The Safety Basis and Documented Safety Analysis Rule contained in 10 CFR 830, Nuclear Safety Management, requires that Department of Energy (DOE) contractors and operators establish and maintain a safety basis for DOE-STD-1027-92 Hazard Category 1, 2, and 3 nuclear facilities. In establishing the safety basis for a nuclear facility, Subpart B of the rule describes how the responsible contractor must prepare a Documented Safety Analysis (DSA) that in part: 1) describes the facility, activities, and operations, 2) systematically identifies hazards, 3) evaluates normal, abnormal, and accident conditions, and 4) derives hazard controls to provide an adequate level of safety to the public, workers and the environment.
ATL Hands-On Safety Basis and DSA Experience The best way to illustrate ATL’s ability to support safety basis reviews and DSAs is through a description of some of our relevant experience. ATL assisted in the development of the Los Alamos National Laboratory’s SAR/Technical Safety Requirements (TSRs) review checklist (OST-300-00-06F) and assisted the Safety Basis Office in the independent review of DSAs. ATL participated in 39 reviews of a wide range of nuclear and non-nuclear LANL facilities, including the following categories:
These reviews were conducted by an expert team with extensive knowledge of DOE’s nuclear safety requirements, the history of their evolution, and current interpretations by the DOE HSS headquarters personnel. As a result, our reviews reflect current DOE thinking on the implementation of 10 CFR 830.
As we did for LANL, ATL can assemble a multi-disciplinary team of experts to cover any aspect and type of DOE facility. The team would include Subject Matter Experts (SMEs) in nuclear safety analysis, criticality safety analysis, systems safety, fire safety, natural phenomena, transportation, industrial hygiene, health physics, and quality assurance. Our review process includes considerable interaction between members so their expertise can be amplified. These reviews are accomplished by an analysis of all the key requirements for a DOE DSA, such as an evaluation of the methodology used, hazard identification, selection of facility hazard category, hazards evaluation, accident selection, accident analysis, selection of safety Structures, Systems, and Components (SSCs), and derivation and selection of Technical Safety Requirements.
ATL has completed the following LANL Project Authorization Basis Reviews:
Several facilities were reviewed at the 30%, 70% and 100% stages during the completion of the Authorization Basis documents.
For another project at LANL, ATL provided expert technical consulting services to address LANL’s integrated safety system, operational readiness review, safety documentation, authorization basis, and FSAR/TSAR/AC, safety and hygiene, fire protection engineering, waste management/environmental compliance, and the conduct of operations. ATL’s work included support of operability assessments, and the development and implementation of corrective action plans. ATL’s operational assistance and mentoring support include the following areas: quality management systems, safety systems, facility safety basis, work authorization, work control, conduction of operations, regulatory compliance, and waste management programs.
ATL complied with specific Environmental, Safety, and Health and Pollution Prevention and Waste Management requirements and standards for the evaluation associated with upgrades to several facilities, including TA-55, TA-18, Weapons Engineering Tritium Facility (WETF), Sigma, Chemistry and Metallurgy Research (CMR), and Capability and Maintenance Improvement Project (CMIP). This was required to maintain nuclear components and processes at LANL, including pit fabrication, and increased their capability for Department of Defense (DoD) delivery orders for nuclear warheads. Under this contract, ATL supported readiness assessments, operational readiness reviews, performance assurance, corrective action planning and implementation assurance. We also assisted in the review of program management processes, including the DNFSB - LANL institutional interface, prioritization of activities, and problem resolution.
ATL’s support to facility operators for Nuclear Materials and Stockpile Management (NMSM) allowed them to resume all activities that were in a shutdown mode. ATL performed operability assessments, which included tabletop and performance-based assessments, against existing objectives and criteria to improve the formality of operational programs at each facility. ATL supported the NMSM Program Office and Facility Management by mentoring facility personnel, developing procedures, implementing ISM, resolving Unresolved Safety Questions (USQs), and developing quality management system tools, performance measures, and corrective actions.
Radioactive Waste Management and Operational Safety Technical Support ATL developed a preliminary set of criteria for cost recovery options for the deactivation of actinide-beryllium neutron sources from commercial licensees. ATL developed criteria to implement LANL’s cost recovery of programmatic funds transferred within the DOE complex for the deactivation of DOE-owned actinide-beryllium neutron sources. In addition, ATL helped LANL personnel investigate options for off-site source preparation, batching, and shipping consolidation procedures.
Operational Readiness Reviews ATL can mobilize a highly qualified team of assessors to support a wide range of tasks — including multidisciplinary teams to complete Operational Readiness Reviews (ORR) and Readiness Assessments (RA). ATL is knowledgeable and experienced in the implementation of the principles of DOE Order 425.1 Startup and Restart of Nuclear Facilities, as well as DOE’s Integrated Safety Management System and Authorization Basis Rule. ATL understands how to conduct or assess ORRs/RAs for complex systems and processes, starting with the basics of how the process should transition from construction to operations in a disciplined and structured way. We ensure that the systems, people, and processes required for safe and compliant operations are ready to bring the operation to life.
ORRs verify the following:
ATL staff includes several individuals with direct DOE experience in conducting, reviewing, and providing training for ORRs and RAs. For example, one ATL staff member provided ORR/RA training throughout the DOE complex and another conducted ORRs at several DOE EM sites. Our ORR/RA approach, which can be applied to many types of facilities, includes the following steps:
Preparation for a readiness review relies on establishing a partnership between operators and the support organizations that provide subject matter expertise (SME). The primary activities ATL performs include: procedural validation using dry runs, maintenance activity validations, and verification that the system meets authorization basis requirements, and the assurance of operator familiarity and qualification. Operator qualification is achieved, in part, by performing drills involving simulated system or process upsets which provide operators with experience responding to these conditions in a realistic environment.
Prior to declaring readiness, ATL evaluates all support processes for compliance with DOE requirements. Assessments are conducted to verify training, quality assurance, radiation protection, industrial and nuclear safety, maintenance, conduct of operations, environmental compliance, etc. to confirm that they are fully ready to support operations. Readiness to operate is declared when the assessments have been completed and deficiencies resolved.
In other work, ATL has provided independent assessments of nuclear safety readiness for the Fernald Closure Project in compliance with DOE 10 CFR 830. ATL prepared Health and Safety Plans for the Fernald Closure Project that included both DOE Nuclear Safety and OSHA Worker Safety requirements. In addition, ATL provided independent review of DSAs for several LANL nuclear facilities including critical transuranic waste processing, characterization, and storage; plutonium laboratories; as well as other, non-nuclear facilities.
