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Ownership matrix
USQ # 17-1806-S
TABLE OF CONTENTS
1.0 INTRODUCTION
..........................................................................................................................
3
1.1 Background
.........................................................................................................................
3 1.2
Purpose................................................................................................................................
4 1.3 Scope
...................................................................................................................................
4
2.0 ISMS OVERVIEW
.........................................................................................................................
5 2.1 ISMS Program Requirements
.............................................................................................
5 2.2 ISMS Business Levels
........................................................................................................
7 2.3 ISMS Guiding Principles
....................................................................................................
8 2.4 ISMS Core Functions
........................................................................................................
11 2.5 Integration of Other Initiatives and
Systems.....................................................................
11 2.6 Management System
.........................................................................................................
13
3.0 RIVER PROTECTION PROJECT OVERVIEW
.........................................................................
15 3.1 River Protection Project
....................................................................................................
15 3.2 Project Integration
.............................................................................................................
16 3.3 Hanford Interfaces
............................................................................................................
16 3.4 External Regulatory and Oversight Agencies
...................................................................
17
4.0 WORK EXECUTION WITHIN ISMS
.........................................................................................
18 4.1 Guiding Principle 1 – Line Management Responsibility for
Safety ................................. 18 4.2 Guiding Principle 2
– Clear Roles and Responsibilities
................................................... 21 4.3 Guiding
Principle 3 – Competence Commensurate with Responsibilities
....................... 23 4.4 Guiding Principle 4 – Balanced
Priorities
........................................................................
24 4.5 Guiding Principle 5 – Identification of Safety Standards and
Requirements ................... 24 4.6 Guiding Principle 6 –
Hazard Controls Tailored to the Work Being Performed ..............
24 4.7 Guiding Principle 7 – Operations Authorization
.............................................................. 25
4.8 Core Function 1 – Define the Scope of Work
...................................................................
25 4.9 Core Function 2 – (Identify and) Analyze Hazards
.......................................................... 28 4.10
Core Function 3 – Develop and Implement Hazard Controls
........................................... 33 4.11 Core Function 4
– Perform Work Within
Controls...........................................................
38 4.12 Core Function 5 – Provide Feedback and Continuous
Improvement ............................... 42
5.0 MAINTAINING AND SUSTAINING
ISMS...............................................................................
48 6.0 SOURCES
.....................................................................................................................................
49
6.1 Requirements
....................................................................................................................
49 6.2 References
.........................................................................................................................
49
TABLE OF FIGURES
Figure 1 DOE ISMS
......................................................................................................................................
3 Figure 2. ISMS Key Components.
...............................................................................................................
5 Figure 3 ISMS Guiding Principles and Core
Functions................................................................................
8 Figure 4 WRPS VPP
...................................................................................................................................
11 Figure 5 WRPS EMS
..................................................................................................................................
12 Figure 6. Identifying and Implementing TOC Requirements.
...................................................................
14 Figure 7. Underground Storage Tanks at the Hanford Site.
.......................................................................
15 Figure 8. Examples of Documents that Implement ISMS for WRPS.
....................................................... 18 Figure
9. Define Work Scope.
...................................................................................................................
25
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Figure 10. Identify Hazards.
......................................................................................................................
29 Figure 11. Hazard Control.
........................................................................................................................
34 Figure 12. Perform Work.
..........................................................................................................................
39 Figure 13. Feedback.
..................................................................................................................................
43
TABLE OF TABLES Table 1. ISMS Guiding Principles and Core
Functions Correlation to Supporting Program Elements. ..... 9 Table
2. External Regulatory and Oversight for the TOC.
........................................................................
17
TABLE OF ATTACHMENTS ATTACHMENT A - ACRONYMS AND ABBREVIATIONS
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55
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1.0 INTRODUCTION
(6.1.1)
1.1 Background
The U.S. Department of Energy (DOE) Integrated Safety Management
System (ISMS) is structured to integrate environment, safety,
health, and quality (ESH&Q) into work planning and execution.
In keeping with DOE O 436.1, “Departmental Sustainability,” and the
waste management character of the Tank Operations Contractor (TOC)
mission, a comprehensive Environmental Management System (EMS) is
established and interwoven with the ISMS for all actions with
potential environmental impacts. Integration is accomplished at the
company, facility, and activity levels. Total ESH&Q integration
enables the assigned missions to be efficient and effective while
protecting the workers, the public, and the
environment. DOE issued specific ISMS Clauses in the Code of
Federal Regulations (CFR) and DOE Acquisition Regulation (DEAR)
that are included as requirements under the Contract between
Washington River Protection Solutions LLC (WRPS) and the Office of
River Protection (DOE-ORP) (Contract DE-AC27-08RV14800, hereinafter
referred to as “the Contract”). Sections of the DEAR related to the
ISMS Description are discussed in Sections 1.0, 2.0, and 4.0. 48
CFR DEAR 970.5204-2, “Laws, Regulations, and DOE Directives,”
requires that ESH&Q requirements applicable to work conducted
under the Contract be implemented by a DOE-approved process. The
process will evaluate the work and the associated hazards and
identify an appropriately tailored set of standards, practices, and
controls, such as a tailoring process included in a DOE-approved
Safety Management System implemented under 48 CFR DEAR 970.5223-1,
“Integration of Environment, Safety, and Health into Work Planning
and Execution.” When such a process is used, the set of tailored
(ESH&Q) requirements, approved by DOE-ORP, are incorporated
into Contract requirements with full force and effect unless WRPS
requests an exemption or other appropriate regulatory relief
specified in the regulation. 48 CFR DEAR 970.5223-1 requires WRPS
to manage and perform work in accordance with a documented ISMS.
The ISMS shall describe how WRPS performs the following: • Defines
the scope of work • Identifies and analyzes hazards associated with
the work
Figure 1 DOE ISMS
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• Develops and implements hazard controls • Performs work within
controls • Provides feedback on adequacy of controls and continues
to improve ISMS Consistent with the DEAR, the Contract requires
WRPS to accomplish work “…in an integrated manner that protects the
workers, public, and environment while enabling efficient cleanup.”
The Contract also states WRPS:
…shall implement a structured, standards-based approach to
planning and control of work including identification and
implementation of worker safety and health standards and
requirements that are appropriate for the work to be performed and
for identifying and controlling related hazards, while facilitating
the effective and efficient delivery of work.
Detailed ISMS requirements are included in the Contract
requirements and guidance to develop, implement, sustain, and
continuously improve a safety management system for DOE and its
contractors. By including key provisions and clauses in the
Contract, DOE-ORP has a mechanism to define the mission, direct
implementation, and monitor the effectiveness of ISMS, integrate
ESH&Q throughout activities performed within the defined scope
of work, and achieve integration of contractor internal and
external activities. See Attachment A for acronyms and
abbreviations associated with this plan.
1.2 Purpose The purpose of this document is to describe the ISMS
structure, policies, programs, processes, and implementing
mechanisms developed and used by WRPS to ensure protection of the
environment and the safety and health of the workers, the public,
and the environment. This ISMS Description, along with related ISMS
implementing mechanisms, fulfills the intent of the following
requirements: • 48 CFR DEAR 970.5204-2, “Laws, Regulations, and DOE
Directives” • 48 CFR DEAR 970.5223-1, “Integration of Environment,
Safety, and Health into Work
Planning and Execution” • ESH&Q related requirements in
Contract Attachment J.2.
1.3 Scope The scope of this document includes the WRPS ISMS
policies, programs, processes, and implementing mechanisms with
reference to lower-tier documents containing the detailed
integration of ESH&Q into work planning and execution. The ISMS
applies to work performed by WRPS under the Contract, and to work
subcontracted out by WRPS. WRPS, through applicable processes and
procedures, is responsible for ensuring subcontractors fully
implement ISMS requirements.
Objective of Integrated Safety Management The Department and
Contractors must systematically integrate safety into management
and work practices at all levels so that missions are accomplished
while protecting the public, the worker, and the environment. This
is to be accomplished through effective integration of safety
management into all facets of work planning and execution. In other
words, the overall management of safety functions and activities
becomes an integral part of mission accomplishment. (DOE P
450.4)
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The scope of this document includes the Environmental Management
System, safety and health management (including industrial hygiene
and radiation protection), quality assurance, sustainability, waste
minimization, and Security and Emergency Services. Use of the terms
“ISMS” and “safety” in this document include environmental
protection, safety and health management (including industrial
hygiene and radiation protection), quality assurance,
sustainability, waste minimization, and Security and Emergency
Services.
