Integrated Safety Management System Description TFC-PLN-41 ... · TFC-PLN-41, REV A-4 Page 5 of 56 January 18, 2018 The scope of this document includes the Environmental Management

Integrated Safety Management System Description

Manual Document Page Issue Date

Management Plan TFC-PLN-41, REV A-4

Page 1 of 56 January 18, 2018

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

http://toc.wrps.rl.gov/rapidweb/PRO/index.cfm?pageNum=232





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 ................................................................ 55





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





• 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)





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”





• 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.





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





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





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





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





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





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





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.





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.





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





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.





• 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





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





“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.





• 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





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).





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.





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





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





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





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.





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.





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.


1. Line Management Responsibility 2. Clear Roles and Responsibilities 3. Competence per Responsibilities





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





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 (TFC-PLN-123) and Authorization Agreement (Correspondence No. 1800004) require identification of hazards to the workers, public, and the environment, as described in DOE G 450.4-1B Volume 1, DOE O 436.1, and ISO 14001. 4.9.1.1 Workers Line, safety, industrial hygiene, environmental, and radiological control personnel jointly review planned higher-risk work, identify radioactive and chemical material inventories, and identify potential hazards (TFC-ESHQ-S_SAF-C-02). The WRPS JHA Checklist is applied as a tool to identify specific hazards and safety work requirements. For lower-risk work, workers, supervisors and appropriate SMEs review and approve identification of hazards (TFC-OPS-MAINT-C-01 and TFC-ESHQ-S_SAF-C-02) and assist with the preparation of work documents.





Various factors are considered in determining the level of planning and work package assembly required (TFC-OPS-MAINT-C-01). To assure comprehensive assessment of hazards and other work control difficulties, the determination of the composition of the planning team and the level of detail required for a given work package considers the following: • Nuclear, radiological, and industrial safety significance of the task • Complexity of the task • Human factors and performance considerations • Skill and experience of the workers. TFC-OPS-MAINT-STD-02 may also be referenced to assist in determining the level of planning required in support of implementation of TFC-OPS-MAINT-C-01. Workers are also engaged in job planning, pre-job walkdowns, and post-job critiques. Workers are made aware of chemical inventories and the proper use of chemicals through the mechanisms described in TFC-PLN-47, administrative procedures (TFC-ESHQ-S_IH-C-02 and TFC-ESHQ-S_IH-C-47), and communications from line management. The EJTA is used to assess work-place hazards and provide data to determine appropriate levels of medical monitoring (TFC-ESHQ-S_IH-C-17). The JHA process is used to identify hazards at the activity level. It is line management’s responsibility to ensure that employee involvement and the appropriate participation of other support personnel are included in the planning process. Craft and field work supervisors shall agree that work is within the crafts’ skill base and that general hazards analysis is all that is required (TFC-OPS-MAINT-C-01, TFC-OPS-MAINT-STD-02, and TFC-ESHQ-S_SAF-C-02). When drafting and verifying a new technical procedure or revision, the initial draft outline is reviewed to incorporate necessary control and (or) hazard mitigation in accordance with TFC-OPS-OPER-C-13. Representation from the Environmental Management, Radiological Control, Industrial Safety, and Industrial Hygiene organizations are involved in the review of hazard identification and mitigation content (for example, tank vapors or beryllium). 4.9.1.2 Public From the Safety Basis perspective, hazards are identified (TFC-ENG-SB-C-06) to determine the facility hazard category, which in turn determines the type of formal safety analysis to be performed. Line management uses characterization of potential hazards for developing facility design and operating features, procedures, controls, scope, and schedule for work performance. Generally, a combination of process (e.g., system) analysis and JHA is employed to identify and characterize hazards. Based on this information, hazards (or safety) analyses are performed as described in the next section. 4.9.1.3 Environment Identification of these hazards supports determination of the necessary NEPA and environmental permitting documentation. The Environmental Protection organization applies a systematic approach to identify all applicable environmental requirements to facilitate protective provisions in specific work control procedures and practices. At the project level, identification of environmental hazards is directed by TFC-PLN-84 and TFC-PRJ-PM-C-02, which incorporate support from the Environmental Protection organization and assign responsibility to determine the necessary environmental documentation.





Analyze the Hazards

4.9.2.1 Workers A team planning process is used for high-risk and complex work (TFC-OPS-MAINT-C-01 and TFC-ESHQ-S_SAF-C-02). The size of the team is determined by the complexity and anticipated hazards associated with the work. Workers and line managers are engaged to plan the work and establish appropriate processes to perform the work. Identification and mitigation of hazards (radiological safety, industrial safety, fire protection, chemicals, occupational health, industrial hygiene) associated with the work are accomplished using the JHA process. The JHA and work control process, combined with processes such as safety council facility walk downs and peer safety observation, are used to obtain worker engagement in hazard identification and analysis at the facility and activity levels. This process ensures that: (1) work planning activities reflect actual field conditions; and (2) knowledge of the facility and (or) activity and experience of the workers is fully applied. For work involving hazardous chemicals, workers, analysts, and line management determine the hazards associated with chemicals during the purchasing, use, storage, transportation, and final disposal. Radiological hazards are identified and evaluated during the work screening process using the following plans and procedures: • TFC-PLN-58 • TFC-PLN-34 • TFC-ESHQ-S_IH-C-02 • TFC-ESHQ-S_IH-C-47 • TFC-ESHQ-RP_RWP-C-01 • TFC-ESHQ-RP_RWP-C-03 • TFC-ESHQ-RP_RWP-C-04 Work that is the responsibility of the TOC but performed by subcontractors is managed in a similar manner. Hazards identification and analysis of work performed by subcontractors is managed by the BTR who administers the terms and conditions of the contract (TFC-BSM-CP_CPR-C-05). 4.9.2.2 Public From the Safety Basis perspective, hazard and accident analyses evaluate hazards, including natural phenomena that result in the uncontrolled release of radioactive or hazardous material that may affect the workers, the public, or the environment. The identification, evaluation, and control of nuclear safety risks associated with TOC facilities are performed per the process hazards analysis process defined in TFC-ENG-DESIGN-C-47. Radiological and hazardous material inventories, facility processes, and planned operations, in part, determine the severity of facility hazards and the need for TSR controls. The Nuclear Safety organization manages the process hazards analysis process. The greatest rigor is applied to nuclear facilities. For nuclear facilities, hazard analyses evaluate hazards associated with the construction, modification, and operation of the facility. The results

Applicable Guiding Principles 1. Line Management Responsibility 2. Clear Roles and Responsibilities 3. Competence per Responsibilities 5. Identification of Safety Standards and

Requirements 6. Hazard Controls Tailored to Work Being

Performed





of these analyses are documented in safety analysis reports (TFC-ENG-SB-C-01, TFC-ENG-SB-C-06). For tank farms, the results are documented in RPP-13033, “Tank Farms Documented Safety Analysis,” or other safety basis documentation as identified on the WRPS Safety Basis web site. For the 242-A Evaporator, the results are documented in HNF-14755; for the 222-S Laboratory, the results are documented in HNF-12125. 4.9.2.3 Environment Analysis of hazards to public health, cultural and natural resources, and the environment is driven by processes described in project documents such as TFC-PLN-84 and TFC-PRJ-PM-C-02. The hazards analysis process follows guidance provided in TFC-OPS-MAINT-C-01 and TFC-PLN-123.

