JP, KING

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HNF-35953-FPRevision 0Implementing Changes toan Approved and In-UseDocumented SafetyAnalysisPrepared for the U.S. Department of EnergyAssistant Secretary for Environmental ManagementProject Hanford Management Contractor for theU.S. Department of Energy under Contract DE-ACOS-9SRL13200FLUOR"P.O. Box 1000Richland, WashingtonApproved for Public Release;Further Dissemination UnlimitedHNF-35953-FPRevision 0Implementing Changes to anApproved and In-Use DocumentedSafety AnalysisJ. P. KingFluor Hanford, Inc.Date PublishedApril 2008To Be Presented atEnergy FacUlty Contractors Operating GroupEFCOG 200B Safely Analysis WorkshopRichland. WAMay 6 - B, 200BPublished inSafely Analysis Working GroupPrepared for the U.S. Department of EnergyAssistant Secretary for Environmental ManagementProject Hanford Management Contractor for theU.S. Department of Energy under Contract DE-AC06-96RL13200FLUOR..P.O. Box 1000Richland, WashingtonCopyright licenseBy acceptance of this article, the publisher and/or recipient acknowledges the U.S. Government's right to retain anonexclusive, royalty-free license in and to any copyright covering this paper.I ft. dad..LetReJease ApprovalApproved for Public Release:FurtherDissemination Unlimited'LEGAL DISCLAIMERThis report was prepared as an account of work sponsored byan agency of the United States Government. Neither the UnitedStates Government nor any agency thereof, nor any of theiremployees, nor any of their contractors. subcontractors or theiremployees, makes any warranty, express or implied, orassumes any legal liability or responsibility for the accuracy,completeness, or any third party's use or the results of such useof any Infannalion, apparatus, product, or process disclosed, orrepresents that its use would not infringe privately owned rights.Reference herein to any specific commercial product, process,or service by trade name, trademark, manufacturer, orotherwise, does not necessarily constitute or imply itsendorsement, recommendation, or favoring by the UnitedStates Government or any agency thereof or its contractors orsubcontractors. The views and opinions of authors expressedherein do not necessarily state or reflect those of the UnitedStates Government or any agency thereof.This document is available to the U.S. Department of Energyand its contractors, in paper from the Office of Scientific andTechnical Information (OSTI). It is available for sale to thepublic from the National Technical Information Service (NTIS).This report has been reproduced from the best available copy.Available in paper copy.PrInted in the United States of AmericaHNF-35953-FPRevision 0Implementing Changes to an In-UseDocumented Safety AnalysisJeffry P (Jeff) KingFluor Hanford Nuclear and Criticality SafetyPlutonium Finishing PlantMSINT5-54P. O. Box 1000, Richland WA, 99352 Phone (509) 373-5194/ FAX (509) 373-2752Jeffry P Jeff King@rl.govAbstractThe Plutonium Finishing Plant (PFP) has refined a process to ensure a comprehensive andcomplete DSAlTSR change implementation. Successful Nuclear Facility Safety Basisimplementation is essential to avoid creating a Potential Inadequacy in Safety Analysis (PISA)situation, or implementing a facility into a non-compliance that can result in a TSR violation.Once past initial implementation, additional changes to Documented Safety Analysis (DSA)and Technical Safety Requirements (TSRs) are often needed due to needed requirementclarifications, operating experience indicating that ConditionslRequired Actions/SurveillanceRequirements could be improved, changes in facility conditions, or changes in facility missionetc. An effective change implementation process is essential to ensuring compliance with 10CFR 830.202(a), "The contractor responsible for a hazard category 1,2, or 3 DOE nuclearfacility must establish and maintain the safety basis for the facility."Effectively Implementing ChangeThe PFP has developed a checklist driven process that is used to implement DSAlTSR change.The process ensures that a complete package documenting readiness to implement is brought tothe Plant Review Committee for concurrence with readiness to implement actions before thechanges are implemented in the field.BackgroundIn 1994, the PFP was the first nuclear facility on the Hanford site to implement a DOE-Order5480.22 compliant TSR document. A detailed readiness assessment-like process was used totransition the facility from the pre-I 994 Operational Safety Requirements and into the 5480.22compliant TSRs. The transition document provided a comprehensive and valuable "snapshot intime" demonstrating implementation ofand compliance with the new TSRs. However, theprocess for maintaining TSR compliance documentation and implementation of future SafetyBasis change was not well defined. From 1994 to 2004, three major PFP Final Safety AnalysisReport revisions and thirty-five TSR revisions were implemented using a process that wasgenerally documented on a single page checklist completed by a single person. This unrefinedSafety Basis change process resulted in numerous oversight and self identified Findings relatedto requirement changes not being incorporated, or being inadequately/improperly