2.0 ISMS OVERVIEW (6.1.1) The structure of the ISMS contains
seven guiding principles and five core functions. The guiding
principles and core functions are interactive and iterative among
elements and business levels (i.e., company level, facility level,
activity level) throughout the life-cycle phases. This structure is
based on the requirements and guidance contained in 48 CFR DEAR
970.5223-1 (Contract DE-AC27-08RV14800, Clause I.142); DOE M
450.4-1, “Integrated Safety Management System Manual;” and DOE G
450-4-1B Volume 1, “Integrated Safety Management System Guide
(Volume 1) for use with Safety Management System Policies (DOE P
450.4, DOE P 450.5, and DOE P 450.6); the Functions,
Responsibilities, and Authorities Manual; and the DOE Acquisition
Regulation.”
2.1 ISMS Program Requirements As described in TFC-POL-16, the
ISMS consists of six components as shown in Figure 2.
Figure 2. ISMS Key Components.
TFC-PLN-01 identifies programmatic elements and requirements for
the ISMS. All aspects of work planning and execution are performed
within the structure of the ISMS. TFC-PLN-01 applies to the WRPS
ISMS related policies, programs, processes, and implementing
mechanisms with reference to lower-tier documents containing the
detailed integration of ESH&Q aspects into work planning and
execution. The plan implements the following requirements: • 48 CFR
DEAR 970.5204-2, “Laws, Regulations, and DOE Directives” • 48 CFR
DEAR 970.5223-1, “Integration of Environment, Safety, and Health
into Work
Planning and Execution” • DOE M 450.4-1, “Integrated Safety
Management System Manual”
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• DOE G 450.4-1B Volume 1, “Integrated Safety Management System
Guide (Volume 1)
for Use with Safety Management System Policies (DOE P 450.4, DOE
P 450.5 and DOE P 450.6); The Functions, Responsibilities, and
Authorities Manual and DOE Acquisition Regulation”
• To the extent possible, the ISMS also includes the four
supplemental safety culture
elements described in DOE M 450.4-1. TFC-PLN-12 includes
relevant safety culture attributes.
Objective
The overall management of safety functions and activities is an
integral part of mission accomplishment. WRPS systematically
integrates safety into management and work practices at all levels
so that our mission is accomplished while protecting the public,
the worker, and the environment. This is to be accomplished through
effective integration of the ISMS into all facets of work planning
and execution.
Guiding Principles The ISMS guiding principles describe the
environment or context for work activities in that most principles
apply to each ISMS core function. WRPS integrates these guiding
principles into all aspects of work planning and execution.
Core Functions The core functions provide the necessary
structure for any work activity that could potentially affect the
workers, the public, and the environment. The core functions
describe what “must be done,” and are applied as a continuous cycle
with the degree of rigor appropriate to the type of work activity
and hazards involved.
Mechanisms Mechanisms define how the ISMS functions are
performed by WRPS. The mechanisms vary based on the hazards and the
work being performed and may include the following: • DOE
expectations expressed through directives (i.e., policies, rules,
orders, notices,
standards, and guidance) and Contract clauses. • Policies,
procedures, and other documents established to implement safety
management
and fulfill commitments made to the DOE.
Responsibilities Responsibilities are clearly defined in
documents appropriate to the activity. WRPS responsibilities are
detailed in documents such as contracts, regulations, charters,
plans, and procedures.
Implementation WRPS implements the ISMS through work definition
and planning, hazards identification and analysis, definition and
implementation of hazard controls, performance of work, developing
and implementing operating procedures, and monitoring and assessing
performance for improvement.
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2.2 ISMS Business Levels There are three business levels within
the ISMS structure: the company level, the facility level and the
activity level.
The Company Level The TOC work scope for WRPS is contractually
divided into seven Contract Line Item Numbers (CLIN), as follows: •
CLIN 1 – Production Operations and Tank Farm Infrastructure • CLIN
2 – Single-Shell Tank Retrieval and Closure • CLIN 3 – WTP [Waste
Treatment and Immobilization Plant] Support and Mission
Integration • CLIN 4 – Supplemental Treatment • CLIN 5 – Early
Feed and Operation of the WTP Low-Activity Waste Facility • CLIN 6
– Pension and Welfare Plans • CLIN 7 – American Recovery and
Reinvestment Act Work Scope (Inactive). The TFC-PLN-84 provides the
WRPS project execution management plan to describe the overall
project management approach for execution of the identified CLINs,
policies, and methods for compliance with DOE O 413.3B, “Program
and Project Management for the Acquisition of Capital Assets.” In
addition, integration of project-level changes and updates to
maintain the Performance Measurement Baseline are described in
TFC-PLN-147, including definitions and a cross-walk of Work
Breakdown Structure (WBS) to Organizational Breakdown Structure
(OBS) to both authorize contract work and define who will
organizationally execute assigned scope based on roles,
responsibilities, authorities, and accountabilities (R2A2s)
maintained by Workforce Resources. Activities performed under this
comprehensive management strategy utilize ISMS, as the work
execution approach to embed Environmental, Safety, Health and
Quality Assurance oversight, described in TFC-PLN-02, into each
work area to fortify a healthy safety culture at WRPS. This
approach implements a corporate “Execution with Certainty”
strategic business model and establishes Earned Value Management
System as the tool for measurement of project performance. The
fundamental project management principles detailed in Appendix C of
DOE O 413.3B are implemented with a tailored approach to assure the
appropriate degree of rigor is applied to reflect the cost, risk
mitigation, schedule and complexity of the project, including
application of applicable lessons learned from federal and
commercial projects.
The Facility Level At the facility level, work is managed at the
functional or sub-project level; multi-disciplinary teams implement
the ISMS core functions through the graded approach established
within the activity work control process (TFC-OPS-MAINT-C-01).
Facility-level integrated work authorization schedules
(TFC-OPS-OPER-C-65) are prepared. Authorized work is established at
the company level and implemented at the facility level. For
example, at Hazard Category 2 and 3 nuclear facilities, authorized
work activities are analyzed and controlled by the Documented
Safety Analysis (DSA) and technical safety requirements (TSR) and
implemented through
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procedures and training. The safety basis (DSAs and TSRs), along
with the environmental basis (e.g., environmental permits, legal
agreements) and the requirements basis (Contract DE-AC27-08RV14800,
TFC-PLN-100), form the Authorization Basis (as part of the
Authorization Agreement, Correspondence No. 1800004) for the
facility. Schedules are addressed at weekly schedule meetings, and
work release is controlled to ensure work (operations, maintenance,
and construction) is performed within the Authorization Basis.
The Activity Level The activity level includes review,
authorization, and expectations to execute authorized work
including, but not limited to, design, engineering, operations,
maintenance, construction, testing, laboratory support, and
assessment. A single work-control process (TFC-OPS-MAINT-C-01)
describes the work definition, graded approach classification, and
processes for non-routine operational activity. This is the
principal mechanism that coordinates incorporation of the ISMS
guiding principles and core functions into detailed mission
performance in the field. TFC-ESHQ-S_SAF-C-02 provides supplemental
guidance to assure effective hazard analysis. Working documentation
is prepared by means of process-trained, team-based worker
engagement practices (e.g., walkdowns, comparison to General Hazard
Analyses [GHAs], work packages, procedures, engineering change
notices, unreviewed safety question [USQ] screenings), and
safeguards (TFC-BSM-IRM-STD-08). Work is scheduled and communicated
at the plan of the day meetings; field work supervisors, leads, and
workers pre-brief, perform, and post-job review the work—to the
extent practical as a team.
2.3 ISMS Guiding Principles The seven guiding principles are
attributes applied to and achieved through execution of the methods
(e.g., processes and procedures) that implement the five core
functions. Guiding Principles one through three are applied to each
activity within each core function at each business level, and are
specifically discussed in Section 4.0, “Work Execution within
ISMS.” Guiding Principles four through seven align with specific
core functions as illustrated in Table 1, and are discussed in
Section 4.0. Figure 3 ISMS Guiding Principles and Core
Functions
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1. Line Management Responsibility for Safety. Line management is
directly responsible
for the protection of the workers, the public, and the
environment. As a complement to the line management, the
Department’s Office of Health, Safety and Security provides safety
policy, enforcement, and independent oversight functions.
