# Presentation: 069678

## LESSONS LEARNED IN ACCELERATING CLOSURE

- A  Facility Representative Perspective Based On Rocky Flats Experience

## OVERVIEW

- What is Accelerated Closure
- Differences in Facility Operations
- Differences in Safety Basis Controls
- Observations on Work Control Documents
- Facility Representative Oversight
- Facility Representative Challenges
- Influencing Contractor Performance

## What is Accelerated Closure

- Increased pace of work
- More work being performed simultaneously
- More workers in the facility, with little or no ISMS experience as practiced by DOE
- More work control documents to review
- More pre- evolution briefings to monitor
- Usually no change in Facility Representative staffing to support increased pace of work

## Facility Operations

- _Pre-Closure_
- Operations are limited to landlord and mission activities governed by procedures
- Operations conducted using well developed and detailed procedures
- Operations are routine and predictable

## Differences in Facility Operations

- _Accelerated closure_
- Closure activities are conducted in parallel with landlord activities
- Contractor management must learn to coordinate multiple activities
- Work control documents, not procedures, control work
- Typically, work control documents not as detailed as operating procedures
- Many activities are performed for the first time, and often for one time only
- Legal agreements and commitments affect work priorities
- Division of work between facility “union” workers and “building trades” union workers

## Safety Basis Controls

- _Pre-Closure_
- Safety Basis documents emphasize safety related equipment
- Specific equipment and structures are identified as Safety Class or Safety Significant Systems Structures and Components (SSC)
- Specific systems and equipment performance parameters are specified in Technical Safety Requirements (TSRs)
- Specific equipment line-ups and performance parameters are documented during surveillance procedures
- The Safety Basis documents do not define conditions required for removing SSC
- Approved facility operations bear little similarity with D&D activities

## Differences in Safety Basis Controls

- _Accelerated Closure_
- Approved activities are controlled by Safety Basis documents that emphasize monitoring and documenting specific safety related functions
- Administrative Controls (ACs) related to Safety Management Programs (SMPs) are increasingly relied upon as the basis for operation during D&D.  This is the fundamental shift in the Safety Basis
- Contractor work force performance impacts AC compliance evaluation especially where continued procedure non-compliance is observed
- DOE and the Contractor may have different opinions of SMP and AC compliance

## Observations on Work Control Documents (WCDs)

- WCDs must contain appropriate level of planning and detail
- Achieving an appropriate level of planning and detail should be the focus of DOE and the Contractor
- WCDs must be prepared in a manner that provides clear prerequisites and work activity performance steps
- The WCD process should identify a single person responsible for the work (e.g., Responsible Manager)
- The WCD process should provide the flexibility, and authority, to make changes as work is in progress
- The WCD change process must have controls to prevent abusing the flexibility provided by the process
- The WCD process should provide a mechanism for documenting changes, and decisions, made during work performance
- New technologies and applications must be approved outside the WCD process

## Facility Representative Oversight

- _Pre-Closure_
- Many Sites have a regimented FR oversight process with pre-planned, pre-approved surveillances that are strictly scheduled
- The FR prepares and performs the surveillance, providing a formal written assessment report of observations
- This process works well for operating facilities
- This process may not align well with the dynamic nature of D&D due to multiple and different D&D activities

## Facility Representative Oversight

- _Accelerated Closure_
- Challenge to DOE management is to recognize that not all activities can be monitored
- The Facility Representative (FR) role in observing work must be understood by the Contractor
- FR must be well versed in facility Safety Basis documents
- Secondary emphasis for FR knowledge should be in radiological controls, work control, conduct of operations, occupational health and safety requirements, and waste acceptance criteria
- FR must be familiar with Contractor procedures, specifically those that implement ISMS and other safety requirements (e.g., nuclear, criticality, radiological safety)
- FR actions can send a positive message that DOE is committed to safety

## Facility Representative Oversight

- _Accelerated Closure_
- Until proven otherwise, FR should assume that Contractor management and their staff, including their workers, are:
- Smart
- Competent and capable
- Motivated
- Capable
- Honestly trying to perform work safely

## FR CHALLENGES

- Establishing and fostering a working relationship with the Contractor that facilitates performance improvement
- Monitoring more than one activity at a time
- Developing expertise in work control document use
- Improving knowledge of OSHA requirements
- Recognizing Contractor staff demonstrating weak performance that may require additional oversight
- Recognizing opportunities to encourage Contractor staff performance improvements
- Evaluating Contractor response to reported performance deficiencies to determine if higher levels of DOE management involvement is needed

## INFLUENCING CONTRACTOR PERFORMANCE

- Prompted assignment of a Contractor Field Engineer monitoring performance at the work area
- Influenced changing Pre-Evolution Brief (PEB) format from a conventional operations format to align the format with ISMS principles
- Improved use of the WCD status log to document changes and decisions made during work performance
- Prompted removal of WCD requirements that added no value
- Improved response to unusual/unexpected conditions encountered during work
- Improved compliance with performing and documenting inspections of safety related equipment
- Provided helpful liaison DNFSB, outside auditors, & RFFO/HQ staffs
- Provided observations of supervisor proficiency prompting management evaluation and mentoring to improve performance
- Contributed useful insight during planning evolutions and fact finding critiques