incorporated,into field-level compliance procedures. The unrefined process ultimately resulted in at leastone TSR violation.Implementation Process ImprovementIn response to the recognized change implementation short comings, Fluor Hanford establishedthe hnplementation Validation Review (IVR) process and issued a site wide procedure titled"Safety Basis Implementation and Maintenance." The primary objectives of the IVR processare to:• Verify that the DSAlTSR controls and requirements are incorporated into facilitydocuments and work instructions;• Verify that facility personnel are knowledgeable of DSAlTSR controls andrequirements; and• Verify that DSAlTSR controls will be adequately implemented.Essential elements of the Safety Basis hnplementation and Maintenance includeimplementation plans, NR checklists, and compliance matrices.Implementation Plans and IVR ChecklistsThe safety basis implementation plan provides a process to ensure the plant hardware,management systems, and personnel are ready to implement the requirements of the safetybasis. It also includes the means to validate the implementation of the safety basis change priorto its implementation/transition date. The plan helps to ensure the appropriate safety basissupporting documents have been reviewed against the safety basis and all required changes tothese documents have been completed and are ready to issue. The IVR checklist provides fordocumentation of the reviews that were performed to determine readiness to implement thesafety basis.Compliance MatricesThe safety basis compliance matrix tracks commitments from the facility DSAlTSR and theDOE-issued Safety Evaluation Report to their implementing procedures and processes. Thecompliance matrix serves as a convenient document during facility performance assessmentactivities and performance ofunreviewed safety question determinations.The compliance matrix or matrices may be maintained as spread sheets, databases, or wordprocessor tables. All of these formats are workable. To be ofreal value, the compliance matrixor matrices must be sufficiently detailed and maintained up-to-date. The compliance matrix isthe starting point in identifying documents affected by safety basis changes. The compliancematrix oftentimes becomes the only comprehensive record ofdisposition of Safety EvaluationReport Conditions of Approval (COA's) and/or technical direction.PFP's Integrated Safety Basis Change Implementation PlanlIVR Checklist ProcessPFP has chosen to integrate the safety basis change implementation plan, and the IVR checklistinto a single safety basis change process and document that satisfies the requirements ofthesite Safety Basis Implementation and Maintenance procedure.Essential Elements to Successful Change ImplementationApproximately three years ofrefining the safety basis change implementation process hasresulted in identification of a number of elements that are essential to successful changeimplementation. These elements are:~ Application of graded approach to the complexity of the implementation plan.Fluor's Safety Basis Implementation and Maintenance procedure defines three levels ofsafety basis change.• Major Changes. Multiple changes, physical alterations of credited components, changesin methods used to demonstrate operability of TSR controls. Major changes couldpotentially affect the ability to comply with the safety basis or involve theimplementation ofa new safety basis.A major change would typically involve a management readiness assessment likereview. The scope and contents of an implementation plan/IVR for a major change isreviewed and approved by the Plant Review Committee.• Moderate Changes. One or more complex changes or numerous changes to creditedcontrols or control parameters involving safety class or safety significant items or TSRoperating limits or administrative controls.A moderate change typically requires at lease two individuals, one ofwhich should befrom an independent oversight organization (e.g., Quality Assurance). The scope andcontents of an implementation plan/IVR for a moderate change are also reviewed andapproved by the Plant Review Committee.• Minor Changes. One or more simple changes to a credited control or control parameterinvolving safety class or safety significant items or TSR operating limits oradministrative controls. This also includes the deletion of credited controls (e.g., as aresult of deactivation or decommissioning activities).A minor change implementation is typically limited to review by two individualsassigned by the project. The scope and contents of an implementation plan/IVR for aminor change is approved by the facility Operations Director or delegate.» Management ownership ofthe implementation process.The facility manager is responsible for maintaining the safety basis. The facility manager ordelegate:• Concurs with the assigned change level (i.e., Major, Moderate, Minor).• Concurs with the scope ofand level ofdetail in the implementation planiNR. Thisconcurrence is delegated for minor changes.• Assigns the individuals responsible for completing the implementation planINR.