2. Clear Roles and Responsibilities. Clear and unambiguous lines
of authority and
responsibility for ensuring safety shall be established and
maintained at all organizational levels within the Department and
its contractors.
3. Competence Commensurate with Responsibilities. Personnel
shall possess the
experience, knowledge, skills, and abilities that are necessary
to discharge their responsibilities.
4. Balanced Priorities. Resources shall be effectively allocated
to address safety,
programmatic, and operational considerations. Protecting the
workers, the public, and the environment shall be a priority
whenever activities are planned and performed.
5. Identification of Safety Standards and Requirements. Before
work is performed, the
associated hazards shall be evaluated and an agreed-upon set of
safety standards and requirements shall be established, which, if
properly implemented, will provide adequate assurance that the
public, the workers, and the environment are protected from adverse
consequences.
6. Hazard Controls Tailored to Work Being Performed.
Administrative and engineering
controls to prevent and mitigate hazards shall be tailored to
the work being performed and the associated hazards.
7. Operations Authorization. The conditions and requirements to
be satisfied for
operations to be initiated and conducted shall be clearly
established and agreed upon.
Table 1. ISMS Guiding Principles and Core Functions Correlation
to Supporting Program Elements.
ISMS Guiding Principles with Environmental Integration
ISMS Core Functions with Environmental Integration
Environmental Management System Elements
DOE-VPP Elements
Quality Assurance Criterion
1. Line Management Responsibility
All Five Core Functions
1. Management Leadership
Chapter 1, Organization Chapter 2, Quality Assurance
Organization
2. Clear Roles and Responsibilities
2. Employee Involvement
Chapter 1, Organization Chapter 2, Quality Assurance
Organization
3. Competence per Responsibilities
5. Safety and Health Training
Chapter 2, Personnel Training and Qualification
4. Balanced Priorities 1. Define Scope of Work
1. Establish Environmental Policy
Chapter 1, Organization
2. Planning
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ISMS Guiding Principles with Environmental Integration
ISMS Core Functions with Environmental Integration
Environmental Management System Elements
DOE-VPP Elements
Quality Assurance Criterion
2. Identify and Analyze Hazards and
Environmental Impacts
3. Worksite Analysis
Chapter 3, Design Control Chapter 10, Inspection
5. Identification of Safety and Environmental Standards
6. Tailor Hazard and
Environmental Controls to Work
3. Develop and Implement
Hazard and Environmental Controls
3. Implementation and Operations
4. Hazard Prevention and Control
Chapter 4, Procurement Document Control Chapter 5, Instructions,
Procedures, and Drawings Chapter 6, Document, Control Chapter 7,
Control of Purchased Items and Services Chapter 8, Identification
and Control of Items Chapter 9, Control of Special Processes
Chapter 11, Test Control Chapter 12, Control of Measuring and Test
Equipment Chapter 13, Handling, Storage, and Shipping Chapter 15,
Control of Nonconforming Items
7. Operations (safety and environmental) Authorization
4. Perform Work Within Controls
Chapter 4, Procurement Document Control Chapter 5, Instructions,
Procedures, and Drawings Chapter 6, Document, Control Chapter 7,
Control of Purchased Items and Services Chapter 8, Identification
and Control of Items Chapter 9, Control of Special Processes
Chapter 11, Test Control Chapter 12, Control of Measuring and Test
Equipment Chapter 13, Handling, Storage, and Shipping Chapter 15,
Control of Nonconforming Items Chapter 17, Records
5. Feedback and
Continuous Improvement
4. Checking All Five Elements Chapter 18, Audits 5. Management
Review
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2.4 ISMS Core Functions
The five core functions below provide the overall framework and
structure of the ISMS: 1. Define the Scope of Work. Missions are
translated into work, expectations are set, tasks
are identified and prioritized, and resources are allocated. 2.
Analyze the Hazards. Hazards associated with the work are
identified, analyzed, and
categorized. 3. Develop and Implement Hazard Controls.
Applicable standards and requirements are
identified and agreed-upon, controls to prevent/mitigate hazards
are identified, the safety envelope [Authorization Agreement] is
established, and controls are implemented.
4. Perform Work Within Controls. Readiness is confirmed and work
is performed safely. 5. Provide Feedback and Continuous
Improvement. Feedback information on the
adequacy of controls is gathered, opportunities for improving
the definition and planning of work are identified and implemented,
line and independent oversight is conducted, and, if necessary,
regulatory enforcement actions occur.
2.5 Integration of Other Initiatives and Systems
Numerous environmental, health, and safety initiatives—such as
the Voluntary Protection Program (), Safety Culture, EMS, and Human
Performance Improvement (HPI)—are used to enhance the effectiveness
of the ISMS. To the extent practical, the ISMS addresses the
supplemental safety culture elements (individual responsibility for
safety, operational excellence, oversight for performance
assurance, and organizational learning for performance
improvement). These initiatives, together with the Quality
Assurance Program Description (QAPD) (TFC-PLN-02) and the
Environmental Management System Description (TFC-PLN-123),
complement ISMS implementation and support the ISMS continuous
improvement objective. Table 1 illustrates the correlation between
ISMS and several other structures.
Figure 4 WRPS VPP
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The EMS component of the ISMS drives implementation of the
applicable environmental requirements in a manner consistent with
the requirements of DOE O 436.1. The Environmental Protection
organization identifies all applicable statutory, regulation,
permit, and other environmental requirements in support of the Tank
Operations Project execution and operations elements. The suite of
applicable Environmental requirements is maintained current by
continual review of requirements sources, emerging DOE requirements
and expectations, and through active interfaces with other Hanford
contractors and environmental stakeholders. The programs comprising
the WRPS EMS are implemented by the Environmental Protection
organization (TFC-POL-30 and
TFC-PLN-123), the Waste Services organization (TFC-PLN-33),
Operations (consisting of line management), and the Safety
organization (TFC-PLN-13 and TFC-PLN-58). These documents also
address EMS elements performed by other contractors per DOE-ORP
contract direction, but not directly implemented by WRPS. WRPS has
an expanded comprehensive work planning process. Teamwork is used
at multiple stages of the work control lifecycle for project
performance. Incorporating lessons learned and best practices,
robust hazard analysis and control are used to evaluate and improve
the way higher-risk or complex work is identified, planned,
approved, controlled, and executed. Key elements of the work
planning process include line management ownership and a graded
approach to work management based on risk and complexity, worker
engagement and integrated work planning teams. As a part of this
process, workers—in multi-disciplinary teams—are directly engaged
in work planning, hazard identification and control, work
execution, and post-job reviews when performed. A graded approach
to work planning is integrated into the work control process, which
is defined in TFC-OPS-MAINT-C-01. As a defense-in-depth measure,
WRPS employs the concepts and principles of HPI as an approach to
error reduction that has been developed in other sectors of the DOE
and nuclear industry at large (TFC-PLN-150). WRPS maintains its
awareness current in DOE-wide HPI activities through participation
with the Energy Facility Contractors Group (EFCOG). This includes
active collaboration with many DOE elements that share interest in
improved work execution performance. Human factors and performance
considerations are variables considered during the work planning
process (TFC-OPS-MAINT-STD-02). Planners enter limitations,
precautions, safety concerns, and other information that will
enhance field performance for the specific job. Planners are
cautioned not to assume that a given work activity will necessarily
be performed by a particular individual or team. The Quality
Assurance (QA) program is established and implemented in compliance
with 10 CFR 830, Subpart A, “Quality Assurance Requirements;” and
DOE O 414.1D, “Quality Assurance.” The QA program is documented in
TFC-PLN-02 and ATS-MP-1032. The QAPD is
Figure 5 WRPS EMS
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organized to address the management, performance, and assessment
criteria of paragraph 830.122. The QA program's key implementing
documents are contained within the Quality Implementing Plan (QIP)
of the QAPD and were developed to provide a correlation between
regulatory consensus standards invoked for implementation of the QA
criteria (ASME-NQA-1-2008, including NQA-1a-2009 Addenda), QA
program requirements, and implementing documents. The QIP provides
visibility to implementing procedures and serves to ensure
consistency in the management and implementation of QA program
requirements. The QA criteria and practices are embedded in all
work processes, including those that relate to nuclear safety.