Categorize the Hazards At the facility or project level, WRPS uses the results of the hazards analyses performed under guidance from TFC-PRJ-PM-C-02 to determine whether existing NEPA documentation and environmental permits adequately address the identified hazards to the public, cultural and natural resources, and the environment. At the facility or project level, the final hazard category is determined as described in TFC-ENG-SB-C-06. The hazard categorization is documented in the DSA or other safety basis documentation contained on the WRPS Safety Basis web site. At the activity level, work is categorized based on risk and complexity as defined in the applicable work control procedure (TFC-OPS-MAINT-C-01). Work categorization sets the level of management rigor required for planning and authorizing work. The hazard and urgency of proceeding with work is specifically considered in work planning. The work prioritization process has bins for addressing a range of hazard priorities, from high-level emergencies to less pressing outage work.

4.10 Core Function 3 – Develop and Implement Hazard Controls

Identify Standards and Requirements In accordance with DEAR 970.5204-2, WRPS is responsible for compliance with standards and requirements applicable to tank farms. Requirements are diverse, derived from multiple sources, and captured in many different forms. Requirements are extracted from approved documents issued for action (e.g., contracts, statutes, regulations, applicable DOE Orders, consent agreements, and permits). An integral component of the Authorization Agreement, the TOC Requirements Basis, consists of the WRPS requirements in the Contract (DE-AC27-08RV14800, as amended). All limitations, controls, regulatory constraints, and assumptions or commitments listed in the Contract are contractually binding. Inclusion of the contract requirements in the Authorization Basis also makes compliance a condition of operation. WRPS performs work under a procedure-based system that implements the Contract requirements. Interpretive authorities manage configuration control of requirements into procedures. Facility experts ensure procedure revisions do not affect the implementation of the requirements. Review and sign-off of procedures ensure traceability between the procedures and the requirements.





Engineering requirements are contained in TFC-PLN-03, which defines the technical baseline (products, processes, structures, systems, and components). ESH&Q requirements are conveyed to subcontractors through contracts and task order agreements. Specific requirements for subcontractors are established during the procurement process as specified in TFC-BSM-CP_CPR-C-05 and TFC-BSM-CP_CPR-C-06. When subcontractors are used to perform work activities, the BTR designated to manage subcontractor performance to the contract language monitors compliance to requirements (TFC-BSM-CP_CPR-C-05).

Identify and Implement Controls to Prevent/Mitigate Hazards The Radiological Control organization reviews proposed work activities and confirms that the work can be accomplished under HNF-MP-5184, “Washington River Protection Solutions LLC Radiation Protection Program,” and HNF-5183, “Tank Farm Radiological Control Manual.” Controls necessary to maintain radiological exposures as low as reasonably achievable (ALARA) and contain radioactive materials are developed and inserted into work control documents, governing radiological work permits, and other supporting technical and (or) administrative procedures. Field work practices are monitored for compliance with prescribed controls and limits. If unexpected radiological conditions are encountered outside the boundaries of planned safe conditions, work is stopped and placed in a safe condition. An in-process ALARA review might then be performed to ensure the work can proceed safely. See Figure 11.

Figure 11. Hazard Control. At the company level, the Authorization Agreement establishes the limits of safe operation for WRPS activities. These limits are based on documented design limitations, controls, regulatory constraints, and assumptions or commitments that are required and based on identified hazards and environmental impacts associated with WRPS facilities and operations. The Authorization Agreement (Correspondence No. 1800004) addresses items of significant importance in establishing and supporting the Authorization Agreement and serves as the mechanism whereby DOE-ORP and WRPS jointly clarify and agree to key

terms and conditions (controls and commitments) for conducting RPP activities safely and efficiently. The Authorization Agreement (Correspondence No. 1800004) states: “Managing, operating, constructing, and performing work within the Authorization Basis is required.” The Authorization Basis has three integral components, as outlined below: • The safety basis • The requirements basis





• The environmental basis. The requirements basis is discussed in Section 4.6.1; discussion of the safety basis and the environmental basis is provided in the following paragraphs. The Nuclear Safety organization manages the safety basis, which includes the DSAs, and TSRs for the tank farms, the 242-A Evaporator, and the 222-S Laboratory. The DSA documents the analyses that identify the radiological and toxicological hazards to facility workers, onsite workers, and the offsite public for the respective facility. The DSAs also describe the significant features or programs that are employed to prevent or mitigate these hazards. The TSRs define the specific controls, both equipment and programmatic, that prevent or mitigate the DSA-identified hazards and thereby ensure safe operation of the respective facility. The DSAs and TSRs for WRPS operated facilities are shown below: • RPP-13033, “Tank Farms Documented Safety Analysis” • HNF-SD-WM-TSR-006, “Tank Farms Technical Safety Requirements” • HNF-14755, “242-A Evaporator Documented Safety Analysis” • HNF-15279, “242-A Evaporator Technical Safety Requirements” • HNF-12125, “222-S Laboratory Documented Safety Analysis” • HNF-14733, “222-S Laboratory Technical Safety Requirements.” The Nuclear Safety organization updates the safety basis as necessary to reflect facility modifications or changes in mission or operations (TFC-ENG-SB-C-01). The Nuclear Safety organization also manages the USQ process. Proposed changes to the facility or operations are evaluated through the USQ process defined in TFC-ENG-SB-C-03 to determine whether the changes require DOE-ORP approval prior to implementation of the changes. The DSA is updated annually to reflect facility modifications or changes in mission or operations made without prior DOE-ORP approval, in accordance with the USQ process, and submitted to DOE-ORP for approval. Note that the USQ process is not used for changes to the TSRs because all changes to the TSRs require prior DOE-ORP approval. A hierarchy of control preference is used for the development of safety basis controls and proceeds as follows: • Preventive controls over mitigative controls • Passive controls over active controls • Engineering controls over administrative controls • Controls with the highest reliability • Controls closest to the hazard. Implementation and maintenance costs are also considered as part of control selection. Schedule impacts are not typically considered in selecting controls during the control decision process. Safety basis controls are implemented at the facility level through procedures (e.g., operating procedures, functional test procedures), which ensure compliance with the TSR (TFC-OPS-OPER-C-02). For tank farms, HNF-IP-1266, “Tank Farm Operations Administrative Controls,” provides additional information on the implementation of the administrative controls. The nuclear criticality safety program, described in TFC-PLN-49 and also managed by the Nuclear Safety organization, is one of the safety management programs required by the DSA. The program ensures that fissile material operations in the tank farm facilities will remain safely subcritical under normal and credible abnormal conditions. The program requires that operations





