Operational Readiness Review

1
Readiness ReviewCourse
Implementation Plan - Mod 8
2
Learning Objectives

• Describe the purpose, timing, and content of an
  Implementation Plan
• Describe how an Implementation Plan is developed
  and modified
• Describe who reviews and approves the
  Implementation Plan

3
Readiness Review Process
6 Months Prior to RR
1 Year Prior to RR
3 Months Prior to RR
4
Implementation Plan (IP)

• Drafted by Team Leader
• Developed by the Team
• Approved by the Team Leader
• Provides the depth - derived from the POA
  (Breadth)

5
Implementation Plan (IP)

• The IP documents
• The process the team uses to conduct the review
  and the rational for that process
• Includes the selection of criteria and review
  approaches to be used
• The procedures the team uses to develop findings
  and conclusions
• The criteria used in finding categorization
  (pre/post-start)
• Provided to DOE/NNSA/EH for comment.

6
Implementation Plan vs Plan of Action
Defining the Scope of the ORR
Plan of Action Defines ORR Breadth
ORR Scope
ORR Implementation Plan Defines Depth
7
7
Implementation Plan Contents

• Introduction/Background
• Purpose
• Scope
• ORR Prerequisites
• Overall Approach
• ORR Preparations
• ORR Process - Criteria and Review Approaches
  Document (CRADs) used for the review
• Administration
• Reporting and Resolutions
• Schedule and
• Appendices.

DOE-STD-3006-2000 Details
4
8
Implementation Plan Developed

• Using the BREADTH and SCOPE - POA
• minimum core requirements to be addressed
• physical boundaries of the readiness review
• administrative boundaries of the readiness review
• By Subject Matter Experts - Team Members
• Using the GRADED APPROACH defined in the POA
• Using the Site-Specific Requirements

9
IP Development Using the POA Breadth(MCRs to be
Reviewed)
MCR 1 - Line management has established programs
to ensure safe accomplishment of work. Personnel
exhibit an awareness of public and worker safety,
health, and environmental protection requirements
and, through their actions, demonstrate a
high-priority commitment to comply with these
requirements.

• The NNSA ORR Team will confirm that ESA-TSE line
  management has established the following
  programs, and personnel can demonstrate a
  commitment to comply with programmatic
  requirements. The review will focus on
  contractual agreements between NNSA and LANL, and
  the implementation of site-specific documentation
  to verify that this MCR has been met.
• Conduct of Operations
• Configuration Management
• Emergency Management
• Environmental Compliance
• Fire Protection
• Maintenance Management

POA Depth EXAMPLE
10
Team Members Identified Using the Breadth of the
POA
MCR 1 - Line management

• The NNSA ORR Team will confirm
• Conduct of Operations SME
• Configuration Management SME
• Emergency Management SME
• Environmental Compliance SME
• Fire Protection SME
• Maintenance Management SME

11
Team Member Identification By Core Requirement
Objective 1
Core Requirement - 1
Objective 2
Objective 3
Functional Area
SME
Objective 1
Core Requirement - 2
Objective 2
11
12
Team Member Identification By Core Requirement -
Example
MCR 7 Safety Systems and systems essential to
worker and public safety are defined
Authorization Basis SME
Safety Basis Objectives
MCR 10 There are adequate and correct ..
Safety limits
12
13
Team Member Selection, Typical Functional Areas

• Engineering Support
• Fire Protection
• Occupational Safety (IH/IS)
• Management
• Configuration Management
• Procedures
• Radiation Protection
• Procedures
• Level of Knowledge

• Operations
• Safety Envelope
• DOE Organization
• Training and Qualification
• Quality Assurance
• Software Quality Assurance
• Criticality Safety
• Environmental Protection and Waste Management

13
14
IP Development using the Graded Approachfrom POA

• Physical modifications to the facility
• Procedural changes
• Personnel changes
• Length of shutdown
• Overall hazard characteristics of the facility
• The complexity of the activity
• A new process or facility versus the restart of
  an existing activity
• The programmatic significance of the subsequent
  operations
• Introduction of new hazards
• Increase in existing hazards or risk
• Operating history of the facility
• Confidence in site-wide issues
• Issues raised through other internal or external
  reviews
• Lessons Learned

15
Graded Approach Example Consideration for New
Starts . .

• Verification without significant reference
  points
• Training and qualification of workers
• New procedures
• New Equipment.
• May drive the ORR to be more thorough and
  comprehensive than for review of a process that
  has significant on-site experience.
• Maturity of Site Infrastructure and results of
  previous reviews (Safety Management Programs).

16
The Graded Approach Example Considerations for
Restarts

• Physical Modifications to the facility . . .
• Changes to the Authorization Basis . . .
• Procedural changes . . .
• Personnel and Management changes . . .
• Length of shutdown . . . .
• Overall hazard characteristics of the facility .
  . .
• Increase in hazards or risk . . .
• Training / expertise issues . . .