Therefore, the actions to implement the QA criteria are integrated
and consistent with the ISMS structure. The DOE VPP promotes safety
and health excellence through cooperative efforts among labor,
management, and government at DOE contractor sites. Key tenets of
VPP include management leadership and commitment, employee
involvement, work site analysis, hazard prevention and control, and
safety and health training. WRPS achieved STAR status, which is the
highest level of recognition awarded within the VPP for outstanding
contractor safety and health programs that have successfully
implemented the program elements. The WRPS VPP program is defined
in TFC-PLN-47. The worker safety and health requirements in 10 CFR
851 apply to the conduct of contractor activities at DOE sites. The
requirements are intended to reduce or prevent occupational
injuries, illnesses, and accidental losses by providing DOE
contractors and their workers with safe and healthful workplaces at
DOE sites. 10 CFR 851 contains programmatic requirements for
management responsibilities and worker rights and responsibilities,
hazard identification and assessment, hazard prevention and
abatement, safety and health standards, functional areas, training
and information, recordkeeping, and reporting. TFC-PLN-47 is a
description of how the 10 CFR 851 requirements are met by procedure
implementation. The ISMS is structured to integrate environment,
safety, health, and quality into work planning and execution. Total
ESH&Q integration enables the assigned missions to be
efficiently and effectively accomplished while protecting the
workers, the public, and the environment.
2.6 Management System The management system is multi-tiered,
beginning with the Contract and Authorization Agreement
(Correspondence No. 1800004) executed between DOE-ORP and WRPS. The
document hierarchy (TFC-PLN-80) employs a tiered graded approach:
Policies convey company position on important-to-safety topics;
Management Plans establish the ISMS mechanisms to accomplish a
given scope of work or a specific task; Charters establish
cross-functional groups and teams that assure coordination in
employment of the ISMS Core Functions is effective. The
Implementing procedures contain specific activity-level methods
that provide direction where a common product or service is
desired. Laws, regulations, and DOE directives will flow through
the hierarchy, placing the requirements associated with specific
activities within the procedures that govern those activities. When
changes occur in the ISMS regulatory requirement documents, these
changes are flowed down through the hierarchy of documents via the
procedure change process and are reflected in new revisions of
policies, procedures, plans, and implementing documents. The
organizations responsible for these documents implement
requirements that include environmental requirements, derived from
the Authorization Agreement (Correspondence No.
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1800004), into their internal procedures. Figure 6 shows the
identifying and implementing of TOC requirements as established by
WRPS. TFC-PLN-100 identifies implementing documents associated with
the WRPS Contract requirements. As implemented by the TOC,
TFC-PLN-100 addresses applicable laws and regulations, as well as
the applicable requirements from DOE orders, directives, or
standards. As part of this process, any exceptions, clarifications,
or alternate means of implementation for these requirements are
identified by TFC-PLN-100.
Figure 6. Identifying and Implementing TOC Requirements.
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External implementing documents for activities controlled by
other site contractors as described in Section J.3 of the Contract
are allowed if controlled in accordance with equivalent TOC
processes and the applicable interface document. When necessary,
management directives are used/issued on an interim basis to
establish and (or) clarify a process or expectation on an immediate
basis that is important to the tank operations mission until the
proceduralized process is established or revised.
3.0 RIVER PROTECTION PROJECT OVERVIEW This section provides an
overview of the River Protection Project (RPP), project
integration, and the TOC outside interfaces.
3.1 River Protection Project Since 1944, highly radioactive
waste from the chemical processing of irradiated reactor fuel has
been stored in underground storage tanks at the Hanford Site.
Approximately 204 million liters (56 million gallons) of caustic
liquid, salt cake, and sludge are currently stored in 177
underground storage tanks in 18 tank farms. The tanks represent
about 60 percent (by volume) of the nation’s and 80 percent (by
radioactivity) of the Hanford Site’s radioactive waste resulting
from nuclear weapons development (see Figure 7).
Figure 7. Underground Storage Tanks at the Hanford Site.
The DOE-ORP was established at the Hanford Site in December
1998, as directed by Congress in Section 3139 of the Strom Thurmond
National Defense Authorization Act for Fiscal Year 1999, to execute
and manage the RPP. The mission of the RPP is to retrieve and treat
Hanford’s tank waste and close the tank farms to protect the
Columbia River. In support of this mission, DOE-ORP has three prime
contractors that are responsible for executing the assigned project
work scope. WRPS is the TOC responsible for ensuring safe storage
and retrieval of current and future tank waste, sampling and
analyzing tank waste and storage of the immobilized waste,
decontamination and decommissioning, initiation of post-closure
monitoring of the tank farms, and early feed to the WTP
Low-Activity Waste Facility. Bechtel National, Inc. (BNI) is the
Waste Treatment Contractor (WTC) responsible for designing,
constructing, and commissioning of the WTP. Wastren Advantage, Inc.
(WAI) is responsible for performing the analytical services
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production functions of receiving, handling, analyzing, storing
samples, performing special tests, and reporting the results of
these analyses and tests to the other Hanford Site contractors. WAI
is co-located at the 222-S Laboratory managed by WRPS, and is the
Analytical Services Production Contractor (ASPC). The EPC
organization (TFC-CHARTER-01) is responsible for development of the
work processes and procedures associated with EPC construction
activities to deliver early feed to the WTP Low-Activity Waste
Facility, commonly known as Direct Feed Low Activity Waste
(DFLAW).
3.2 Project Integration Support to the DOE-ORP is provided in
managing the RPP integrated baseline (TFC-PLN-84); coordinating RPP
activities in support of baseline communications and interface
management; and assisting in decision-making to identify key
strategic issues, possible outcomes, and optimization (TFC-PLN-39).
This function also assists with the RPP integration activities
among DOE-ORP, BNI, and WAI. WRPS performs cost-effective
integration of RPP activities. This is done by establishing
processes and systems to accomplish this integration, identify and
track integration issues to resolution, communicating plans and
accomplishments at the RPP level, and providing project status
information (TFC-PLN-83). Interface control documents are
collaboratively developed to define the requirements and acceptance
criteria to meeting infrastructure, waste feed, product delivery,
and waste management functional needs within the RPP.
3.3 Hanford Interfaces At the Hanford Site, the TOC’s primary
interface is with the ORP. In addition, there may be interfaces
with DOE’s Richland Operations Office (DOE-RL) and Pacific
Northwest Science Office. WRPS relies on support services from the
other Hanford contractors in order to meet its mission commitments
(TFC-BSM-CP_CPR-C-17). WRPS interfaces with other DOE prime
contractors for services as outlined in the Attachment J.3 of the
Contract. Contractors that interface with the TOC include the
following: • Mission Support Alliance provides most of the Hanford
Site infrastructure support
services (Mission Support Contractor) such as safeguards,
security, protective forces, emergency management support, crane
and rigging services, roads, grounds, electricity, sewer and water
services, biological, ecological, and cultural resource reviews,
etc.
• BNI manages the design and construction of the WTP project,
managed by DOE-ORP,
for final treatment of tank waste. WRPS has explicit interfaces
with BNI to prepare for the commencement of WTP receipt of tank
waste.
• CH2M Hill Plateau Remediation manages the Plateau Remediation
Contract, which
provides groundwater/vadose zone integration; site well drilling
and decommissioning; low-activity waste disposal; industrial and
radioactive liquid effluent treatment and disposal; low-level waste
and mixed low-level waste treatment, storage, and disposal;
operation and maintenance of the Solid Waste Integrated Forecast
Technical database; operates the Environmental Restoration Disposal
Facility; etc.
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• HPMC Occupational Medical Services manages Hanford Site
occupational health
services for Hanford workers. HPMC provides medical
qualifications, medical monitoring, and occupational medical
services.
• WAI is the ASPC, which provides analytical laboratory services
to the TOC. • Johnson Controls provides the TOC with steam service.
• Unitech Services Group provides contaminated laundry services to
the TOC. • Pacific Northwest National Laboratory provides research,
development, and
demonstration support services, as well as radiological
instrumentation, dosimetry services, and other environmental
monitoring and analysis support services to the TOC.
• Interface documents including Memorandums of Agreements,
Administrative Interface
Agreements, and interface controls documents. Inter-contractor
work orders/task orders support delivery and receipt of safe and
reliable services between the many Hanford contractors. The
Interface Management Program is controlled by TFC-PLN-102.
3.4 External Regulatory and Oversight Agencies
Table 2 provides an overview of the TOC’s external regulatory
and oversight agencies that are in addition to DOE, and their
primary focus. DOE is discussed in Section 4.2, “Guiding Principle
2 – Clear Roles and Responsibilities,” and Section 4.12.4,
“Oversight and Enforcement.”