involving fissile materials have criticality safety evaluations, which are prepared according to TFC-ENG-CHEM-P-04 to identify any criticality safety controls necessary to ensure safety. The criticality safety controls are implemented in various documents that control work activities, such as HNF-SD-WM-OCD-015, “Tank Farms Waste Transfer Compatibility Program.” Proposed changes to the facility operation are evaluated for impact/coverage by the safety basis using the USQ process (TFC-ENG-SB-C-03). For work that affects facility systems, structures, or components, a TOC Design Authority evaluates proposed activities to ensure the changes are covered by the facility technical baseline and the safety basis document. Another important element of controls is the development and implementation of appropriate emergency management systems and plans for the facility or an individual. The emergency management program (TFC-ESHQ-EP-C-01) uses facility hazards and environmental impact analyses as a technical basis for planning emergency response training, drills, and exercises; emergency procedures are developed to mitigate and control hazards. The extent of emergency planning and preparedness performed directly corresponds to the type and scope of hazards, the environmental impacts present, and the potential consequences of events. The emergency management program also addresses the potential for off-site impact of planned/changing operations by comparing changing facility mission and lifecycle conditions against approved facility emergency management hazards assessment and emergency action levels. Appropriate emergency action level changes are made as a result of that review, which is performed annually or following a significant change in a facility process. At the activity level, the procedure-based work control system provides defense-in-depth for work to be accomplished using the work control process through a hierarchy of analyses and documentation. In development and control of the safety basis, the hazard/safety analysis leads to TSR controls that are applied to managing work within acceptable bounds. These include administrative controls that are described in more detail in HNF-IP-1266. Radiological controls, new engineered controls, and permits are identified and specified in the JHA. Personnel are briefed on hazards and controls prior to performing work (TFC-OPS-MAINT-C-02). TFC-PLN-123 describes the WRPS Environmental Protection organization and the programs it implements. This document describes the organization’s structure, lists key roles and responsibilities, and describes how the Environmental Protection organization implements its charters within the overarching structure of the WRPS ISMS. TFC-PLN-123, TFC-PLN-125, and TFC-POL-30 also discuss Environmental Programs in a way that matches the EMS implementing structure identified in guidance for DOE O 436.1. These documents describe how the environmental programs are integrated into the ISMS as part of the EMS. Associated EMS implementing documents are identified in TFC-PLN-123. All responsible organizations ensure that required environmental controls are identified and implemented by: (1) developing procedures and standards to drive implementation of the requirements; (2) providing SME support to projects; (3) reviewing proposed work against applicable requirements; (4) generating appropriate permit applications; (5) providing SME support to the activity-level work control process, where work packages are screened and approved; (6) supporting incorporation of appropriate environmental controls in work control procedures; (7) supporting field work activities; (8) flow down of appropriate requirements to subcontractors; and (9) surveillance, inspection, and assessment. The Waste Services group manages the TOC solid waste, provides transportation and packaging services, and administers waste minimization programs support services. The program includes transportation/packaging and the waste minimization program. The group ensures these activities





are carried out in a manner that protects human health, the worker, and the environment; and meets applicable federal, state, and local regulatory requirements. ISMS implementing Waste Services procedures include the following: • TFC-PLN-33 • TFC-OPS-WM-C-01 • TFC-OPS-WM-C-10 • TO-100-052 • Waste Services Records Material Controls Worksheets. Controls specific to hazard and risk are developed during the planning process and incorporated into the governing work control documents and permits. Mechanisms used to manage changes in key processes are described in procedures that address the items listed below: • Preparing operating specification documents (TFC-ENG-CHEM-P-14) • Using temporary modifications or bypasses of equipment (TFC-OPS-OPER-C-11) • Replacing equipment in safety class/safety significant systems

(TFC-ENG-DESIGN-C-15) • Addressing USQs (TFC-ENG-SB-C-03) • Preparing and using Operations and Maintenance procedures (TFC-OPS-OPER-C-13). As determined by the risk and (or) complexity of the work, work planning is performed using a “team” approach. Management ensures that the team includes an appropriate mix of worker expertise and ESH&Q professional support. The team reviews planned work and develops necessary controls for the work hazards. Field work supervisors confirm that designated work controls are included in the work package. The team approach uses a multi-disciplinary team to walk down a proposed work activity, to evaluate the hazards, and to confirm that the controls are in place. Through the JHA, controls, work permits, and work instructions (e.g., lockout/tagout, fall protection, confined space, or hoisting and rigging) are documented for work media (TFC-OPS-MAINT-C-01) and are communicated to the work force (TFC-OPS-MAINT-C-02). The Procedure process (development, verification, validation, and approval) uses a team approach that includes an appropriate mix of worker expertise, field work supervisor, Engineering, and SMEs (e.g., Radiological Control, Environmental, Safety, and Criticality Safety). Throughout the process, HPI concepts and philosophies are used to increase error prevention; hazards are evaluated and necessary controls are implemented to mitigate any identified work hazards. TFC-PLN-58 controls chemical exposure hazards. A two-pronged strategy is used to reduce potential risks to the work force. American Industrial Hygiene Association (AIHA) guidance and WRPS Industrial Hygiene program documents and procedures are used to resolve characterization and exposure uncertainties in parallel with engineering upgrades intended to reduce potential exposures and limit the need for personal protective equipment. AIHA guidance to resolve uncertainties will be applied on a work area or tank farm basis. Work permits are used to ensure that identified hazard controls are in place and used when performing work (e.g., excavation permits, asbestos work permits, core drilling/tie-in permits, hot





work permits, energized electrical work permits, confined space permits, Hanford Site oversize/overweight permits, Fire Marshal permits, non-emergency hydrant tie-in permits, and radiological work permits). The effectiveness of design, engineered, administrative, and personal protective equipment controls are confirmed through exposure monitoring during performance of work. Medical monitoring is also performed. Prior to work, individuals are evaluated and appropriate medical qualifications and monitoring are initiated based on workplace standards. HPMC Occupational Medical Services ensures that Hanford Site workers receive appropriate medical qualification, monitoring and related occupational medical services. This process includes use of the EJTA, which is the primary mechanism used to ensure that personnel have appropriate medical qualifications and medical monitoring based on assigned job functions and hazards. The EJTA, in conjunction with exposure monitoring, provides the primary data input components for occupational health (TFC-PLN-34). HPMC effectively supports pre-placement, periodic, return-to-work, and termination health examinations. An EJTA is completed for each employee and the adequacy of hazard controls is assessed when medical monitoring results indicate adverse health consequences to workers. EJTAs are prepared for subcontractors when hazards are identified in the statement of work (TFC-BSM-CP_CPR-C-05 and TFC-ESHQ-S_IH-C-17).

4.11 Core Function 4 – Perform Work Within Controls The Contract and the Authorization Agreement (Correspondence No. 1800004) provide WRPS legal authority to plan and conduct work at the Tank Farms. Such work includes construction, operation, maintenance, laboratory analysis, and modification of facilities. It also includes a broad scope of activities such as studies, planning, engineering, design, waste packaging, and environmental sampling. The safety controls for work are derived from laws, regulations, DOE Orders, and other standards invoked in the Contract and hazard analysis performed and implemented in the company, facility, and activity level procedures (e.g., DOE-0336 or DOE-0359, which govern lockout/tagout and control of hazardous energy, respectively). At the activity level, TFC-OPS-MAINT-C-01 defines work management from initiation of a work request through work order closeout. Field work supervisor, shift manager, worker, and Senior Supervisory Watch (if necessary) responsibilities are delineated, including conduct of a pre-job briefing, in accordance with the expectations of TFC-OPS-MAINT-C-02. See Figure 12.


1. Line Management Responsibility 2. Clear Roles and Responsibilities 3. Competence per Responsibilities 7. Operations Authorization





Figure 12. Perform Work.