• Assigns work priorities to organizations that have actions to complete within theimplementation plan.» Early planning of scope/detail based on safety basis change level assignment.Allow sufficient time to complete implementation actions. Completion of some actions,such as training or equipment modifications, may take longer than originally anticipateddue to availability ofpersonnel (shift work, vacations, etc.).• For major changes, implementation plan development should start concurrently withfacility approval of the safety basis and no later than upon submittal of the changepackage to DOE for approval.• For moderate changes, implementation plan development should start no later thanresolution ofany DOE review comments and drafting of the Safety Evaluation Report.• For minor changes, implementation plan development typically starts upon receipt fromDOE of the change approving SER.Reviews, Document Changes, and Other Actions to Include in the Implementation PlanPFP's implementation plan process has identified numerous categories of reviews, documentchanges, and other actions such as training and work planning that must be considered. Theseinclude:• Active Justifications for Continued Operation and open Unreviewed Safety QuestionDeterminations, Unreviewed Safety Question process categorical exclusions (CX's).• Criticality Safety and Fire Hazard Analyses documents.• Safety Basis compliance matrix or matrices.• Operational aids such as status boards, shift orders, other operator aids, recovery plans.• Engineering documents such as drawings, system description documents, operatingspecification documents, safety equipment list.• Work planning items such as job hazard analyses, work packages with affecteddocuments within or that involve affected equipment.• Emergency preparedness documents such as the emergency preparedness hazardsassessment, building emergency plans, and other emergency response procedures.• Administrative and technical procedures.• Training to the safety basis change(s). This category includes a training needs analysisto determine the scope/delivery of the training and the required audience, developmentofthe training package, delivery and documentation ofthe training, and evaluation ofany affected existing training packages (e.g., operator or engineertraining/qualification/certification modules) that require modification.• Consulting with involved management and organizational groups to identify any "gaps"in the implementation plan, such as additional documents that might not have beenidentified for change.• Post implementation punch lists and action tracking system entries for items that willnot be completed before declaration of readiness for change implementation.• Log book entries to notifY responsible personnel when the implementation process isentered, and then again when implementation readiness is declared and implementationeffective date.• Assembling an "evidence book" of completed actions. This book is actually a three ringbinder containing copies of all completed documented changes, implementation planreview comments, e-mails to others documenting requests to complete actions, repliesdocumenting completed actions, log book entries, completed training actions, etc.• Obtaining concurrence from the Plant Review Committee on readiness to implement.• Coordinating roll-out of the revised safety basis and affected documents. Some tasksmay need to include a "time out" or be deferred while obsolete procedures are removedfrom the field or work package and replaced with ones updated to reflect the revisedsafety basis.• Verification that, after readiness declaration, all affected document changes are issuedin a timely manner.Disposition of a Completed Implementation PlanThe completed implementation plan is issued as a controlled engineering document for recordsretention purposes. Record copies ofthe documents that were changed as part ofimplementation are retained as required by the site records management system. However, thepopulated "evidence book" and a hard copy ofthe completed implementation plan are retainedin plant for easy future reference. These retained copies are especially useful when a safetybasis change such as a Justification for Continued Operation must be closed out or"unimplemented".Benefits from Using the Refined Safety Basis Change Implementation ProcessAs a direct result ofusing the refined safety basis change implementation plan/IVR process,thePFPhas:I. Reduced the number of oversight findings of documents not being current with theapproved safety basis.2. Reduced the number of work packages and work procedures rendered unworkable dueto safety basis changes not being incorporated into them.3. Improved safety basis change training delivery process. Target audiences requiringtraining are identified through an analysis of training needs that are specific to changepackages.4. Improved the accuracy ofcontinuing training packages by ensuring that they arereviewed and revised to reflect safety basis changes.5. Reduced the potential for safety basis change induced PISA's and TSR violations.

IMPLEMENTING CHANGES TO AN APPROVED AND IN-USE DOCUMENTED SAFETY ANALYSIS

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IMPLEMENTING CHANGES TO AN APPROVED AND IN-USE DOCUMENTED SAFETY ANALYSIS

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