Conduct of the Review May 2005 Revision 6T6L

Upon successful completion of this topic, the student should be able to: Describe the Functional Area concept including: Team Member responsibility Finding issues vice solutions Performance IAW Requirements concept ORR/RA scope Basic report administration Requirements determination and considerations Programs understanding Personnel aspects Equipment aspects Findings- categorization 6T6L May 2005 Revision

Team Member Tasks Assist in preparation of Implementation Plan: Develop acceptance criteria / performance objectives; Develop lines of inquiry for each review objective; Complete individual team member readiness preparations. Conduct Review: Reviewing documents, procedures, drawings; Compile support documentation; Provide compliance review; Execute ORR as defined in Implementation Plan; Develop issues and findings Assist, as needed, to Complete the Review and Final Report. 6T6L May 2005 Revision

Team Member Tasks (continued) Work with other ORR/RA members: to resolve and communicate issues; to prepare the review documentation and report; to eliminate redundant reviews. Submit completed review documents for review and approval. Concur with determination of operational readiness and conclusions of ORR/RA report (in their area of assessment). 6T6L May 2005 Revision

An Effective ORR/RA Schedule driven; Requires Effective Coordination Avoid duplication of: Interviews, procedure reviews; Drills, exercise observations . . . Know time line of the review Schedule driven; Defined sequences; Stay on point, avoid distractions; Preparation of report forms critical and critical path . . . 6T6L May 2005 Revision

Team Communications Team evaluators must stay within their scope of review. However, team leader should be made aware of problems that may have broader impact *: Don't assume other review teams are aware of problems; Don't assume informal one-on-one discussions adequately relay the problem. Bring to attention of team leadership. i.e., generic problems that may affect other areas . . . An effective Team maintains effective communications! 6T6L May 2005 Revision

Expanding the Review The review criteria may define parameters by which the review may be expanded. For example: Initially, the review may specify interviews with ten randomly selected operators. A deficiency of one more operators may result in expanding the review approach to 25 operators. Or, The review may specify a walk-down of the most crucial safety systems. At a pre-determined number of deficiencies, the review may be expanded to the entire configuration control system. 6T6L May 2005 Revision

Pulling the String A team member determines that personnel are not familiar with an important procedure… There is a problem with: the procedure? training / identification of those needing training? supervision? 6T6L May 2005 Revision

Sustainable Infrastructure is Implemented and “in place”! One View of Readiness Sustainable Infrastructure is Implemented and “in place”! 6T6L May 2005 Revision

Important Inter-relationships 6T6L May 2005 Revision

Documenting Review Methods Assessment Form (Form 1) Use a Form 1 to document methods and actions taken by team members in evaluation process . . . Each Form 1: Covers specific objective; Documents team members review methodology and results; Enough detail to allow a reviewer of form to follow evaluation logic; Follows approach detailed by CRA (document differences, if any, and reasons for change); Discuss and defend any aspect of review approach not accomplished; States whether criteria met or not. Lists issues associated with that objective: Discuss issue and details in both the Form 1 and on the Form 2. 6T6L May 2005 Revision

Documentation of Deficiencies Deficiency Form (Form 2) Used to document findings identified during criteria evaluation process . . . Requirement based = clear and specific description of the requirement and the condition which is deficient . . . Primary objective = clear communication . . . 6T6L May 2005 Revision

Review and Approval of Your Work ¬ Completed by team member; ­ Approved by Team Leader; ® Senior Advisor involved; ¯ Often an iterative process; ° Team Leader and Senior Advisor sign entire report; ± Team Member signs for Functional Area only; ² Dissenting opinion path available if no resolution. 6T6L May 2005 Revision

Pre-Start / Post-start Prior to being published, each finding should be identified as to whether or not, in the opinion of the ORR/RA team leadership, it must be resolved as a prerequisite to start of operations. This determines if it is a Pre-Start or Post-Start. Guidance is in the DOE/NNSA Order and Standards and Handbook and may also be included in the POA and IP. The contractor/DOE may be required by the Authorization Authority to resolve all Pre-Start findings of the DOE ORR/RA prior to startup or restart of a facility. 6T6L May 2005 Revision