Operational activities are conducted in accordance with the facility conduct of operations program that ensures operations are managed, organized, and conducted in a manner that results in a high level of performance and, therefore, contributes to safe and reliable operations. Conduct of operations is implemented using thorough and clear procedures based on requirements contained in DOE O 422.1, “Conduct of Operations,” and are outlined in TFC-PLN-05. The process requires that roles and responsibilities are clearly defined, adequate training is provided, and procedures are followed. Operation controls include

controls used during planning to address ESH&Q issues and hazards, and procedural controls used during implementation. Maintenance activities are conducted in accordance with the facility maintenance program that ensures systems are returned to operable status and maintenance activities are performed as intended and when needed (TFC-PLN-29). Construction activities are conducted in accordance with the facility construction program, TFC-PRJ-CM-C-01. TFC-PLN-84 and TFC-PRJ-PM-C-02 provide an overview of the scope, responsibilities, and processes used to manage projects. Work planning, authorization, and conduct for work performed in general purpose facilities managed and performed by WRPS are outlined in TFC-OPS-MAINT-C-01. Depending on the type of work involved, the field activity is performed by either HAMTC craft personnel, outside contractors (for equipment covered by a warranty or a service contract), other Hanford Contractors, or is subcontracted by the Construction organization for work screened as falling under the Davis-Bacon Act (TFC-BSM-HR_EM-C-05). The following sections further describe company-level implementation, as well as facility- and activity-level implementation relative to the areas of confirmation of readiness, operations authorization, and performing work safely.

Confirm Readiness The TOC has readiness review processes that verify the readiness of facilities, processes, or projects (TFC-PLN-16). Each process confirms that hazards to the worker, the public, and the environment are identified, mitigated, or eliminated; that requirements are met; and that work is ready to be performed safely within the established controls. The formality and degree to which work is proceduralized and that direct worker supervision at the activity-level are based on the type and magnitude of hazards, the degree to which hazards are known, the strength of the controls selected, the complexity of the work, and the worker’s knowledge and qualifications.





The type of review needed to validate readiness is justified in the Startup Notification Report sent to DOE for approval. During conceptual design, decisions are made regarding the safety classification of components and the interfaces with existing systems/facilities/processes. The disruptions or differences made to existing systems/facilities/processes or their interfaces are considered when determining the type of readiness reviews required by DOE O 425.1D, “Verification of Readiness to Start Up or Restart Nuclear Facilities.” As the project progresses, certifications of work completed are assembled as objective evidence of the quality, and thus the pedigree, of the system. This documentation becomes the framework for establishing that the required actions were taken during the construction and testing phases of the project. This documentation also becomes the basis for the operating procedures developed to safely conduct the necessary operations of the facilities, activities, or operations and on which the qualification of the operators will be established. The responsible manager prepares a plan of action specifying the scope or breadth of the required review and transmits it to DOE for approval. From the plan of action, an implementation plan is derived specifying the depth of the review based on the plan of action’s defined breadth. Combining the breadth of the review with the depth of review describes the scope of the review. The objective evidence of the readiness process is evaluated through a management self-assessment conducted by line management responsible for the operation of the facilities, activities, or operations. During the assessment, management reviews observations of normal operations; operations with upset; and documentation of the planning, procedures, and qualifications of those involved in the operations. Upon completion of the management self-assessment process and correction of significant identified safety, operational, and Authorization Agreement (Correspondence No. 1800004) implementation weaknesses, management declares the facilities, activities, or operations ready for operations. An independent team, with no line responsibility for the facilities, activities, or operations on which the review is performed, then validates management’s declaration of readiness. This review is either an Operational Readiness Review or a Readiness Assessment. A DOE Operational Readiness Review follows the Contractor Operational Readiness Review. The DOE Operational Readiness Review verifies the contractor’s validation of readiness, determines the effectiveness of the contractor’s ability to assess its own readiness, and verifies DOE is ready to manage and oversee the new facilities, activities, or operations. The Contractor Readiness Assessment may or may not be followed by a DOE Readiness Assessment. Not all readiness activities require the rigor of a formal verification of readiness. For those systems/facilities/processes being started or restarted that are below the thresholds for conducting a Readiness Assessment, an operational readiness checklist is prepared by management responsible for the facilities, activities, or operations prior to start up or restart. Depending on the complexity of the facilities, activities, or operations, readiness coaches (mentors) are sometimes used to reinforce planning and performance of readiness activities. Regardless of complexity, employees undertake work activities with full understanding that they are individually accountable for their own safety and the safety of others involved in or affected by the activity. Employees are qualified through training, qualifications, and experience to perform the tasks assigned. They understand that they are required to follow established procedures or work guidance documents for the work being undertaken. They know that they are to stop work if they discover errors in the procedures or conditions that may change the controls needed to safely perform the work. They also actively engage in developing and changing the procedures or work guidance documents. Employees understand they not only have the right, but the obligation, to stop work if, at any time, they are aware an unsafe condition exists or an unsafe act is being performed. Additionally, employees understand they have the responsibility to report any concern related to an environmental compliance and protection concern). Every employee is





expected to understand the hazards and hazard controls in place before beginning an activity no matter how complex or simple. Operations performs a technical review of the work package to ensure prerequisite conditions are addressed before work begins. Verification is performed to ensure that work package and (or) technical procedure prerequisite conditions are complete and that controls specified in the work package or required by the JHA are in place before the work activity is initiated (TFC-OPS-MAINT-C-01). Pre-job briefings are held prior to commencement of operations, maintenance, and construction work. The supervisor directs the work to be performed per the work instructions and documentation in the work package. Line management is responsible for maintaining satisfactory conduct of operations standards by establishing an appropriate set of Operations policies and facilitating Operations personnel compliance through training and management participation in activities.

Operations Authorization Authorization to conduct operations in Hazard Category 2 (tank farms, 242-A Evaporator) and Hazard Category 3 (222-S Laboratory) nuclear facilities is granted by DOE-ORP in the form of an executed Authorization Agreement. An Authorization Agreement is the mechanism whereby the DOE-ORP and WRPS jointly clarify and agree to key conditions for conducting work safely and efficiently. The Nuclear Safety organization maintains the Authorization Agreement (Correspondence No. 1800004) in accordance with TFC-ENG-SB-C-12. Within the Authorization Agreement is an Authorization Basis that establishes the limits of safe operations. The Authorization Basis’ safe operation limits are based on documented design limitations, controls, regulatory constraints, and assumptions or commitments that are required and based on identified hazards and environmental impacts associated with tank farms facilities and operations. As required by TFC-ENG-SB-C-12, the Authorization Agreement is reviewed and updated annually to ensure the contents remain current and applicable to the TOC work scope. At the activity-level, TFC-PRJ-PC-C-12 provides work authorization, contract authority, and internal controls to ensure that only approved, authorized work is performed in an integrated and consistent approach. At the task activity-level, TFC-OPS-MAINT-C-01, provides work review expectations for the Operations Engineer/Shift Manager, and work authorization and work release expectations by the Shift Manager for field execution. Work is released by the operations shift office after prerequisites are met and after ensuring work can be performed within the boundaries of the Authorization Basis (as a part of the Authorization Agreement).

Perform Work Safely The Conduct of Operations, Maintenance, and Construction programs establish the requirements, roles, responsibilities, ESH&Q integration, and expectations for work execution. Work is performed by personnel who are trained and, as necessary, qualified to perform their assigned task (TFC-OPS-MAINT-C-01). Pre-job briefings are conducted (TFC-OPS-MAINT-C-02) and the work procedures or instructions, results of hazard analysis, and required permits and controls necessary to the job (e.g., lockout/tagout, fall protection, confined space, or hoisting and rigging) are reviewed with the worker. Work is performed in a disciplined manner with strict adherence to procedures.