Table 2. External Regulatory and Oversight for the TOC.
External Regulatory and Oversight Activities
Environmental Protection
Agency
Washington Department of
Ecology
Washington Department of
Health
U.S. Department of Transportation
Defense Nuclear Facilities
Safety Board
Benton Clean
Air Agency Regulates all treatment/storage/ disposal activities
under Resource Conservation and Recovery Act, Toxics Substance
Control Act, Comprehensive Environmental Resource Conservation
Liability Act, Tri-Party Agreement, Solid Waste Management Act, and
the Washington State Hazardous Waste Management Act
X X
Regulates radioactive air emissions X X Regulates
non-radioactive air emissions X X
Regulates liquid effluents X X Regulates offsite transportation
of radioactive and non-radioactive hazardous wastes
X X
Ensures and enhances the safety of DOE’s defense nuclear
facilities operations
X
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4.0 WORK EXECUTION WITHIN ISMS (6.1.1) The preceding portions of
this document discussed the basic structure of an ISMS and the RPP.
Expectations are communicated. Programs are established to provide
management and workers with the guiding principles and structure to
ensure safety, quality, and environmental protection is an integral
part of each work activity. A comprehensive work planning process
evaluates and improves the way higher risk, more complex work is
identified, planned, approved, controlled, and executed.
TFC-PLN-100 cross-references specific TOC implementing documents to
the Contract requirements each satisfies. Figure 8 provides an
illustration of example documents that implement the five ISMS Core
Function.
Figure 8. Examples of Documents that Implement ISMS for
WRPS.
The hazards and complexity of the work determines the level of
rigor applied to training, procedures, and control of work. This
section describes in detail how the integration of ESH&Q within
management processes establishes a common set of controls essential
for the safe and efficient performance of work.
4.1 Guiding Principle 1 – Line Management Responsibility for
Safety WRPS fully endorses the guiding principle that line
management is directly responsible and accountable for the
protection of the workers, the public, and the environment by
integrating ESH&Q into the planning, hazard analysis and
control, and performance of work. Clearly defining the term “line
management” is important so safety management roles and
responsibilities are understood. As published in DOE G 450.4-1B,
Volume 1, line management is defined as
1. Define the Scope of Work• TFC-BSM-CP_CPR-C-05• TFC-PLN-39•
TFC-OPS-MAINT-C-01
2. Identify Hazards• TFC-ESHQ-S_SAF-C-02• TFC-ESHQ-RP_RWP-C-
03
3. Develop and Implement Hazard Controls• TFC-PLN-07•
TFC-ESHQ-S_IH-C-07
4. Perform Work Within Controls• TFC-OPS-OPER-C-13
5. Provide Feedback and Continuous Improvement• TFC-PLN-10•
TFC-ESHQ-Q_C-C-01
ISMS Core
Functions
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“any management level within the line organization, including
contractor management, which is responsible and accountable for
directing and conducting work.” Work is broadly defined to include
physical work, design, engineering, maintenance, operations,
testing, administrative, and assessment. An ISMS provides line
management with the technical resources necessary to fulfill their
responsibility. To strengthen its ISMS, WRPS implemented the
attributes of a healthy safety culture, which includes free flow of
communication and an environment free of retaliation for raising
safety concerns. Consistent with strong safety culture principles,
management conducts periodic employee safety meetings, further
enhancing the flow of communications regarding relevant safety
information. TFC-PLN-12 identifies the focus areas and attributes
associated with a healthy safety culture. These attributes include
providing an environment where individuals will feel free to raise
safety concerns without fear of harassment, intimidation,
retaliation, or discrimination.
WRPS Flowdown of Authority Line direction for company and
facility/project work activities flows down from the DOE-ORP
through the Project Manager to the work area and functional
managers pursuant to TFC-CHARTER-01.
Tank Operations Field Activities Under the organization
structure established to implement the Area Team approach, the work
area managers are responsible for the overall tank farms facility
operation and work execution. The Shift Managers are directly
accountable for work release, monitoring, and control of field
activities (supported by the Senior Supervisor Watch when assigned)
(TFC-PLN-05). ESH&Q experts provide monitoring and oversight of
field activities to ensure the protection of the workers, the
public, and the environment. Every employee is empowered and
expected to exercise “stop work” authority to prevent performance
of an unsafe act or to correct an unsafe condition (DOE-0343,
“Hanford Site Stop Work Procedure”). The Business Services
organization manages the non-nuclear facilities on the tank farms
and is responsible for procurement of materials and contract
services.
Safety Integration Forums Various forums are used to assist with
integration and oversight of organizations and activities. The
TOC-sponsored committees and councils have formal charters, defined
responsibilities, and lines of authority in TOC administrative
procedures. Other forums discussed below, such as boards and safety
meetings, have applicable governing documents. • Executive Safety
Review Board (ESRB) (TFC-CHARTER-32) provides oversight of
identification, causal analysis, reporting, and corrective
action plan development for issues identified in significant
problem evaluation requests (PER). The ESRB also provides feedback
and senior management direction concerning the focus and conduct of
assessments; reviews the health of the Safety Management Programs
and Price-Anderson Amendments Act (PAAA) program performance; and
reviews issues that have crosscutting organizational
implications.
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• WRPS Safety Councils (TFC-CHARTER-02) are WRPS’ safety
leadership councils.
The Employee Accident Prevention Councils and subcommittees
report to the President’s Accident Prevention Council. These
councils provide employee leadership and ensure employee
involvement, thereby achieving maximum accident prevention and
injury reduction by application of the VPP and ISMS principles. The
ALARA Committee is a subcommittee of the President’s Accident
Prevention Council and periodically reports on ALARA Committee
activities.
• Joint Test Group (TFC-CHARTER-15) conducts thorough reviews of
test procedures
to ensure they can be performed safely, to ensure compliance
with applicable procedure requirements, and to demonstrate
accomplishment of test objectives.
• WRPS Baseline Change Control Board (TFC-PRJ-PC-C-12) is
composed of WRPS
managers from the project and support functions. The Board is
responsible for reviewing and approving baseline change requests as
defined in TFC-PRJ-PC-C-12. The Change Control Board is also
responsible for approving baseline change requests identified by
the Program Change Control Board as requiring senior management
decision on company-wide strategy and priority prior to submittal
to DOE-ORP.
• Safety Meetings (TFC-ESHQ-S_SAF-CD-10) promote safety by
addressing different
health or safety topics, including information on basic issues,
control methods, and established programs. Employees are encouraged
to use a questioning attitude and engage in each meeting by sharing
their ideas on safety issues.
• Joint Review Group (TFC-ESHQ-RP_ADM-C-11) is a senior,
experienced,
multi-disciplinary team that ensures work documents categorized
as high risk are comprehensive and thoroughly reviewed, including
contingency plans for emergent situations. The Joint Review Group
(JRG) performs a balanced review of high-hazard work evolutions to
ensure potential hazards are identified in various permits and
supporting documents and appropriate controls are incorporated into
technical work documents that direct the work. The JRG ensures the
five ISMS core functions have been adequately applied to the work
evolution under consideration.
• Behavior Based Safety (TFC-CHARTER-20) is a program that
involves conduct of
peer safety behavior observations resulting in immediate
feedback to help identify and extinguish at-risk work practices in
the tank farms, thus preventing injuries. This program is proactive
and provides positive reinforcement of good safety behaviors and
practices.
• Safety Culture Improvement (TFC-PLN-12) establishes and
defines the roles and
responsibilities assigned to the Safety Culture Monitoring Panel
and the Safety Culture Improvement Team. The Safety Culture
Monitoring Panel monitors inputs most indicative of the company’s
Safety Culture health to identify potential concerns in the work
environment that merit additional attention by the organization.
The Safety Culture Improvement Team provides safety culture inputs
to the Safety Culture Monitoring Panel.
• Lockout/Tagout Hazardous Energy Control Committee
(TFC-CHARTER-41)
functions to ensure the effective implementation of the Hanford
Site Lockout/Tagout program DOE-0336 in the servicing and
maintenance of machines and equipment in
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which unexpected energization, start up, or release of stored
energy could cause injury to employees.
