Defense Programs, dated April 20, 2005, *Delegation of Authority for Order 425.1C, Startup and Restart of Nuclear Facilities*.
- The Manager, YSO, will be the Startup/Restart Authority for Level II RAs unless delegated (i.e., via SNR approval) to the Contractor.
- The Contractor Senior Manager will typically be the Startup/Restart Authority for Level I (checklist) RAs.

## Readiness Process Diagram - 1

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## Continuing Operations Plan

**Continuing Operations Plan**
- A program to provide for and document the deliberate and systematic maintenance of equipment/ system operational readiness, procedure accuracy and viability, and personnel qualification/ proficiency, and readiness to operate in support of a program-related mission(s).  Where feasible (based on a documented analysis of benefits, risks, and costs), surrogate materials shall be used to provide assurance that equipment/ systems remain operational.
- The _[UCN-21695, Continuing Operations Plan](http://www-internal.y12.doe.gov/forms/UCN-21695.doc)_ must be submitted on the Startup Notification Report within six months of the date when PROGRAM WORK was last performed.

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## Determine if a Startup/Restart Exists

- Is it a new project/activity/work scope?
- Has a Change Request been started substantially alters the operation of an existing process or adds a new process?
- Has the Operation/ Processes/ Equipment been idle for more than 6 months and a Continued Operations Plan is not approved by YSO?
- Was the Operation/ Processes/ Equipment shutdown by YSO direction or shutdown by an abnormal event?
- If any are YES then a Startup/Restart exists.

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## Develop Scope

- Define the Scope of the Startup/Restart
- Identify the processes involved.
- Is the Safety Basis affected?
- Has Criticality Safety approach changed?
- List the affected equipment (SSCs)
- Evaluate Security Impacts
- List affected procedures
- Will personnel qualifications change
- Walk down the Facility and System to look for other interactions/interferences, new hazards
- Document the scope in the Startup/Restart section of _[UCN-21679](http://www-internal.y12.doe.gov/forms/UCN-21679.doc)__, _*Readiness Applicability and Review Level Determination*

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## Determining the Readiness Confirmation Level

- Evaluate the Startup/Restart at the Facility’s Operational Safety Board meeting
- Answer questions 1 through 8 on _[UCN-21679, ](http://www-internal.y12.doe.gov/forms/UCN-21679.doc)_*Readiness Applicability and Review Level Determination* and determine review level.
- Have the review level determination approved by Readiness Assurance Manager and/or Senior Management

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## Readiness Process Diagram - 2

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## Startup Notification Report (SNR)

- The SNR is updated and submitted quarterly to YSO for review and approval by the 15th day of first month of each subsequent quarter.
- In accordance with DOE Order 425.1, the SNR is required to look ahead at least 12 months and to update information from previous periods for startups or restarts that have not yet occurred and to add information for each startup or restart that has been identified since the last report.
- The SNR is used by NNSA to grant approval of the proposed review level [i.e., whether readiness will be confirmed by the performance of a Readiness Assessment (RA) or an Operational Readiness Review (ORR)] and to track the status of startups or restarts.
- Additionally, it ensures that the appropriate Startup/Restart Authority is established.
- To ensure that each startup or restart is properly evaluated, NNSA also requires that startups or restarts using the Standard Operations Checklist or making use of a Continued Operations Plan also be included on the SNR.
- The asterisked questions in the Startup/Restart Description section of _[UCN-21679](http://www-internal.y12.doe.gov/forms/UCN-21679.doc)__, _*Readiness Applicability and Review Level Determination are used to complete the SNR.*