Line managers are responsible for worker safety and ensure that controls remain in place during work execution. Line managers are experienced personnel who receive the necessary training and qualifications to carry out their assigned duties and responsibilities. Employee hazard communication training stresses hazard recognition and acceptance of individual roles and responsibilities for worker safety. Employees are also trained on their rights and responsibilities regarding their stop work responsibility (DOE-0343). Work is performed according to approved work instructions and procedures that are maintained under configuration control. By following work instructions procedures that have been developed, reviewed, and approved in accordance with established requirements, workers ensure that their work complies with the approved safety basis, requirements basis, and applicable environmental permits and regulations. Baseline management activities, such as the USQ process, are performed to ensure proposed modifications to the technical baseline are properly reviewed and are consistent with requirements and standards. Engineering supports line management by preparing or approving proposed technical baseline changes and reviewing the fieldwork scope to provide assurance that operational activities are also consistent with safety requirements. Administrative and technical procedure revisions are implemented and controlled through the procedure change authorization process (TFC-BSM-AD-C-01; TFC-OPS-OPER-C-13; ATS-310, Section 1.1; and ATS-310, Section 11.16).

4.12 Core Function 5 – Provide Feedback and Continuous Improvement The DOE established that the contractor assurance system (CAS) contributes to adequate implementation of ISMS. WRPS’ contractor self-assessment program addresses the following elements. See Figure 13. : • Performance measures and performance

indicators. • Line and independent evaluations. • Compliance with applicable requirements. • Data collection, analysis, and corrective actions. • Continuous feedback and performance improvement.


1. Line Management Responsibility 2. Clear Roles and Responsibilities 3. Competence per Responsibilities





Figure 13. Feedback.

Collect Feedback Information

WRPS has contractual and corporate commitments to continuously improve executing the TOC mission (TFC-POL-16). The process of feedback and continuous improvement involves the collection of formal and informal feedback, self-identification, and implementation of opportunities for improvement; and acting on feedback from self-assessment, oversight, and enforcement activities. Systems are in place to collect and analyze operations and safety performance data to support these efforts, as described below. Improvements may be accomplished through resolution of single specific issues, or may involve company-level program and process improvements, facility or equipment design changes, or changes to specifications and procedures. ISMS program elements are subject to feedback and continuous improvement through assessment and feedback processes. Feedback and continuous improvement occurs at each level of work and at every stage in the work process. Sources of feedback at a minimum include the items listed below:

Work management feedback Required and Management-Directed assessments Audits/Independent assessments Quality Assurance Surveillance Reports External assessments Event investigations/critiques Problem Evaluation Requests Collective Significance Review Trend analysis

Peer Safety Observer Program Safety councils Performance indicators VPP surveys/assessments Occurrence reporting Risk management Lessons Learned Organizational all-hands meetings

The ESRB (TFC-CHARTER-32) provides management-level oversight through the review and approval of activities (cause analysis and action development) related to significant PERs. An investigation is appropriate for all events, conditions, “near misses,” or other indications of situations within or outside the operations organization that, if uncorrected, can adversely affect safety, health, quality assurance, safeguards and security, operations, or the environment. This investigation process directly feeds into the problem evaluation process where causes and corrective actions are determined. The responsible line organization manager may elect to activate an event investigation to evaluate near misses, other issues with real or potential impact to the ESH&Q of the tank farms facilities and (or) personnel, and that are directly related to human performance issues.

Monitor and Measure Performance Title 10 CFR 830, Subpart A, “Quality Assurance Requirements,” requires that performance be monitored, measured, and evaluated to identify and implement improvement opportunities; this





requirement is implemented by TFC-PLN-02. Within the context of the ISMS, monitoring, measuring, evaluating, and making decisions for improvement occur at multiple levels. Formal safety performance objectives, measures, and commitments are approved by DOE annually and are monitored and revised based on review of performance indicators and other feedback mechanisms. The TOC publishes a monthly report of performance indicators (TFC-PRJ-PC-C-11). Periodically, senior management establishes goals to achieve the mission in a safe manner (discussed in Section 4.8.1). Managers identify suitable safety and operating metrics and leading indicators that address operating experience. Operations are then monitored to measure performance relative to established metrics. ESH&Q and operations information is gathered, analyzed, trended, and disseminated to communicate performance, need for improvement, and progress toward implementation of corrective/improvement actions. Tactical indicators, both leading and lagging, are used to provide management feedback to measure and continuously improve the TOC ISMS and to manage adverse trends before they affect performance. These performance indicators are published monthly and posted to the Operations web site for ease of accessibility. The TOC executive management team meets monthly to assess the information from the performance indicators and provide management direction for improvement. The TOC ISMS performance indicators are subject to feedback and continuous improvement. The TOC will continue to collaborate with the DOE-ORP to provide meaningful and relevant performance measurements.

Identify and Implement Improvement Opportunities As defined in Section 4.12, the WRPS ISMS includes a Feedback and Continuous Improvement component to measure the adequacy of work performed in satisfying the applicable requirements and expectations established in the Contract. Applicable laws, regulations, consensus standards, authorization bases management controls, and DOE guidance resources are integrated with the mechanisms used to identify and implement improvement opportunities. The Contractor Assurance System element of the OPI organization is represented by Contractor Assurance managers in each principal project organization; this practice provides for continuity of assessment perspective and effective liaison for tracking of priority issue resolution. The project Contractor Assurance managers are members of the quarterly CSR process (TFC-CHARTER-44). The oversight component enhances the ISMS principle that employees are accountable for working safely and are responsible for performing quality work. Workers follow procedures and, with management participation, establish an overall awareness of safety in the workplace. To further enhance safe work practices, workers are trained to recognize hazardous conditions in the workplace, to perform work to procedures, and are expected to report unsafe work conditions to their supervisors. ESH&Q professionals inspect the workplace and work practices and are available to workers. Additionally, the Employee Concerns Program and Ethics and Compliance Program ensures appropriate attention and response to any employee question or concern relative to safety, health, security and emergency services, quality, environmental protection, business ethics, compliance with laws and regulations, fraud, abuse, mismanagement, and (or) physical working conditions. Numerous recognition mechanisms are used with awards given on a defined frequency to recognize safe behavior (e.g., monthly, annually, and on the spot) and to a range of employee