• Plant Review Committee (TFC-ENG-SB-C-09) applies to multiple
committees
established for field operation organizations. Among other
duties, the Plant Review Committee (PRC) evaluates safety basis
related topics such as new information (e.g., potential inadequacy
in the safety analysis, safety basis amendments, justification for
continued operations) presented to the PRC by the USQ, evaluator,
Nuclear Safety engineer or designee.
• Chemical Vapor Solutions Team (TFC-CHARTER-21), which includes
Hanford
Atomic Metal Trades Council (HAMTC), professional, and
management representatives, is engaged in a collaborative effort to
increase and improve the flow of information to the workforce and
the public, including: (1) access to field data and sampling
results; (2) more complete information as to how WRPS protects
workers; (3) an explanation of technologies being developed and
tested in the field; and (4) expanded definitions and background on
a number of vapors-related topics.
The TOC participates in committees and boards sponsored by other
DOE or Hanford organizations. Participation on these committees and
boards facilitates information exchange, the development of common
approaches where appropriate and cost effective, and networking to
enhance functional area cooperation. These committees further
strengthen those internal to WRPS, while providing valuable
site-wide perspectives and sharing of lessons learned information.
The responsibility for determining participation is with the
appropriate TOC functional organization.
4.2 Guiding Principle 2 – Clear Roles and Responsibilities Roles
and responsibilities are defined by: (1) assignment within the
organization; and (2) the function or activity being performed,
which are contained in TOC policies and procedures such as the
institutionalized ISMS process, roles and responsibilities related
to company level, facility level, and activity level, with an
on-going iterative interaction between the management levels. The
process and relationship between WBS, OBS, and R2A2s at the company
level are described in TFC-CHARTER-01. Management and workers at
every level are responsible and accountable for understanding and
implementing established company standards for safety,
environmental protection, quality, and efficiency. Personnel are
accountable for their personal safety and the safety of their
peers, the public, and the environment. The “ISMS Expectations for
Implementation of the Integrated Safety Management System” were
communicated to the workforce, both formally and informally. These
expectations continue to be discussed and emphasized during formal
training, safety meetings, lessons learned reports, weekly
tailgates, employee performance management activities, all-employee
meetings, staff meetings, Conduct of Operations activities, My
Safety Focus Program, Anti-Harassment Training, Supervisory Skills,
Safety Culture program, Human Performance Improvement activities,
and VPP activities. Posters containing these expectations are
displayed throughout the various WRPS-controlled locations. The
annual performance appraisal process (TFC-BSM-HR_EP-C-01) provides
the mechanism for formal annual review. Positive recognition of
personnel accountability is applied when warranted, as is “Employee
Discipline” (TFC-BSM-HR_EP-C-02).
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Management at every level ensures that employees understand
their role in implementing these standards as an integral part of
meeting company objectives and customer expectations.
TFC-ESHQ-AP-C-03 provides interaction between management and the
workforce to assess and reinforce behaviors, knowledge, and
compliance with WRPS expectations, policies, and procedures. •
Workers are responsible for participating in the activity level of
each ISMS core
function. Workers from cross-disciplines are actively engaged in
work planning (TFC-OPS-MAINT-C-01); hazard identification and
control; work performance within the controls, including feedback
and continuous improvement (TFC-ESHQ-S_SAF-C-02); and stop work
responsibility (DOE-0343).
• Field Work Supervisors and Leads are responsible for directing
work activities and
managing safety culture. Their focus is on the activity level
for each ISMS core function. Field work supervisors and leads
participate in work planning, hazard identification and control,
work performance within the controls, and feedback and continuous
improvement.
• First Line Managers are responsible for ensuring that the work
environments created by
field work supervisors and leads are producing safe results that
support and advance company and customer objectives. Their focus is
on the activity and facility level for each ISMS core function.
First line managers also ensure company policies and procedures are
effectively implemented. These managers coordinate resources and
work activities with other organizations, provide technical
direction according to their qualification, provide direction for
work, and report work progress and the quality of performance.
• Mid-Level Managers (project, department, technical support)
are involved in providing
technical direction, resources, planning, reporting, personnel,
and issue management in support of specific projects and their WRPS
areas of responsibility. The managers’ focus is on the programmatic
and facility level, with support to senior management on
company-level matters. Managers ensure barriers affecting the safe
performance of work are addressed, and that activities support
established budgets, milestones, and customer expectations.
• Senior Managers are responsible for ensuring that company
standards are established
and implemented that meet customer expectations for executing
work in a safe, proper, and efficient manner. Their focus is on the
company level, with overall project and program management and
support to the customer. Senior management interfaces with the
customer, regulators, stakeholders, HAMTC, and the public on
company and project matters.
• The Project Manager (WRPS Company President and Chief
Executive Officer) is
responsible for the overall management and safe operation of the
TOC and is supported by the Work Area and Functional Senior
Managers.
• DOE-ORP interfaces with WRPS to ensure continued excellence in
mission execution
and ESH&Q management. ORP and WRPS senior managers
collaborate to clearly define company and project performance
expectations and priorities.
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4.3 Guiding Principle 3 – Competence Commensurate with
Responsibilities Workforce Resources, Organizational Performance
Improvement (OPI), and line management work together to ensure
qualified workers perform work safely using approved procedures.
The work to be performed by an organization is evaluated against
standards and requirements. Management determines the staffing
levels, training, and identifies the mix of knowledge, skills, and
abilities typically required for the organization’s positions. For
exempt and non-exempt positions, career matrices are established
that define position titles, minimum education and experience
requirements, and potential career progression. New and (or)
revised career matrices are generated as needed. Job applicants may
come from sources within or outside the company depending on the
specialization of the position. Individual training, education, and
experience of job applicants are evaluated before candidates are
considered qualified to fill a position (TFC-BSM-HR_EM-C-02).
Within the OPI organization, the Training organization supports
management in this activity by administering the training program
as established in the company-level management plan TFC-PLN-61.
This plan identifies the process to ensure employees are trained
and qualified to safely, competently, and effectively perform their
job functions. The Training organization works with line
organizations to develop the training to meet applicable
requirements and to maintain an electronic training database for
the implementation of training requirements and enhancements. The
electronic training database and the employee job task analysis
(EJTA) process (TFC-ESHQ-S_IH-C-17) assists managers in determining
the following: • Training requirements based on working conditions
(i.e., hazards to which the individual
will be exposed, such as bloodborne pathogens or heat
stress)
• Tasks the employees will perform (e.g., crane operations, lock
and tag)
• Requirements based on worker classification (e.g., field work
supervisors, radiological worker), and
• Technical staff position qualifications (e.g., Design
Authority, QA Engineer, Operations
Engineer). The systematic approach to training process is
required by DOE O 426.2 for positions identified in the Training
Implementation Matrix (TIM). This model applies the elements of
Analysis, Design, Development, Implementation, and Evaluation,
referred to as the ADDIE model. A graded approach is applied to the
degree necessary to ensure efficiency, but still adequately
transfers knowledge and skills to the workforce. The systematic
approach to training process may be applied to other training
programs as deemed necessary by line management, TOC training
management, and instructional staff (TFC-BSM-TQ_ADD-C-01). The TOC
has an approved TIM encompassing the tank farms, 242-A Evaporator,
and the 222-S Laboratory. The TIM identifies which DOE O 426.2
requirements are applicable and identify exceptions and
clarifications. The TIM is approved by DOE-ORP and became the only
contractually bounding DOE O 426.2 requirements for TOC and 222-S
Laboratory. The approved TIM for the TOC identifies operations and
support personnel who require a qualification program defined in
DOE O 426.2. Associated training program descriptions have
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been developed to establish standards for technical staff
positions requiring qualification and are located within Business
Services and ESH&Q procedures. Any person who performs or
observes work within a hazardous waste zone must have the necessary
training to enter TOC nuclear facilities via the Access Control
Entry System (ACES) (TFC-ESHQ-RP_ADM-C-15 or ATS-310, Section 1.5
for 222-S Laboratory). The process that assists managers in
determining necessary employee medical qualifications and
monitoring is the EJTA. The EJTA is the mechanism to obtain
necessary medical monitoring based on the individual’s job
requirements, hazards, exposures, and overall risk associated with
the assigned work scope. This process supports the collection of
data necessary for a risk-based approach to medical qualification
and monitoring. An EJTA is prepared for each employee
(TFC-ESHQ-S_IH-C-17), including subcontracted personnel when
required (TFC-BSM-CP_CPR-C-05).