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## Standard Operations

- When a startup/restart does not require an RA or ORR then it is considered a startup/restart that uses the Y-12 standard startup process (i.e., standard operation checklist). Confirmation of the satisfactory attainment of operational readiness for standard operations is achieved by using _[UCN-21050](https://www-internal.y12.doe.gov/forms/UCN-21050.doc)__, Standard Operations Checklist. _
- The items on form _[UCN-21050](https://www-internal.y12.doe.gov/forms/UCN-21050.doc)__ should be evaluated for applicability early in the startup or restart. _
- Where a particular checklist item is not changed (e.g., the Safety Basis documents or Security Plan are not changed) as a result of the startup or restart, then that item would not be applicable to the particular startup or restart. If the item is not applicable to the startup or restart, then mark the "N/A" box and provide in the "BASIS" section the justification as to why the checklist item is not applicable. Justification for the exclusion of a checklist item requires written basis for excluding the item, and a discussion is required.
- If the item is applicable to the startup or restart, then mark the "YES" box and summarize in the "BASIS" section of that item the actions that must be completed prior to the startup or restart and the _documentation that will be provided_ to show that it has been completed.
- For more specific guidance, see Y15-190, Readiness Manual, _[Vol. 1, Chap. 3](https://www-internal.y12.doe.gov/acm/y12pro/Y15/y15-190/v1ch3.pdf)__. _

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## Refine Startup/Restart Scope

- Readiness Assurance Manager assigns a Readiness Leader
- Flesh out work scope
- Develop a resource loaded integrated schedule.
- All startups or restarts undergoing a readiness confirmation review need detailed schedules prepared early in the project that are approved by the responsible manager and, when assigned, the project manager. For the more complex projects, these schedules first appear in the initial Project Execution Plan (PEP) (see _[Y13‐007](https://www-internal.y12.doe.gov/acm/y12pro/Y13/y13-007.pdf)__) for approval by management. The project schedule must include the tasks required to attain full operational readiness as well as the tasks associated with the applicable readiness confirmation reviews. This is an expectation of the NNSA Y-12 Site Office. _

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## Readiness Process Diagram - 3

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## Develop Readiness Plan

- The Readiness Plan must identify the tasks required to support attaining operational readiness. This level of detail is typically covered in the project integrated schedule which is included as an attachment to the Readiness Plan.
- In its simplest form, the Readiness Plan is a combination of the scheduled tasks and the evidence requirements (closure criteria) for those tasks, the involved equipment, and people.
- For more specific guidance, see Y15-190, Readiness Manual, _[Vol. 1, Chap. 5](https://www-internal.y12.doe.gov/acm/y12pro/Y15/y15-190/v1ch5.pdf)__._

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## Scoping Meeting

- The Scoping Meeting is only required for startups or restarts where NNSA is the Startup/Restart Authority.   When held, the scoping meeting is conducted with representatives of the YSO.  The scoping meeting is to occur prior to the development of the final Plan of Action (POA), but it should only be held after the Readiness Plan is approved and provided to YSO.
- Joint Facility and system walk down
- Define bounds of Readiness Activities

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## Develop RA II / ORR Plan of Action

- The POA is a critical plan that defines the scope and prerequisites for the readiness confirmation review.
- The POA should describe how performance of the startup/restart will be demonstrated and clearly indicate where simulations and surrogate materials will be used.
- Identify Applicable Core Requirements
- Identify Prerequisites to attaining operational readiness
- Identify Personnel
- Identify Equipment Boundaries
- Identify Procedures
- Identify Review Team Leader
- Identify if a Startup Plan is Required

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## Develop Level I Plan of Action

- The POA is a critical plan that defines the scope and prerequisites for the readiness confirmation review. Description of the scope in the POA should be specific.
- The POA for a Level I RA must include the applicable evaluation criteria (the _[CRADs](https://home1.y12.doe.gov/ready/termlookup.php?term=Criteria%20and%20Review%20Approach%20Document)__) as describe in Y15-190, __[Vol. 1, Chap. 9](https://www-internal.y12.doe.gov/acm/y12pro/Y15/y15-190/v1ch9.pdf)__. The POA should describe how performance of the startup/restart will be demonstrated and clearly indicate where simulations and surrogate materials will be used. _
- Use UCN-21051 as review criteria
- Include CRADs from Vol. I Chapter 9
- Identify if a Startup Plan is Required

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## Achieving Operational Readiness

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## Readiness Assist Team

- Managing the process for achieving operational readiness involves executing the schedule, monitoring the progress of tasks needed to attain operational readiness, conducting practice evolutions, maintaining and reviewing evidence files, reviewing current corrective actions, and interviewing personnel to ensure they are aware of assignments and requirements.
- A key element for success in this process is the development of documentation and other deliverables that are of high quality. Ensuring that a high level of quality is achieved will support an efficient readiness confirmation process. To this end several projects have used the Readiness Assist Team (RAT) to start early (just before the time testing starts) to help the project team ensure that applicable requirements are met with adequate assurance of quality and that performance can be demonstrated without problems. In the RAT approach, problems or concerns are provided to the person responsible for the particular area. While these are tracked, they are not documented as formal findings, but rather the decision as to how or whether to address them is left to line management.
- Completion of this informal confirmation prepares operations and support organizations for the PSA or Level I RA.