categories (e.g., hourly, non-exempt, exempt, management, and teams) to recognize employees’ contributions. The Contractor Assurance System (TFC-PLN-83) works in conjunction with the Quality Assurance Program (TFC-PLN-02) to establish a management assessment strategy and approach to collect evidence of performance in a manner to confirm that projects are accomplishing the TOC mission safely. Substantial commitments are made to gain management presence in the field observing hazardous work related activity. A data management system was established to facilitate consolidation of observations, findings, PER results, and other operational lessons learned. Each month, a team of experienced line and functional managers gather to conduct a CSR to assure that information and data regarding issues and opportunities are being factored with the operational perspectives of key project managers. This practice ensures a robust and timely process is at work to identify crosscutting issues, trends, and to promote transfer of lessons learned across project boundaries; with conclusions reported to the ESRB on a quarterly basis as an added level of critical self-assessment review. Within the Contractor Assurance System, the Assessment Program provides a management structure that integrates management observations, assessments, requirements-based reviews, corrective actions, and lessons learned activities to achieve continuous improvement of business systems throughout the ISMS structure (define scope of work, identify/hazards analysis, implement controls, perform work within controls, and provide feedback and continuous improvement). Internal independent Quality Program audits/assessments are performed to: (1) evaluate management effectiveness, adequacy of work performance, item/product/process quality and product effectiveness; and (2) promote improvement in operations, maintenance, and construction. The audits/assessments provide company and facility management with accurate, timely, and consistent feedback to measure the effectiveness in accomplishing the mission, while assuring adherence to requirements. The Assessment Program compiles performance observations into the established issues management mechanisms; supports continuous improvement; and integrates ESH&Q with business, operations, and construction reviews. Managers at all levels of responsibility are tasked with assessing: management processes; examining in particular how the Guiding Principles and Core Functions of ISMS are being incorporated; the effectiveness of existing hazard analysis and established controls; and with providing real-time field hazard identification and emphasis on leadership’s expectation of prompt, and where required, documentation. The Assessment Program is described in TFC-PLN-10. Independent assessments are described in TFC-ESHQ-AP-C-02. Required and Management-Directed are described in TFC-ESHQ-AP-C-01. In addition to item-by-item review, performance monitoring of collective effort, resultant risk insights and targeted assessment planning support the established Corporate Performance Metric dashboard and its routine review by senior management. The results of this feedback analysis is made available to all WRPS staff via the company intranet and through the lessons learned evaluation and communications processes. WRPS has instituted a process that provides all personnel the ability to initiate a PER for any quality, safety, health, operability, and environmental related issue or recommendation





(TFC-ESHQ-Q_C-C-01). The process uses a web-based desktop tool to route, receive, respond, and status PER tasks and generate reports. Other processes, such as Non-Conformance Reporting, the Noncompliance Tracking System, and the Occurrence Report and Processing System are also used to manage issues. Assessments (Management, Independent, and External) findings and observations are documented in PERs for evaluation and resolution. Depending upon the significance of the issue, action tracking, investigation, understanding why the issue occurred, applying appropriate corrective actions, and monitoring the effectiveness to mitigate recurrence are essential for ensuring a continuously improving culture. As previously stated, various awareness forums (e.g., Safety Councils, PAAA organization, ESRB, PER Screening Committee) review PER data to uniformly communicate and effectively address issues, corrective actions, and lessons learned. WRPS takes seriously the management of safety issues resulting from these various processes, particularly those issues raised by workers. The Operating Experience/Lessons Learned Program (TFC-OPS-OPER-C-28) uses designated personnel to oversee and facilitate implementation of lessons learned. Personnel generate lessons learned using feedback from the participants’ operating experience, reviews, pre-job/post-job briefings, critiques, and assessments. Site-specific lessons learned, including successes, are reviewed and factored into future activities, including work planning and execution. In addition, lessons learned from relevant operating events across the DOE complex are incorporated into the program. The Lean Management System provides a systematic, structured, and focused process to build a performance culture that leads to long-term, dramatic improvements in delivery, quality, safety, and cost, in support of feedback and continuous improvement (TFC-PLN-154). At the activity-level, management presence in the field and observation of activities are effective means of feedback. Pre-job briefings, post-job review, in-process ALARA reviews, and management observations provide the opportunity for face-to-face, two-way communication between the worker and management. The system engineer’s performance monitoring program (TFC-ENG-FACSUP-P-01) establishes the technical basis for collecting, trending, and analyzing report information that enables the reaction to predictive indicators rather than reacting to failures. System engineers prepare system health reports quarterly to provide feedback to Operations on the health of vital safety systems. WRPS also uses the injury and illness statistics to increase workers sensitivity to and education of hazards and the resulting fact-finding effort to develop lessons learned.

Oversight and Enforcement The TOC uses the results of external oversight reviews and regulatory inspections and investigations as feedback to ensure compliance and identify opportunities for improvement (TFC-BSM-IA-C-02). The ORP Facility Representative Program, within ORP Tank Farms Operations Division, is responsible for inspecting ongoing and completed work to ensure compliance with federal, state, local, and contractual requirements. It also oversees line management assessments of contractor readiness to start up new operations. The DOE-HQ, Office of Environmental Management, and Office of Enterprise Assessment performs regular assessments of specific programs at DOE sites that have significant amounts of





special nuclear material or other hazards; perform follow-up reviews to ensure corrective actions are effective to prevent recurrence; perform complex-wide studies of issues and generic weaknesses in specific programs; and develop and validate reports that identify findings, issues, and opportunities for improvement. The U.S. Environmental Protection Agency, Region X, provides oversight of air emissions, and Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA) units on the Hanford Site. The Environmental Protection Agency (EPA) participates in joint inspections of tank farm facilities with the Washington State Department of Ecology (Ecology) and the Washington State Department of Health (WDOH). Ecology is the lead agency for non-radioactive air emissions and RCRA units on the Hanford Site. Ecology performs routine inspections to ensure that the regulated facilities are in compliance with the applicable regulations. WDOH is the lead agency for radioactive air emissions. WDOH performs routine inspections to ensure that the regulated facilities are in compliance with the applicable regulations.

Contractor Assurance System TFC-PLN-83 describes the TOC processes that implement the contractor requirements of DOE O 226.1B, “Implementation of Department of Energy Oversight Policy.” The focus areas of this assurance system include integrated environment, safety, and health system; safeguards and security; cyber security; and emergency management. The Contractor Assurance element of the OPI organization serves as the focal point for assuring assessment planning is comprehensive and tailored to the recognized areas of concern. Contractor Assurance is responsible for the PER process, the assembly of cumulative performance measurement data in dashboards and trend charts, and such evaluation tools. To achieve the objective of a “zero threshold” to initiation of feedback information, an ongoing effort exists to refine the information management aspects of the issues identification and resolution coordination. The QA Audit/Independent Assessment process requires WRPS to conduct internal audits at planned intervals to determine whether the quality management system conforms to the requirements found in NQA-1, 2008/2009 standard, and to the quality management system requirements established by the WRPS QAPD. This helps assure the WRPS QA program is effectively implemented and maintained. The audit program is planned, taking into consideration the status and importance of the processes and areas to be audited, as well as the results of previous audits/assessments. The Management assessment aspects of the WRPS ISMS develop a large body of information; these are used both for corrective action tracking purposes and for the elicitation of leading indicators of total performance adequacy. Expertise is maintained to promote statistical and graphical realization of collective performance risk insights—these support timely movement of lessons learned to points in the Project where they can be employed. The reach of the Contractor Assurance System is extended with the establishment of Contractor Assurance managers in each major project organization; this practice provides for continuity of assessment perspective and effective liaison for tracking of priority issue resolution. The ESRB provides added confidence in the communication, analysis, and follow through on aggregate performance information insights about trends and improvement opportunities. The





Manager of Contractor Assurance is a full member of the ESRB and provides the recording Secretary functions for the ESRB to ensure advance delivery of review materials to members. This manager regularly schedules meetings with established agendas and mechanisms for action designation in the area of all PERs that are considered “significant,” thus requiring a detailed level of causal analysis as well as review of those analyses conclusions and recommendations by the ESRB.