4.4 Guiding Principle 4 – Balanced Priorities Through the WRPS
Project line organizations, resources are allocated to balance
ESH&Q, programmatic, and operational considerations. Through
the Earned Value Management System (EVMS), the Project Integration
support organization assists projects and their support functions
to generate risk-balanced schedule and resource plans. These
estimates are based upon anticipated uncertainty when budget and
upper-tier WBS decisions are made; work control processes provide
for uncertainty reduction as detailed planning progresses (e.g., by
early worker engagement and risk register development in
sub-projects). As efforts reach the stage of physical work in the
field, uncertainties are reduced to specific work controls that are
proportionate to the need based upon detailed work planning and
hazard analysis.
4.5 Guiding Principle 5 – Identification of Safety Standards and
Requirements TFC-PLN-100 is identified in the ORP-WRPS
Authorization Agreement (Correspondence No. 1800004) as the
mechanism for the flowdown of the TOC, including laws, regulations,
and DOE directives, into WRPS implementing policies, procedures,
plans, and other work control documents. For purposes of general
requirements, policies and plans describe work control processes
for each type of requirement source (i.e., among ESH&Q
upper-tier governing documents). Key specific procedures, such as
TFC-OPS-MAINT-C-01, detail how multi-disciplinary teams implement
the ISM Core Functions to identify hazard controls. In this
process, subject matter experts (SME) ensure that all applicable
requirements are incorporated into these work controls.
4.6 Guiding Principle 6 – Hazard Controls Tailored to the Work
Being Performed Tailoring of controls is conducted in accordance
with WRPS procedures for the implementation of the graded approach
(TFC-PLN-112). The variety of mission activities within the TOC
Projects result in work descriptions being at the upper levels of
the WBS; such descriptions typically describe outcomes or end-state
conditions with only limited identification of the specific
mechanisms used to achieve those states. Through the Project
Integration processes, project planning and other decision-making
processes are detailed and hazard analyzed to ensure they can be
accomplished with controls tailored to the actual work. An
important aspect of tailoring is identification of conservative
controls that reflect appropriate consideration of the residual
uncertainty that may be present when work is begun. Procedures such
as TFC-OPS-MAINT-C-01, DOE-0336, and TFC-ESHQ-S_SAF-C-02 detail how
multi-disciplinary
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teams implement the ISM Core Functions to assure hazard controls
are representative of actual work plans and anticipated
hazards.
4.7 Guiding Principle 7 – Operations Authorization At the
Contract business level in the TOC Project, work performance is
authorized in a top-to-bottom manner through the delegation of line
management responsibility to formulate plans, budgets, and
schedules for mission work. In keeping with the EVMS (TFC-PLN-147),
cost account managers are assigned duties for overseeing the
allocation of authorized resources as needed to conduct project
work safely. Through the facility and activity levels of control,
actions are subject to additional authorization points in
accordance with work release procedures and practices (TFC-PLN-05)
designed to ensure that the initial conditions, established by
field work control requirements (e.g., isolation of hazardous
energy sources) are in place in accordance with the associated
procedures. Operations shift management coordinates for assurance
that all applicable permits (e.g., Radiation Work Permits) are in
place and in conformance with pertinent procedures.
4.8 Core Function 1 – Define the Scope of Work Defining work
scope (see Figure 9) is a process in which DOE mission expectations
are defined, prioritized, and divided into discrete activities that
account for the associated hazards, requirements, controls, and
funding needed to complete the mission. DOE-ORP, as the facility
owner, defines the mission and requirements. The TOC establishes
the mechanisms for accomplishing the mission, to assign
responsibility, and to implement work priorities through
risk-informed planning for the effective and efficient use of
resources.
Figure 9. Define Work Scope. Sections 4.8.1 through 4.8.4
describe definition of work scope and balanced priorities primarily
at the company level as part of the TOC business, budget, and
contract process. Section 4.8.5 describes how this element is
accomplished at the facility/activity level.
Translate Mission into Work The processes, tools, and controls
used to translate the TOC lifecycle baseline into Contract period
plans and execution year work is described in TFC-PLN-147.
Execution year
work is captured and authorized by DOE-ORP for performance
through the WRPS Contract. Work is then performed in accordance
with the Contract and associated ESH&Q commitments and
performance objectives. The TOC lifecycle baseline is an integral
subset of the RPP integrated baseline, which describes the combined
activities of DOE-ORP, WTC, ASPC, and the TOC. The scope and
requirements of the TOC lifecycle baseline are described and
assigned
Applicable Guiding Principles
1. Line Management Responsibility 2. Clear Roles and
Responsibilities 3. Competence per Responsibilities 4. Balanced
Priorities
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through the RPP System Plan and the Contract. Scope and
requirements are then translated into a more specific scope,
schedule, and cost basis at the activity level and implemented
through the application of WRPS procedures. The current set of
plans and procedures used to define, schedule, resource load,
assess and mitigate risk, release, execute, and control changes to
the work are as listed below: • TFC-PLN-147 • TFC-BSM-CP_CPR-C-17 •
TFC-OPS-MAINT-C-01 • TFC-PLN-03 • TFC-PLN-39 • TFC-PLN-84
• TFC-PLN-102 • TFC-PLN-123 • TFC-PRJ-PC-C-02 • TFC-PRJ-PC-C-05
• TFC-PRJ-PC-C-12 • TFC-PRJ-PM-C-02
The processes described in these plans, including
multi-disciplinary teams comprised of technical, operational,
management, ESH&Q, customer representatives, and SME that
execute these processes, implement procedures. During this process,
these team members implement ISMS principles through the following:
• Clear definition of scope and technical requirements •
Identification of discrete activities and their potential hazards •
Scheduling activities in a safe and logical progression •
Estimating the resources required to successfully and safely
perform the work • Identifying and maintaining critical interface
agreements • Mitigation and control of identified risks and hazards
• Assignment and controlled release of the work for execution •
Safe performance of the work • Continuous feedback that leads to
changing how the work is performed with particular
attention to the potential for accumulation of risk through
multiple changes. In addition, control of safely configured
equipment, facilities, materials, qualified staff, and enabling
documentation required to execute mission work is described in
TFC-PLN-03.
Set Expectations The WBS development process establishes the
expectations for accomplishing work, prioritizing tasks, and
allocating resources. A hierarchy of mechanisms is used such that
each successive lower tier provides an increasing level of detail
on “what” work is to be performed and “how” integration occurs
(i.e., broad mission objectives are translated into discrete
tasks). Expectations are set by establishing performance
objectives, including ESH&Q performance, whereby cost and
schedule considerations can never override safety considerations
for the assigned work. The formality of these objectives depends on
the scope of work, its complexity, and the hazards associated with
the work.
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At the activity level, as stated in Section 4.2, “Guiding
Principle 2 – Clear Roles and Responsibilities,” employee
expectations are set annually and periodically reviewed.
Prioritize Tasks and Allocate Resources Potential hazards are
considered in prioritizing and scheduling work during the
integrated planning process (TFC-PLN-147) and work package
preparation (TFC-OPS-MAINT-C-01 and TFC-ESHQ-S_SAF-C-02). WRPS
maintains a Plan of the Day and Plan of the Week to manage
near-term work (TFC-OPS-OPER-C-65). Work scheduled beyond the Plan
of the Week timeframe is planned and scheduled in the Integrated
Management Meeting and other departmental scheduling meetings.
Subcontractor ISMS Flowdown The procurement process is described
in RPP-8411, “Procurement Process Description,” that defines an
integrated supply chain to consistently acquire the highest quality
and best value products and services while ensuring necessary
technical standards and requirements are met. The following
paragraphs describe the specific mechanisms by which WRPS ensures
flowdown of ISMS and performs oversight of subcontractor safety,
health, and quality work performance. Specific requirements for
subcontractors, including safety requirements, are documented
during the procurement process. Subcontracts are developed and
managed within two major categories: (1) products that include
materials, supplies, equipment and commercial items; and (2)
technical services obtained from subcontractors. These subcontracts
contain standard provisions and may include Special Provision 5
(Contract DE-AC27-08RV14800), which contains the ISMS DEAR Clause
970.5223-1 depending on the magnitude and complexity of the task
order. Regardless of the type of contract issued, each element of
work is issued to the subcontractor via a task order, which
includes a specific statement of work (SOW) governed by the
following procedures: • TFC-BSM-CP_CPR-C-05 • TFC-BSM-CP_CPR-C-06.