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## Conduct of a Level I RA

- When the form UCN-21051, is complete and the evidence files are assembled, the Review Team conducts the assessment.
- The diagram below shows the typical steps to authorization to startup.

- Startup Plan ?

## Performance Self-Assessment

- Prior to the formal declaration of readiness for a Level II Readiness Assessment or Contractor ORR, an independent management assessment, called a Performance Self-Assessment (PSA) is conducted.
- The diagram below shows the typical steps declaring readiness.

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## Certification of Readiness

- A Certification of Readiness Letter (COR) is prepared by the Responsible Manager and signed by the Startup/Restart (a.k.a. Authorization) Authority, after the Performance Self-Assessment (PSA) is completed and the prerequisites in the Plan-of-Action (POA) have been fully met, to certify to the readiness confirmation review [Readiness Assessment (RA) or Operational Readiness Review (ORR)] team leader that the startup or restart has attained a fully operational state of readiness and the review may begin.
- Ensure closure criteria and prerequisites have been met, actions required for operation have been completed, and outstanding issues from the Prerequisite Confirmation Meeting (if held) have been resolved.
- Ensure that the PSA has been completed and any pre-start findings have been resolved and post-start actions are documented and plans approved and on schedule for closure.

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## Level II RA / ORR

- After completing the PSA and declaring readiness, BWXTY-12 will conduct a readiness review.
- If BWXTY-12 is the Startup Authority, the lower path is followed after the BWXT Y-12 review.
- If an ORR or NNSA RA is required, then the upper path is followed after the completion of the BWXT Y-12 RA or ORR.

- Startup Plan ?

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## Startup Authorization Letter

- This applies for startups or restarts where BWXT Y-12 has been designated as the Startup/Restart (a.k.a. Authorization) Authority on the SNR, the Startup Authorization Letter (SAL) is the formal communication from the Responsible Manager to the BWXT Y-12 Startup/Restart Authority that the facility has been brought to a state of operational readiness such that operations may safely and compliantly begin.
- Verify that pre-start findings from the Performance Self-Assessment (PSA) and Level II RA have been closed in Corrective Action Planning System (CAPS).
- Verify that post-start findings from the PSA and Level II RA have corrective actions established and are entered into CAPS.
- Ensure open post-start findings have approved action plans and are on schedule for closure.
- Develop the SAL providing the following information:
- Title of activity/task.
- Brief description of the reviews conducted.
- Summary of results from each review and current status (e.g., 3 pre-starts/closed, 4 post-starts/2 closed, etc.).
- Recommendation for startup and request for final approval statement.
- Forward the SAL through appropriate organizational channels to the Startup/restart Authority for review and approval.

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## Resumption Request Letter

- IF NNSA is the Startup/Restart Authority, The Resumption Request Letter (RRL) is the formal communication from BWXTY-12 to NNSA that the facility has been brought to a state of readiness to safely and compliantly start operations.
- Verify that pre-start findings from the Performance Self-Assessment (PSA), Contractor Review, and the NNSA Review (when applicable) have been closed in Corrective Action Planning System (CAPS) and verified by NNSA.
- Verify that post-start findings from the PSA, Contractor Review, and NNSA Review have approved corrective actions established and are entered into CAPS.
- Ensure open post-start findings are on schedule for closure.
- Develop the RRL providing the following information:
- Title of the startup or restart.
- Brief description of the reviews conducted.
- Summary of results from each review and current status (e.g., 3 pre-starts/closed, 4 post-starts/2 closed, etc.).
- Recommendation for startup and request for final approval statement.
- Forward the RRL for review and approval.

