Departmental Initiative to Enhance Activity-level Work Planning and Control DOE and DOE Contractors Industrial Hygiene Meeting in Conjunction with the 2014 American Industrial Hygiene Conference and Exposition David J Weitzman Industrial Hygienist Department of Energy Office of Health and Safety, HS-10 June 2, 2014

Thanks to CH2M  WG, Idaho, LLC 2 Integrated Safety Management (ISM)

3 Institutional Level Facility Level Activity Level: Work Planning & Control ISM 3

Activity-Level Work Planning and Control (ALWPC) Where the ISM rubber meets the road Applicable to all types of work activities including operations, maintenance, research, decommissioning, construction, etc. Protects both the worker from the plant and the plant from the worker 4

Defense Nuclear Facilities Safety Board (DNFSB) Expressed concern about work control processes in Recommendation Several DNFSB letter with WP&C concerns Reviewed WP&C at DOE sites with defense nuclear facilities from Issued DNFSB/TECH-37 ISM at the Activity Level: Work Planning and Control in

The Deputy Secretary outlined the following major actions in his November 2012 letter: Develop a DOE Handbook on ALWPC for contractor implementation Develop DOE CRADs and other guidance for oversight of ALWPC Conduct a workshop and evaluate operating experience DOE’s Response 6

Special ISM Champions Workshop DOE Forrestal HQ Building and Video and Web Conferencing Washington, DC May 15-16, 2013

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Approved, soon to be published Objectives: –Improve implementation of Activity-level Work Planning and Control (ALWPC) and activity-level work; –Assist contractors in more effectively meeting requirements of ISM at the activity level; –Provide a resource to clarify DOE requirements that govern activity-level work; –Provide good practices for implementing activity-level work; and –Show the linkage between safety culture and effective ALWPC practices. New Handbook Activity-level Work Planning and Control Implementation 9

Addresses: –Implementation of work planning and control –Skill of the worker –Work planning and control metrics, analysis, and trending –Collaborative team approaches –Activity-level work control document writer’s guide –Activity-level work control document verification and validation guidelines –Multi-week scheduling management –Fostering an environment to promote a positive safety culture and a safety-conscious work environment –DOE requirements citations as performance expectations New Handbook Activity-level Work Planning and Control Implementation 10

Implementation Sections: –Work planning and control and ISM –Defining the scope of work –Planning the Work – Identify and Analyze Hazards –Planning the Work – Develop and Implement Hazard Controls –Planning the Work – Scheduling –Performing Work within Controls –Providing Feedback on Adequacy of Controls and Continuing to Improve Safety Management New Handbook Activity-level Work Planning and Control Implementation 11

12 HDBK Example ALWPC Process

DOE G A Federal Line Management Oversight of DOE Nuclear Facilities Published April 14, 2014 Objectives: –Revise DOE-G to enhance guidance for ALWPC oversight –Measure effectiveness of ALWPC systems and identify situations in which the desired outcome is not achieved –Provide a clear set of expectations and evaluation criteria –Share best practices rather than promoting a single acceptable approach 13

DOE G A Federal Line Management Oversight of DOE Nuclear Facilities Published April 14, 2014 –Revised DOE-G to enhance guidance for Activity-level Work Planning and Control (ALWPC) oversight –Can use for measuring effectiveness of ALWPC systems and identify situations in which the desired outcome is not achieved –Provides a clear set of expectations and evaluation criteria –Shares best practices rather than promoting a single acceptable approach 14

DOE G A Federal Line Management of DOE Nuclear Facilities Based on: –The DOE requirements and guidance documents for ISM –URS Inc. procedures and an EFCOG guidance document, where appropriate –DOE analysis of ALWPC lessons learned, best practices, and DOE’s Operating Experience Program data –Lessons learned from implementation of ongoing DOE improvement actions –Ongoing efforts to improve safety culture across the DOE complex 15

DOE G A Federal Line Management of DOE Nuclear Facilities WP&C sections: –Field Element WP&C Assessments Program Definition Program Implementation –Operational Awareness –Oversight Schedule –Oversight Roles and Functions 16

DOE G A Federal Line Management of DOE Nuclear Facilities WP&C sections: –Analysis, Tracking, and Trending –Headquarters WP&C Oversight –CRAD Usage –Preparation for Oversight of Work Activities –Conducting Oversight of Work Activity Execution –Graded Approach for Conducting Oversight of Work Activities 17

DOE G A Federal Line Management of DOE Nuclear Facilities Includes Criteria Review and Approach Documents (CRADs): –Programmatic CRADs –Implementation CRADs –CRADs include: References to requirements Lines of Inquiry (LOIs ) –Are tailored to the level of hazard: – From high hazard and complexity to activities appropriate for Skill of the Worker –Are useful for: Planned reviews as well as routine operational awareness 18

Sustained Federal and Contractor Oversight of ALWPC 19 Sample NNSA Work Planning and Control improvements during FY2013 and FY2014 (courtesy Jim Winter, NA-00-10) : –NNSA biannual reviews of Field Offices emphasize WPC oversight in the Maintenance and Conduct of Operations CRADs –A growing number of Field Offices are collaboratively targeting ALWPC oversight more holistically with Facility Representatives and SMEs such as IHs. –Several M&O Contractors are applying elements of the EFCOG WPC CRADs to Contractor Assurance activities –WPC performance improvement plans are actively managed by M&O Contractors and Field Offices

Sustained Federal and Contractor Oversight of ALWPC Sample EM Work Planning and Control improvements during FY2013 and FY2014 (courtesy Don Rack, EM-42) : –All EM contractors include ALWPC oversight as part of their contractor assurance systems and have incorporated ALWPC oversight into their annual assessment schedules –Each EM field element has Identified a ALWPC SME to conduct programmatic oversight –EM HQ ALWPC oversight is performed by the Office of Operational Safety (EM-42) –EM's FY 2014 ALWPC oversight will continue to focus on ALWPC program implementation 20

Work Planning and Control Training National Training Center Course SAF-269: Fundamentals of Work Planning and Control –Provides foundational level knowledge of work planning and control concepts and processes –For DOE contractor and Federal oversight personnel –Pilot tested May 5-6, 2014 at Nuclear Facility Safety Programs Workshop 21

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