Compliance Issues A non-compliance issue does not necessarily mean a Pre-Start finding! Does the non-compliance represent: significant risk? significant mission impact? significant political impact? significant lack of control? 6T6L May 2005 Revision

So, the question is..... Does this finding represent a deficiency of such magnitude as to prevent startup until resolved? Clear failure to implement commitment or assumption of TSR or DSA OR: Is it related to sustainability? Not a significant safety Issue? Limited impact to Activity within review scope? 6T6L May 2005 Revision

Determining Pre- or Post Start Pre-Start Unacceptable Risk Acceptable Risk Probability Post start 6T6L May 2005 Revision

Don't just identify the finding. . . Understand the potential impact of the finding! The possible consequences of not resolving it . . . The potential that those consequences will be realized and impact: - personnel; - environment; - facility; - mission; - public . . . 6T6L May 2005 Revision

Determine the possible consequences if Finding is Consider program elements that FINDING limit consequences Determine the possible consequences if Finding is Consider confidence in not corrected Management System Determine the potential(s) Consider program of those consequences elements that limit being realized potential of unwanted occurrences TL Handbook Appendix 11 6T6L May 2005 Revision

Some Obvious Prestart Criteria Causes a loss of operability that prevents safe shutdown or loss of monitoring ability of safety related systems (i.e. important to safety) . . . Indicates a lack of control that can have near term impact on operability or functionality of safety related systems . . . Requires operator action in short period of time to prevent or mitigate consequences . . . Violates assumption or controls by which DOE/NNSA accepts risk of operations . . . 6T6L May 2005 Revision

Some More Obvious Prestart Criteria Results in operation outside of limits of TSRs, OSRs, etc. . . . Results in an Unreviewed Safety Question: Increase in the probability or consequence of accident or failure mode described in SAR? Introduction of a new accident or failure mode not described in SAR? Reduction in the margin of safety as described in SAR? Results in failure to comply with Authorization Bases commitments (TSR, LCOs, Surveillances etc.) . . . 6T6L May 2005 Revision

Some More Obvious Prestart Criteria Operations/Activities that can lead to: Environmental release of hazardous material in excess of reporting guidelines, permit limits, etc. Exposure of off-site personnel in excess of radiological guidelines for off-site exposure or chemical exposure in excess of minimum reportable amounts. Worker / on-site exposures in excess of guidelines or requirements. 6T6L May 2005 Revision

Finding - example Two LCOs (10.1.1 and 10.2.2) specified in the activity SAR are not covered by approved surveillance procedures. 6T6L May 2005 Revision

Finding - example Emergency exits from this facility do not meet the requirements of NFPA 101 (Life Safety Code). The exits are required to have quick- open "crash bar" hardware. 6T6L May 2005 Revision

Finding - example Posting of Radiological areas and entry control programs for these areas per the requirements of 10 CFR 835 were inadequate. No control device was used as required on each entrance to the hot cell 2 area (high radiation area). 6T6L May 2005 Revision

Finding - example Although an adequate energy isolation procedure has been developed for this activity, maintenance personnel that service equipment in the area were not familiar with the procedure. No program has been established for root cause determination of maintenance failures, as required by DOE O 4330.4B 6T6L May 2005 Revision

Finding - example No valve identification was provided for the line emergency shutdown system. Although operators questioned were well aware of the shutdown procedure, new personnel may not be aware of these valves. 6T6L May 2005 Revision

Finding - example The pipe content and direction flow labeling for this process has been limited to those lines with hazardous materials. Non-hazardous material lines have not yet been labeled. 6T6L May 2005 Revision

If the Results of the Review are not Successful Significant Team Decision; Facts must support . . . Discuss situation and options with Authorization Authority . . . Two Options: Suspend the Review. Interim Report including what was done and areas not done. Final report for completed Functional Areas (FA) . . . High level discussion and findings for incomplete FAs . . . Terminate the Review. Report results with basis for repeat of entire ORR/RA. 6T6L May 2005 Revision