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USQ #13-0660-S
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM
DESCRIPTION FOR THE TANK OPERATIONS
CONTRACTOR
Manual
Document
Page
Issue Date
Management Plan
RPP-MP-003, REV 6d
Page 1 of 59
May 22, 2013
Ownership matrix Click for copy of Word (native) file
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 .......................................................................................................... 9
2.5 Integration of Other Initiatives and Systems..................................................................... 10
2.6 Management System ......................................................................................................... 13
3.0 RIVER PROTECTION PROJECT OVERVIEW ......................................................................... 14
3.1 River Protection Project .................................................................................................... 14
3.2 Project Integration ............................................................................................................. 15
3.3 Hanford Interfaces ............................................................................................................ 15
3.4 External Regulatory and Oversight Agencies ................................................................... 17
4.0 WORK EXECUTION WITHIN ISMS ......................................................................................... 17
4.1 Guiding Principle 1 – Line Management Responsibility for Safety ................................. 17
4.2 Guiding Principle 2 – Clear Roles and Responsibilities ................................................... 22
4.3 Guiding Principle 3 – Competence Commensurate with Responsibilities ....................... 24
4.4 Guiding Principle 4 – Balanced Priorities ........................................................................ 25
4.5 Guiding Principle 5 – Identification of Safety Standards and Requirements ................... 26
4.6 Guiding Principle 6 – Hazard Controls Tailored to the Work Being Performed .............. 26
4.7 Guiding Principle 7 – Operations Authorization .............................................................. 26
4.8 Core Function 1 – Define the Scope of Work ................................................................... 26
4.9 Core Function 2 – (Identify and) Analyze the Hazards .................................................... 30
4.10 Core Function 3 – Develop and Implement Hazard Controls ........................................... 35
4.11 Core Function 4 – Perform Work Within Controls........................................................... 40
4.12 Core Function 5 – Provide Feedback and Continuous Improvement ............................... 44
5.0 MAINTAINING AND SUSTAINING ISMS............................................................................... 50
6.0 SOURCES ..................................................................................................................................... 51
6.1 Requirements .................................................................................................................... 51
6.2 References ......................................................................................................................... 51
TABLE OF FIGURES
Figure 1. ISMS Key Components. ............................................................................................................... 5
Figure 2. Management System................................................................................................................... 13
Figure 3. Underground Storage Tanks at the Hanford Site. ....................................................................... 14
Figure 4. Organizational Relationships for the DOE-ORP. ....................................................................... 15
Figure 5. Examples of Documents that Implement ISMS for WRPS. ....................................................... 18
Figure 6. WRPS Organization Chart.......................................................................................................... 19
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
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Issue Date
RPP-MP-003, REV 6d
Page 2 of 59
May 22, 2013
TABLE OF TABLES
Table 1. ISMS Guiding Principles and Core Functions Correlation to Supporting Program Elements. ... 11
Table 2. External Regulatory and Oversight for the TOC. ........................................................................ 17
TABLE OF ATTACHMENTS
ATTACHMENT A - EXPECTATIONS FOR IMPLEMENTATION OF THE INTEGRATED SAFETY
MANAGEMENT SYSTEM ...................................................................................................... 57
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
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1.0 INTRODUCTION (6.1.1)
1.1 Background
The U.S. Department of Energy (DOE) Integrated Safety Management System (ISMS) is
structured to integrate environment, safety, health, and quality (ESH&Q) into work planning and
execution. In keeping with DOE direction (DOE O 450.1A, “Environmental Protection
Program”) and the waste management character of the Tank Operations Contract 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;
embodied in the overall ISMS objective to “Do Work Safely.”
In October 1995, the Defense Nuclear Facilities Safety Board (DNFSB) issued
Recommendation 95-2 regarding Nuclear Facility Safety Management. The DOE’s acceptance
of Recommendation 95-2 resulted in the development and implementation of the Integrated
Safety Management Implementation Plan for Board Recommendation 95-2, dated April 1996.
Since publication of the DOE implementation plan, DOE has 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 DOE, Office of River Protection (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.
DEAR 970.5204.2 (“Laws, Regulations, and DOE Directives”) requires that environmental,
safety, and health (ES&H) 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
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 (ES&H) requirements, approved by
DOE, are incorporated into Contract Attachment J.2, List B, as contract requirements with full
force and effect unless WRPS requests an exemption or other appropriate regulatory relief
specified in the regulation.
DEAR 970.5223-1 requires WRPS to manage and perform work in accordance with a
documented ISMS. The ISMS shall describe how WRPS:
• Defines the scope of work
• Identifies and analyzes hazards associated with the work
• Develops and implements hazard controls
• Performs work within controls, and
• 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
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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. This ensures the overall
management of safety functions and activities.
becomes an integral part of mission
accomplishment. (DOE P 450.4A)
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, Attachment J.2, List B, which includes
the 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.