A Buyer’s Technical Representative (BTR) is assigned by the
requisitioning organization, activity, or cost account manager to a
task order to act as the day-to-day technical representative. The
primary duty of the BTR is to provide technical direction and
clarification to the subcontractor to ensure performance of all
elements in accordance with the SOW without placing emphasis on
schedule or cost to the detriment of quality, safety, or the
environment (TFC-BSM-CP_CPR-C-05). The BTR is responsible for
internal coordination of, and interface with, the subcontractor
regarding the various technical requirements such as quality
assurance, safety, health, security and emergency services,
protective forces, environmental, PAAA, and ISMS principles
applicable to the performance of the Contract pursuant to the TOC
implementing procedures. The TOC ESH&Q organizations provide
subcontractor management support to the BTR by: (1) communicating
requirements; and (2) performing assessments, inspections, and (or)
surveillances to ensure compliance (TFC-PLN-116). When applicable,
the task is evaluated against the approved safety basis in
accordance with TFC-ENG-SB-C-03.
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Facility/Activity Level For operational, maintenance, and
construction activities, the scope of authorized work is captured
on a schedule, is addressed at the plan-of-the-week meetings, and
is communicated during the plan-of-the-day meetings within the work
control process. Line supervisors and managers ensure activities
relating to ESH&Q issues (e.g., worker safety and health,
environmental compliance monitoring, waste management, safety
system operability, radiological control, and quality assurance)
are resource loaded by coordination with ESH&Q managers.
Operations personnel analyze facility and equipment conditions and
resources, and initiate actions to ensure activities significant to
ESH&Q are promptly resolved. Safety basis and environmental
basis controls, such as those specified in the TSRs and
environmental specification requirements, are monitored through
surveillance testing, equipment status control programs, and
operator rounds. At the individual task level, work control
processes, such as job hazard analyses and radiological work
permits, may be standing documents used for pre-defined standard
work scopes or may be job-specific. The work control processes use
face-to-face work planning engagement of workers, line management,
and the ESH&Q support personnel for higher risk or complex
work. A comprehensive work planning process is also used to involve
the workers in hazard identification. In this way, preparations are
identified to: (1) reduce the possibility of injury or exposure of
the worker and minimize the impact on the public and the
environment; and (2) ensure the work scope is properly defined.
This process works because of the worker engagement and attention
of personnel to each other’s safety needs as a result of the
ESH&Q training provided to the TOC workforce. The entire
process of defining and planning the work is improved through the
TOC Assessment program, which provides feedback to the planning
process. The scope of maintenance, operations, and construction
work is defined using the TOC work control process
(TFC-OPS-MAINT-C-01). The hazards are identified during the
planning stage using integrated work planning/review teams or job
hazard analyses/radiological work permits. The rigor or level of
work planning required (e.g., verbally directed, routine, planning
required, work planning with JRG review) is determined by initial
work screening. The required planning elements for conducting the
various levels of work planning are graded to the complexity of the
work, the hazards encountered in performing the work, and the
uncertainty about the work and hazards it entails.
4.9 Core Function 2 – (Identify and) Analyze Hazards Identifying
and analyzing potential hazards and environmental impacts is
important to ensuring hazards are adequately controlled and
requirements are met. Hazards and environmental impacts (e.g., tank
vapors or beryllium) are identified as part of baseline
development, a process that continues throughout the facility or
project lifecycle. Work performed as part of the mission is
evaluated against the bounding conditions of the safety basis. For
the TOC, hazard identification and analysis are defined at the
company level, but they are implemented at the facility and
activity level.
Applicable Guiding Principles
1. Line Management Responsibility 2. Clear Roles and
Responsibilities 3. Competence per Responsibilities
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The job hazard analyses process for identifying, evaluating,
controlling, and communicating potential hazards associated with
work performed by the TOC is described in TFC-ESHQ-S_SAF-C-02. This
procedure applies to all TOC work activities involving general
plant maintenance, building maintenance, construction, facility
operations, environmental remediation, subcontractors, and service
organizations. Job Hazard Analysis (JHA) within the work scope and
responsibility of other Hanford prime contractor service
organizations (e.g., Fire Systems Maintenance, Refrigerated
Equipment Service) are prepared in accordance with their work
processes as described by their work programs per contract with DOE
and as described in their approved ISMS descriptions. The GHA and
worker training and qualifications provide the worker with the
proper skills and abilities to perform routine work activities. If
work activities are covered by the GHA and performed using a
general Radiological Work Permit (RWP), for radiological work, no
additional hazard analysis is required. Work processes and hazard
identification and controls are integrated with HPI processes, and
the appropriate amount of rigor is applied to ensure resources are
concentrated on the critical tasks to be performed. Hazards,
error-likely situations, and error precursors that may be
associated with the critical tasks are identified (see Figure
10).
Figure 10. Identify Hazards.
At the activity level, the workers are trained to identify and
select the appropriate controls for a broad range of hazards that
may be encountered. These hazards and controls are provided in a
JHA checklist, which is a tool that reminds workers of the types of
hazards that may exist and the controls identified for mitigating
the hazards. The JHA is used by workers, supervisors, and SMEs
throughout the work processes. Additional requirements and special
controls are also included, such as the need for any special work
permits, checklists, or authorizations (TFC-ESHQ-S_SAF-C-02).
Technical procedures are developed for routine operations and
incorporate task specific hazard controls, as discussed in
TFC-OPS-OPER-C-13. For both new procedures and revisions, a JHA
walkdown is performed in accordance with TFC-ESHQ-S_SAF-C-02 by the
procedure writer, with hazard mitigation reviewed by personnel such
as the procedure user and representatives from Operations,
Environmental, Radiological Control, Industrial Safety, and
Industrial Hygiene. Hazards and hazard controls are subsequently
validated during the procedure validation walkdown. The process to
develop, implement, and maintain the primary facility safety basis
is contained in TFC-ENG-SB-C-06 and TFC-ENG-SB-C-01. Similarly, the
TOC environmental basis is administratively implemented by
TFC-PLN-123. Projects are designed using an iterative process
focused on enabling assumptions, risk management, and decision
analysis. TFC-PRJ-PM-C-02 addresses construction projects.
TFC-ESHQ-RP-STD-03 addresses radiological aspects of new designs.
Multi-disciplinary design
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review teams help identify and resolve design and lifecycle
issues for their respective disciplines. This activity is
coordinated with hazard identification and analyses. Identified
hazards are mitigated by design or engineered controls as part of
the design process. Analysis of facility hazards, environmental
impacts, and job hazards is an essential process for ensuring that
construction and facility operations and maintenance are conducted
in a safe and environmentally protective manner. Facility hazard
analyses provide for the development of facility-specific controls
to protect workers, the public, and the environment. The JHA
process identifies hazards (facility and activity specific) to
establish effective work controls and provide for safe performance
of work. Hazard and environmental impact identification and
analyses are performed per TFC-ESHQ-S_SAF-C-02. For Level 1 work
packages (ref. TFC-OPS-MAINT-C-01), new technical procedures, or
major revisions to technical procedures (ref. TFC-OPS-OPER-C-13), a
walkdown of the job site with the supervisor is performed to
identify potential hazards relating to tasks to be performed. The
supervisor ensures engagement by the worker representative(s).
These may include Industrial Safety, Industrial Hygiene, Health
Physics Technician, Environmental Representative, and other SMEs,
as determined necessary by the planner/procedure writer and
supervisor. Work activities classified as high risk receive review
by the JRG to ensure that relevant work documents are
comprehensively and thoroughly reviewed, including contingency
plans for emergent situations (TFC-ESHQ-RP_ADM-C-11). This review
of work activities is meant to be independent upon the mechanism
(e.g., work instructions, procedures, work plans, etc.) used to
control the process. Bargaining unit personnel engaged in the JRG
are expected to provide additional information, as needed,
regarding work planning assumptions and workability of the work
documentation. From a worker’s standpoint, bargaining unit
personnel also ensure work documentation adequately addresses job
hazards. A table-top discussion performed in lieu of a required
field walkdown, as noted above, requires approval of the
responsible Level 2 manager. For activities conducted by the TOC,
site-specific environmental impact statements, environmental
analyses, applicable supplemental analyses, and approved site-wide
categorical exclusions are prepared under the National
Environmental Policy Administration (NEPA).
Identify the Hazards WRPS’ EMS (