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## Readiness to Proceed Letter

- Where the startup or restart requires a NNSA review, the certification of readiness to begin the NNSA review takes the form of a Readiness to Proceed (RTP) Memorandum. The RTP is prepared by the Responsible Manager after the completion of the BWXT Y-12 readiness confirmation review (RA or ORR) and closure of any pre-start findings.  The RTP is signed by the General Manager or Deputy General Manager for Operations and is issued to the Y-12 Site Office (YSO) Manager, declaring that the startup or restart has attained a fully operational state of readiness and is ready for the NNSA review.

## Readiness To Proceed Letter (cont.)

- IF NNSA is the Startup/Restart Authority AND NNSA will be conducting a RA or ORR, THEN prepare the Readiness to Proceed letter and submit the letter to the Responsible Manager.
- The letter should be a formal declaration of readiness to start the NNSA review, indicating completion of the BWXT Y-12 review and summarizing the results.
- The letter should be submitted only when pre-start findings from the BWXT Y-12 review are complete and post-start items have an approved corrective action plan that is on schedule for closure.
- Ensure that evidence of closure of pre-start findings from the BWXT Y-12 review is made available to YSO for their review and verification.
- Any open pre-start items should be discussed in the letter indicating why it is acceptable to start the review with these items open.
- The letter should include as attachments, the BWXT Y-12 review report and when applicable the manageable list of open items.
- Items listed on the Manageable List of Open Items for a NNSA RA or ORR must be scheduled for resolution during the NNSA review so that the NNSA review team has time to review the closure of the items.
- IF NNSA will be conducting a RA or ORR AND the Authorization Agreement for the Facility in which the startup or restart is occurring requires revision to authorize the proposed activity, THEN submit the revised Authorization Agreement (signed by BWXT Y-12) with the RTP for approval by NNSA upon completion of the NNSA RA/ORR.

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## NNSA RA / ORR

- Where the startup or restart requires a NNSA review, the certification of readiness to begin the NNSA review takes the form of a Readiness to Proceed (RTP) Memorandum. The RTP is prepared by the Responsible Manager after the completion of the BWXT Y-12 readiness confirmation review (RA or ORR) and closure of any pre-start findings.  The RTP is signed by the General Manager or Deputy General Manager for Operations and is issued to the Y-12 Site Office (YSO) Manager, declaring that the startup or restart has attained a fully operational state of readiness and is ready for the NNSA review.

- Startup Plan ?

## Startup Plan

- The Startup Plan (when used) defines the systematic process and controls that will guide operations immediately after the authorization to operate is received and support a smooth, deliberate, and controlled transition into unrestricted routine operations.  The period of operations covered by the Startup Plan is often referred to as “first use.”
- The Startup Plan must address any actions or functions that cannot be demonstrated during the reviews.  This may include first-use, phase-in, proficiency, process safety, and product or software quality.
- In general, any actions or functions that can not be performed until after startup authorization is received (e.g., testing with hazardous materials, performing control manipulations, finalizing procedures where actual run data is needed, etc. should be addressed in the Startup Plan. Additional guidance and templates are available on the Readiness Assurance (RA) web site, _[https://home1.y12.doe.gov/ready/](https://home1.y12.doe.gov/ready/)__. _

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## Startup Authorization

- When the Startup/Restart Authority approves the RRL (NNSA) or SAL (BWXTY-12), the following are the steps to release the startup or restart for routine operations.
- When the Startup/Restart Authority has approved the startup or restart, then review the authorization for any special conditions.
- Start operations in accordance with Startup Plan (when applicable) and in compliance with special conditions, as applicable.
- Monitor the startup or restart to ensure operations are conducted within requirements.
- Document the results of the execution of the Startup Plan and any special conditions, as applicable.
- Develop any applicable lessons learned in accordance with Y15-331, *Lessons Learned Program*.

## Resources

- The Y-12 Readiness Assurance Web Site [https://home1.y12.doe.gov/ready/] has a wide range of resources to aid in the implementation of Readiness Program requirements.
- Detailed guidance on planning for attaining operational readiness and reviews to confirm that it has been attained.
- Project tools such as samples and templates, links to forms, searchable glossary, frequently asked questions, etc.
- Searchable Real-time Startup Notification Report.
- Table showing the status of active and completed startups and restarts.
- Metrics, announcements, training materials, contacts, etc.

- The End?