17
17
IP Development Using Requirements

• Contractual Requirements (List A/B, S/RIDs, WSS)!
• DOE Codes, Orders, Standards, or Regulations
• Industry Standards, or Regulations (i.e, IEEE,
  ANSI, ASME)
• Site Specific Requirements

18
Requirements are used to

• Define controls such as
• Engineered Controls - Structures, Systems,
  Components (SSC)
• Administrative Controls - Policies, procedures,
  programs, and documentation
• Personnel Protective Equipment (rad protection
  clothing, hard hats, respirators, glasses, etc.)

18
19
Example of Regulatory Requirements used in
Controlling Hazards

• Essential hardware systems are defined -
  Engineered Controls
• Containing Geometry - ANS 8.1
• Effluent Recovery System - 420.1
• Fire Suppression System - 420.1
• Confinement Ventilation - DSA
• Mechanical Guarding - 29 CFR 1910

21
20
Example of Regulatory Requirements used in
Controlling Hazards

• Essential programs are defined - Administrative
  Controls (SMP) CFR 830.204
• Training - 5480.20, 29CFR 1910.147
• Operations - 5480.19
• Emergency Response - 151.1
• Configuration Control - 5480.19
• Inspection/Surveillance/Maintenance - 431.1,
  5480.19, CFR 830.120

22
21
Criteria and Review Approach Document (CRAD)

• Derived from the Performance Objectives defined
  by the MCR.
• CRAD includes the
• Objectives - high level review topic from Core
  Requirement
• Criteria - elements of the Objective, including
  references
• Review Approach - documents, interviews, and
  observations.

10
22
Developing the CRADs for the IP
23
The Implementation Plan

• Implementation Plan (IP) approved by the Team
  Leader, with Team Member inputs.
• The Team Leader will provide (not for approval)
  the ORR Implementation Plan to
• EH for review and comment for all startups and
  restarts
• To the Authorization Authority
• To Appropriate PSO as Required.
• Do not commit in the Implementation Plan to more
  than the ORR/RA schedule can support!
• Match the POAs scope . . .

8
24
Structuring the Implementation Plan

• Establish technical areas of importance . . .
• Allocate areas into Functional Areas (FAs) . . .
• Identify personnel with needed competencies to
  address each Functional Area . . .
• Subdivide Core Requirements into selected
  Functional Areas . . . .
• Develop CRADs

Example IP
9
25
Readiness ReviewCourse
Implementation Plan - Mod 8
26
Learning Objectives

• Describe the purpose, timing, and content of an
  Implementation Plan
• Describe how an Implementation Plan is developed
  and modified
• Describe who reviews and approves the
  Implementation Plan

27
Readiness Review Process
6 Months Prior to RR
1 Year Prior to RR
3 Months Prior to RR
28
Implementation Plan (IP)

• Drafted by Team Leader
• Developed by the Team
• Approved by the Team Leader
• Provides the depth - derived from the POA
  (Breadth)

29
Implementation Plan (IP)

• The IP documents
• The process the team uses to conduct the review
  and the rational for that process
• Includes the selection of criteria and review
  approaches to be used
• The procedures the team uses to develop findings
  and conclusions
• The criteria used in finding categorization
  (pre/post-start)
• Provided to DOE/NNSA/EH for comment.

30
Implementation Plan vs Plan of Action
Defining the Scope of the ORR
Plan of Action Defines ORR Breadth
ORR Scope
ORR Implementation Plan Defines Depth
7
31
Implementation Plan Contents

• Introduction/Background
• Purpose
• Scope
• ORR Prerequisites
• Overall Approach
• ORR Preparations
• ORR Process - Criteria and Review Approaches
  Document (CRADs) used for the review
• Administration
• Reporting and Resolutions
• Schedule and
• Appendices.

DOE-STD-3006-2000 Details
4
32
Implementation Plan Developed

• Using the BREADTH and SCOPE - POA
• minimum core requirements to be addressed
• physical boundaries of the readiness review
• administrative boundaries of the readiness review
• By Subject Matter Experts - Team Members
• Using the GRADED APPROACH defined in the POA
• Using the Site-Specific Requirements

33
IP Development Using the POA Breadth(MCRs to be
Reviewed)
MCR 1 - Line management has established programs
to ensure safe accomplishment of work. Personnel
exhibit an awareness of public and worker safety,
health, and environmental protection requirements
and, through their actions, demonstrate a
high-priority commitment to comply with these
requirements.

