The EM/HQ Perspective on Readiness Review Robert Goldsmith, PhD Director of Operations Oversight EM-62

Office of Operations Oversight EM-60 - Office of Safety Management and Oversight EM-62 - Mission: To determine the effectiveness of Federal and contractor safety and health programs and management systems at EM field sites

EM-62 Oversight Responsibilities Day-to-day oversight of operational safety Line management assessments Integrated Targeted Validation and verification of completed corrective actions Startup and restart of nuclear facilities Timely identification and assistance in correction of deficient safety conditions Line management assessments, consistent with DOE Order 226.1, the DOE Worker Safety and Health Program, and ISMS criteria – targeted is stuff like con ops, work control, radcon, hazardous energy control Completeness of CAs and effectiveness Operational Readiness Reviews/Readiness Assessments

EM-62 Readiness Review Responsibilities Startup Authorities ID OR ORP RL SR WIPP P/P BNL Cat 3 FOM HQ Cat 2 restart Startup authority is Dae S-1 is the startup authority for new Category 1 and 2 Facilities. (NNSA may have had this delegated to S-2 New Category 2 activities in existing facilities have been treated as Cat 2 Restarts (Historically)

EM-62 Readiness Review Responsibilities Review and recommend approval Plan of Action Startup Notification Requests Declaration of Readiness ORRs & RAs Lead, participate or observe Central Technical Authority DNFSB We Review and Recommend where EM has startup authority The Appropriate Startup Authority approves the SNR ORRs – both contractor and field office

EM Recent Experience Most ORRs and RAs executed properly Anomalous events Premature declaration of readiness Site not following its own procedures RA begun before DSA approved Site procedure that almost precluded ORRs Over Last 18 months Premature – Oak Ridge MSRE Not following procedures ID RA w/o DSA – SRS Site Procedures the precluded ORRs – RL “Optics Problem” with GWSB#2 at SRS. This is a new building to hold vitrified waste canisters from the DWPF. Up to 4 of these buildings were analyzed in the DSA. Therefore the site did not consider it a major modification and did not do a PDSA. The regulators saw the situation differently. Both positions can be defended by the Order. The new SRS decision process still does consider this action as requiring a PSA.

Recent EM/HQ Actions Include readiness review process in integrated assessments Developed a DOE O 425.1C CRAD Memo from COO reiterating expectations with regard to DOE O 425.1C Working group with DOE-ID, CWI, EM, HSS, CTA EM Field SRS: New Decision Process in Place RL: Revised Readiness Procedure Ines memo: SNRs due 1/31 and quarterly Approved DSA before ORR/RA Working group with DOE-ID, CWI, EM, HSS, CTA To develop comprehensive plan that addreses what facilities are needed to carry out the cleanup mission, what facilities are needed, what is the AB umbrella for these facilities, what exemptions are required, what can we do at HQ to streamline exemption process, and what changes or interpretive guides can we make to minimize the level of subjectivity for 425?

Some EM issues with DOE O 425.1C Readiness Assessments are intended to be highly flexible What is an initial startup? What is a new facility? What is a major/substantial modification? What should follow a contractor RA? Need for S-1 approval of new Cat 2 facilities? Readiness Assessments are intended to be highly flexible, enabling a broad range of scope and depth – this may not be well embraced throughout the complex and regulators. Other processes should not be used to diminish the RAs domain or preclude sound professional judgment. RAs as defined in the Order, and even more so in STD-3006, are intended to be very flexible.  Also, 3006 clearly states in section
.10.1(8), "There is flexibility within the expectations for an RA. Therefore, it should not be necessary for the contractor to define any other readiness review processes."  Initial startups – new nuclear activity in existing facility; new equipment; existing nuclear process that moves to different locations (burial grounds, waste drums). S-1 approval carries a high overhead that doe not necessarily improve safety. Incentive to game the system to avoid the overhead.

Workshop Should Consider Recommendations for changes to Order and associated standards and guides Consensus on key definitions Template for readiness determination site process, including documentation Standardized CRAD DOE library of precedents Consider not making changes. The PDSA standard STD-1189 (in draft) has a definition of new facility. This will pre-empt and resolve some of our issues. Standardized CRAD- so sites know what to expect and reviewers know what to review.