Other Mechanisms

Feedback to wider audiences of workers occurs primarily through Communications and Public Relations (C&PR), which provides multi-media messaging to both internal and external customers. The C&PR organization strives to ensure that employees are aware of the status and implementation of continuous improvement initiatives and activities (status of tank vapors, beryllium hazard analyses, etc.).

5.0 MAINTAINING AND SUSTAINING ISMS As described in this document, work planning and execution are being accomplished with company-, facility-, and activity-level integration of the core functions, guiding principles, and programs and mechanisms of the TOC ISMS. The ISMS Description, declaration of effectiveness, and performance objectives, measures, and commitments (POMCs) and other requested information are submitted to the DOE-ORP in accordance with an annual call letter from DOE-ORP and by section C.3.2 of the WRPS prime contract (Contract DE-AC27-08RV14800). The annual declaration and effectiveness review document the status and implementation of the ISMS over the previous year, and are supported by objective evidence, such as safety and quality performance metrics and trending data; results from ISMS targeted reviews or verifications, assessments, surveillances, management walkthroughs, event and accident investigations; and documented effectiveness of corrective actions taken to improve deficiencies or adverse safety and/or quality performance. Revision to the ISMS Description occurs as needed or as requested by annual call letter, and may include substantive changes to the TOC work scope, methods or technologies used to implement ISMS, or organizational changes (e.g., the addition of construction work scope and supporting processes), while minor, or administrative, changes, may be driven by procedure name or number changes, etc. . Further information on the programmatic elements and requirements for the TOC ISMS can be found in TFC-PLN-01. Both WRPS internal processes and DOE external processes, as previously described in Section 4.12, “Core Function 5 – Provide Feedback and Continuous Improvement,” establish the TOC ISMS structure. The DOE reviews, coupled with the facility representative program, provide valuable oversight and input to maintaining and continuously improving the ISMS structure currently in place. Institutionalizing ISMS is accomplished through effective processes and a safety culture that is owned by the TOC personnel. Processes and safety culture each mature through training, mentoring, changing, and monitoring processes, programs, procedures, and work practices as they are improved. Continuous improvement comes from issue identification, disposition, implementation, verification, and effectiveness monitoring. A strong safety culture supports a healthy ISMS, which in turn strengthens the safety culture; thus, continuous improvement is achieved. WRPS is fully committed to continuous improvement of the ISMS while accomplishing the TOC mission.





WRPS firmly believes, as does the DOE-ORP, that performance of quality work in a safe manner is our single most important objective during the execution of the RPP mission. WRPS commits to providing the support to cultivate the culture to enable that to happen.

6.0 SOURCES

6.1 Requirements 1. Contract DE-AC27-08RV14800, Section C.3.2 “Integrated Safety Management System,”

paragraphs 2 and 3. 6.2 References

1. 10 CFR 830, Subpart A, “Quality Assurance Requirements.”

2. 10 CFR 851, “Worker Safety & Health Program.”

3. 48 CFR DEAR 970-5204-2, “Laws, Regulations, and DOE Directives.”

4. 48 CFR DEAR 970.8223-1, “Integration of Environment, Safety, and Health into Work

Planning and Execution.”

5. ASME-NQA-1-2008, and NQA-1a-2009 addenda.

6. ATS-310, Section 1.1, “Administrative Procedure Control Process.”

7. ATS-310, Section 1.5, “Entry Control.”

8. ATS-310, Section 11.16, “Technical Procedure Control Process.”

9. ATS-LO-100-153, “222-S Laboratory Waste Packaging and Preparation for Shipment.”

10. ATS-MP-1032, “222-S Laboratory Quality Assurance Project Plan.”

11. Correspondence No. 1800004, “River Protection Project Authorization Agreement Between the U.S. Department of Energy, Office of River Protection and Washington River Protection Solutions LLC.”

12. DE-AC27-08RV14800, “Tank Operations Contract.”

13. DOE-0336, “Hanford Site Lockout/Tagout Procedure.”

14. DOE-0343, “Hanford Site Stop Work Procedure.”

15. DOE G 450.4-1B, Vol. 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.

16. DOE M 450.4-1, “Integrated Safety Management System Manual.”

17. DOE O 226.1B, “Implementation of Department of Energy Oversight Policy.”





18. DOE O 414.1D, “Quality Assurance.”

19. DOE O 422.1, “Conduct of Operations.”

20. DOE O 425.1D, “Verification of Readiness to Startup or Restart Nuclear Facilities.”

21. DOE O 426.2, “Personnel Selection and Training and Qualification Requirements for DOE Nuclear Facilities.”

22. DOE O 436.1, “Departmental Sustainability.”

23. HNF-12125, “222-S Laboratory Documented Safety Analysis.”

24. HNF-14733, “222-S Laboratory Technical Safety Requirements.”

25. HNF-14755, “242-A Evaporator Documented Safety Analysis.”

26. HNF-15279, “242-A Evaporator Technical Safety Requirements.”

27. HNF-5183, “Tank Farm Radiological Control Manual (TFRCM).”

28. HNF-IP-1266, “Tank Farms Operations Administrative Controls.”

29. HNF-MP-5184, “Washington River Protection Solutions LLC Radiation Protection

Program.”