• The NNSA ORR Team will confirm that ESA-TSE line
  management has established the following
  programs, and personnel can demonstrate a
  commitment to comply with programmatic
  requirements. The review will focus on
  contractual agreements between NNSA and LANL, and
  the implementation of site-specific documentation
  to verify that this MCR has been met.
• Conduct of Operations
• Configuration Management
• Emergency Management
• Environmental Compliance
• Fire Protection
• Maintenance Management

34
Team Members Identified Using the Breadth of the
POA
MCR 1 - Line management

• The NNSA ORR Team will confirm
• Conduct of Operations SME
• Configuration Management SME
• Emergency Management SME
• Environmental Compliance SME
• Fire Protection SME
• Maintenance Management SME

35
Team Member Identification By Core Requirement
Objective 1
Core Requirement - 1
Objective 2
Objective 3
Functional Area
SME
Objective 1
Core Requirement - 2
Objective 2
11
36
Team Member Identification By Core Requirement -
Example
MCR 7 Safety Systems and systems essential to
worker and public safety are defined
Authorization Basis SME
Safety Basis Objectives
MCR 10 There are adequate and correct ..
Safety limits
12
37
Team Member Selection, Typical Functional Areas

• Engineering Support
• Fire Protection
• Occupational Safety (IH/IS)
• Management
• Configuration Management
• Procedures
• Radiation Protection
• Procedures
• Level of Knowledge

• Operations
• Safety Envelope
• DOE Organization
• Training and Qualification
• Quality Assurance
• Software Quality Assurance
• Criticality Safety
• Environmental Protection and Waste Management

13
38
IP Development using the Graded Approachfrom POA

• Physical modifications to the facility
• Procedural changes
• Personnel changes
• Length of shutdown
• Overall hazard characteristics of the facility
• The complexity of the activity
• A new process or facility versus the restart of
  an existing activity
• The programmatic significance of the subsequent
  operations
• Introduction of new hazards
• Increase in existing hazards or risk
• Operating history of the facility
• Confidence in site-wide issues
• Issues raised through other internal or external
  reviews
• Lessons Learned

39
Graded Approach Example Consideration for New
Starts . .

• Verification without significant reference
  points
• Training and qualification of workers
• New procedures
• New Equipment.
• May drive the ORR to be more thorough and
  comprehensive than for review of a process that
  has significant on-site experience.
• Maturity of Site Infrastructure and results of
  previous reviews (Safety Management Programs).

40
The Graded Approach Example Considerations for
Restarts

• Physical Modifications to the facility . . .
• Changes to the Authorization Basis . . .
• Procedural changes . . .
• Personnel and Management changes . . .
• Length of shutdown . . . .
• Overall hazard characteristics of the facility .
  . .
• Increase in hazards or risk . . .
• Training / expertise issues . . .

17
41
IP Development Using Requirements

• Contractual Requirements (List A/B, S/RIDs, WSS)!
• DOE Codes, Orders, Standards, or Regulations
• Industry Standards, or Regulations (i.e, IEEE,
  ANSI, ASME)
• Site Specific Requirements

42
Requirements are used to

• Define controls such as
• Engineered Controls - Structures, Systems,
  Components (SSC)
• Administrative Controls - Policies, procedures,
  programs, and documentation
• Personnel Protective Equipment (rad protection
  clothing, hard hats, respirators, glasses, etc.)

18
43
Example of Regulatory Requirements used in
Controlling Hazards

• Essential hardware systems are defined -
  Engineered Controls
• Containing Geometry - ANS 8.1
• Effluent Recovery System - 420.1
• Fire Suppression System - 420.1
• Confinement Ventilation - DSA
• Mechanical Guarding - 29 CFR 1910

21
44
Example of Regulatory Requirements used in
Controlling Hazards

• Essential programs are defined - Administrative
  Controls (SMP) CFR 830.204
• Training - 5480.20, 29CFR 1910.147
• Operations - 5480.19
• Emergency Response - 151.1
• Configuration Control - 5480.19
• Inspection/Surveillance/Maintenance - 431.1,
  5480.19, CFR 830.120

22
45
Criteria and Review Approach Document (CRAD)

• Derived from the Performance Objectives defined
  by the MCR.
• CRAD includes the
• Objectives - high level review topic from Core
  Requirement
• Criteria - elements of the Objective, including
  references
• Review Approach - documents, interviews, and
  observations.

10
46
Developing the CRADs for the IP
47
The Implementation Plan

• Implementation Plan (IP) approved by the Team
  Leader, with Team Member inputs.
• The Team Leader will provide (not for approval)
  the ORR Implementation Plan to
• EH for review and comment for all startups and
  restarts
• To the Authorization Authority
• To Appropriate PSO as Required.
• Do not commit in the Implementation Plan to more
  than the ORR/RA schedule can support!
• Match the POAs scope . . .

8
48
Structuring the Implementation Plan

• Establish technical areas of importance . . .
• Allocate areas into Functional Areas (FAs) . . .
• Identify personnel with needed competencies to
  address each Functional Area . . .
• Subdivide Core Requirements into selected
  Functional Areas . . . .
• Develop CRADs

Example IP
9