30. HNF-SD-WM-OCD-015, “Tank Farms Waste Transfer Compatibility Program.”

31. HNF-SD-WM-TSR-006, “Tank Farms Technical Safety Requirements.”

32. ISO 14001, “Environmental Management Systems – Requirement with guidance for use.”

33. RPP-13033, “Tank Farms Documented Safety Analysis.”

34. TFC-BSM-AD-C-01, “Administrative Document Development and Maintenance.”

35. TFC-BSM-CP_CPR-C-05, “Procurement of Services.”

36. TFC-BSM-CP_CPR-C-06, “Procurement of Items (Materials).”

37. TFC-BSM-CP_CPR-C-17, “Interface Management.”

38. TFC-BSM-HR_EM-C-02, “Employment Staffing.”

39. TFC-BSM-HR_EP-C-01, “Performance Objectives and Career Development Planner.”

40. TFC-BSM-HR_EP-C-02, “Employee Discipline.”

41. TFC-BSM-IA-C-02, “Cooperating with Outside Audits, Inspections, and Investigations.”





42. TFC-BSM-IRM-STD-08, “Information Security Management Standard.”

43. TFC-CHARTER-01, “Tank Operations Contractor Charter.”

44. TFC-CHARTER-02, “WRPS Safety Councils.”

45. TFC-CHARTER-15, “Joint Test Group.”

46. TFC-CHARTER-20, “Behavior Based Safety.”

47. TFC-CHARTER-21, “Chemical Vapor Solutions Team.”

48. TFC-CHARTER-32, “Executive Safety Review Board.”

49. TFC-CHARTER-41, “Lockout/Tagout Hazardous Energy Control Committee.”

50. TFC-CHARTER-44, “Collective Significance Review.”

51. TFC-ENG-CHEM-P-04, “Preparing Criticality Safety Evaluation Reports.”

52. TFC-ENG-CHEM-P-14, “Operating Specification Documents.”

53. TFC-ENG-DESIGN-C-15, “Commercial Grade Dedication.”

54. TFC-ENG-DESIGN-C-47, “Process Hazard Analysis.”

55. TFC-ENG-FACSUP-P-01, “TOC System Engineer Program.”

56. TFC-ENG-SB-C-01, “Safety Basis Issuance and Maintenance.”

57. TFC-ENG-SB-C-03, “Unreviewed Safety Question Process.”

58. TFC-ENG-SB-C-06, “Safety Basis Development.”

59. TFC-ENG-SB-C-09, “Plant Review Committee.”

60. TFC-ENG-SB-C-12, “Authorization Agreement Maintenance and Annual Update.”

61. TFC-ESHQ-AP-C-01, “Required and Management-Directed Assessments.”

62. TFC-ESHQ-AP-C-02, “Independent Assessments/Audits.”

63. TFC-ESHQ-AP-C-03, “Management Observation Program.”

64. TFC-ESHQ-EP-C-01, “Emergency Management.”

65. TFC-ESHQ-Q_C-C-01, “Problem Evaluation Request.”

66. TFC-ESHQ-RP_ADM-C-11, “Joint Review Group.”

67. TFC-ESHQ-RP_ADM-C-15, “Entry and Exit Controls.”





68. TFC-ESHQ-RP_RWP-C-01, “Radiological Risk Screening.”

69. TFC-ESHQ-RP_RWP-C-03, “ALARA Work Planning.”

70. TFC-ESHQ-RP_RWP-C-04, “Radiological Work Permits.”

71. TFC-ESHQ-RP-STD-03, “ALARA Decision Making Methods.”

72. TFC-ESHQ-S_IH-C-02, “Hazard Communication.”

73. TFC-ESHQ-S_IH-C-17, “Employee Job Task Analysis.”

74. TFC-ESHQ-S_IH-C-47, “Chemical Management Process.”

75. TFC-ESHQ-S_SAF-C-02, “Job Hazard Analysis.”

76. TFC-ESHQ-S_SAF-CD-10, “Safety Communications.”

77. TFC-OPS-MAINT-C-01, “Tank Operations Contractor Work Control.”

78. TFC-OPS-MAINT-C-02, “Pre-Job Briefings and Post-Job Reviews.”

79. TFC-OPS-MAINT-STD-02, “Work Planning and Work Instruction Development.”

80. TFC-OPS-OPER-C-02, “Safety Basis Implementation Checklist Preparation, Review,

and Approval.”

81. TFC-OPS-OPER-C-11, “Equipment Temporary Modifications and Bypasses.”

82. TFC-OPS-OPER-C-13, “Technical Procedure Control and Use.”

83. TFC-OPS-OPER-C-28, “Operating Experience/Lessons Learned.”

84. TFC-OPS-OPER-C-65, “Rolling Schedule Process.”

85. TFC-OPS-WM-C-01, “Waste Planning Checklist.”

86. TFC-OPS-WM-C-10, “Contaminated Equipment Management Practices.”

87. TFC-PLN-01, “Integrated Safety Management System Plan.”

88. TFC-PLN-02, “Quality Assurance Program Description.”

89. TFC-PLN-03, “Engineering Program Management Plan.”

90. TFC-PLN-05, “Conduct of Operations Implementation Plan.”

91. TFC-PLN-07, “Dangerous Waste Training Plan.”

92. TFC-PLN-10, “Assessment Program Plan.”

93. TFC-PLN-12, “Safety Culture Improvement Plan.”





94. TFC-PLN-13, “Fire Protection Program.”

95. TFC-PLN-16, “Operational Readiness Program Plan.”

96. TFC-PLN-29, “Nuclear Maintenance Management Program.”

97. TFC-PLN-33, “Waste Management Basis.”

98. TFC-PLN-34, “Industrial Hygiene Exposure Assessment Strategy.”

99. TFC-PLN-39, “PBS-ORP-0014 Enterprise Risk & Opportunity Management Plan.”

100. TFC-PLN-47, “Worker Safety and Health Program.”

101. TFC-PLN-49, “Criticality Safety Program.”

102. TFC-PLN-58, “Chemical Management Plan.”

103. TFC-PLN-61, “Tank Operations Contractor Training and Qualification Plan.”

104. TFC-PLN-80, “Procedure Program Description.”

105. TFC-PLN-83, “Assurance System Program Description.”

106. TFC-PLN-84, “Tank Operations Contract Project Execution Management Plan.”

107. TFC-PLN-100, “Tank Operations Contractor Requirements Basis Document.”

108. TFC-PLN-102, “TOC Interface Management Plan.”

109. TFC-PLN-116, “Subcontractor Oversight.”

110. TFC-PLN-125, “Sustainable Program Plan.”

111. TFC-PLN-123, “Environmental Management System Description.”

112. TFC-PLN-147, “Project Controls System Description.”

113. TFC-PLN-154, “Lean Management System Transformation Process.”

114. TFC-POL-16, “Integrated Safety Management System Policy.”

115. TFC-POL-30, “Environmental Management Policy.”

116. TFC-PRJ-CM-C-01, “Construction Management.”

117. TFC-PRJ-PC-C-02, “Work Breakdown Structure Development and Administration.”

118. TFC-PRJ-PC-C-05, “Estimating.”

119. TFC-PRJ-PC-C-11, “Performance Indicator Program.”





120. TFC-PRJ-PC-C-12, “Baseline Change Control.”

121. TFC-PRJ-PM-C-02, “Project Management.”





ATTACHMENT A - ACRONYMS AND ABBREVIATIONS

ACES Access Control Entry System AIHA American Industrial Hygiene Association ALARA As Low As Reasonably Achievable ASPC Analytical Services Production Contractor BNI Bechtel National, Inc. BTR Buyer’s Technical Representative C&PR Communications and Public Relations CFR Code of Federal Regulations CLIN Contract Line Item Number DEAR Department of Energy Acquisition Regulation DFLAW Direct Feed Low Activity Waste DOE U.S. Department of Energy DOE-HQ U.S. Department of Energy Headquarters DOE-ORP DOE Office of River Protection DOE-RL DOE Richland Operations Office DSA Documented Safety Analysis Ecology Washington State Department of Ecology EFCOG Energy Facility Contractors Group EJTA Employee Job Task Analysis EMS Environmental Management System EPA Environmental Protection Agency EPC Engineering Procurement & Construction ESH&Q Environment, Safety, Health, and Quality ESRB Executive Safety Review Board EVMS Earned Value Management System GHA General Hazards Analysis HAMTC Hanford Atomic Metal Trades Council HPI Human Performance Improvement ISMS Integrated Safety Management System JHA Job Hazard Analysis JRG Joint Review Group NEPA National Environmental Policy Administration OBS Organizational Breakdown Structure OPI Organizational Performance Improvement PAAA Price-Anderson Amendments Act PER Problem Evaluation Request PRC Plant Review Committee QA Quality Assurance QAPD Quality Assurance Program Description R2A2 Roles, Responsibilities, Authorities, and Accountabilities RCRA Resource Conservation and Recovery Act RPP River Protection Project RWP Radiological Work Permit SOW Statement of Work SME Subject Matter Expert TIM Training Implementation Matrix TOC Tank Operations Contract TSCA Toxics Substance Control Act TSR Technical Safety Requirement USQ Unreviewed Safety Question





ATTACHMENT A - ACRONYMS AND ABBREVIATIONS (cont.)

VPP Voluntary Protection Program WAI Wastren Advantage, Inc. WBS Work Breakdown Structure WDOH Washington State Department of Health WRPS Washington River Protection Solutions LLC WTC Waste Treatment Contractor WTP Waste Treatment and Immobilization Plant