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.
The scope of this document includes the
Environmental Management System, safety
and health management (including industrial
hygiene and radiation protection), quality
assurance, pollution prevention, 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, pollution prevention,
waste minimization, and security and emergency services.
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2.0 ISMS OVERVIEW
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 O 450.1A, 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 (“Integrated Environment, Safety, and HealthSafety Management
System Policy”), the ISMS consists of six components as shown in Figure 1.
Figure 1. ISMS Key Components.
TFC-PLN-01, “Integrated Environment, Safety, and Health Management System Plan,” 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 970.5215-3, “Conditional payment of fee, profit, or incentives”
• 48 CFR DEAR 970.5223-1, “Integration of Environment, Safety, and Health into Work
Planning and Execution”
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• 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 the DOE
Acquisition Regulation.”
To the extent possible, the ISMS also includes the four supplemental safety culture elements
described in DOE M 450.4-1. Safe Work Environment (SWE) attributes (TFC-CHARTER-34,
“Safe Work Environment Charter”) include relevant supplemental safety culture elements.
2.1.1 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.
2.1.2 Guiding Principles
The ISMS guiding principles describe the environment or context for work activities in that most
principles apply to each and every ISMS core function. WRPS integrates these guiding principles
into all aspects of work planning and execution.
2.1.3 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.
2.1.4 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:
• 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.
2.1.5 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.
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2.1.6 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.
2.2.1 The Company Level
At the company level, the Contract provides the mechanism for the DOE-ORP management of
WRPS scope. The Contract establishes the work scope, specifications, standards, and
requirements for the work to be performed. The Contract establishes the mechanisms for the
DOE-ORP to provide technical direction, approve the Authorization Agreement that establishes
the overall authorization basis for the work scope (see Section 4.7, “Operations Authorization,”
for discussion on the TOC’s Authorization Agreement), and manage the River Protection Project
(RPP) integrated baseline.
WRPS establishes programs, policies, plans, processes, and procedures for work accomplishment;
manages work interfaces; and directs work. Work includes design and construction of facilities
and equipment, operations and maintenance, laboratory support evaluation of performance, and
reporting. Budgets are developed using estimates provided by the line organizations. Through
collaborative interaction with functional support organizations, these budgets incorporate the
ESH&Q resources required to execute the work safely and to maintain the safety and mission-
critical infrastructure of the facilities. After DOE approves the program requirements, project
work requirements flow down to the facility level for planning, scheduling, and work execution.
At the Company Level the Tank Operations Contract Project Execution Plan (TFC-PLN-84)
provides for a projectized Organizational Breakdown Structure (OBS). In keeping with the
current budget year priorities, the planned milestones and other project outcomes are allocated
into subprojects and functional support organizations. Each Contract Line Item domain contains
one or more line management projects to assure integrated planning, hazard and barrier analysis
and controls identification.
WRPS maintains the portions of the RPP integrated performance baseline that flow from the
Contract Line Items; in keeping with the Project Execution Plan, work is divided into mission
projects and subprojects with qualified project managers. Project organizations develop lower-
tier actions such as campaigns to achieve specific milestones (TFC-PRJ-PC-C-02, “Work
Breakdown Structure and WBS Dictionary Sheet Development and Administration”).
Four line organizations: Base Operations; Tank Farm Projects; SST Retrieval and Closure; and
WTP SupportOne System IPT deliver the TOC Mission objectives. ESH&Q, Engineering,
Project Integration, Business Operations and Workforce Resources organizations and functional
work processes support the achievement of ISMS-effective work controls.
The Project Integration organization prepares plans and schedules (TFC-PRJ-PM-C-03, “Project
Categorization and Tailoring”) to ensure work objectives reflect application of the ISMS Core
Functions in the early stages of definition. Integration of resources to ensure safe work
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performance is maintained at all change-affected decision levels (TFC-PRJ-PC-C-12, “Baseline
Change Control”).
Within the Base Operations element of the WBS, an Area Team approach is used to strengthen
continuity of knowledge about aspects of Tank Operations that vary depending upon the age and
current functions of sub-elements of the tank waste system. The Area Team approach also serves
to strengthen the planning of management assessments (TFC-ESHQ-AP-C-01, “Management and
Specialty Assessments”) by allowing oversight activity to focus in known areas of concern or
opportunity – and in particular within the effective span of line management’s control and
detailed knowledge of ongoing operations.
2.2.2 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, “Tank Operations Contractor Work
Control”). Facility level integrated work authorization schedules (TFC-OPS-MAINT-C-09,
“Eight Week Rolling Schedule Process”) are prepared. Authorized work is established at the
company level isand implemented at the facility level. For example, at nuclear facilities,
authorized work activities are bound by the Documented Safety Analysis (DSA) and technical
safety requirements (TSRs) and implemented through procedures and training. These documents,
along with environmental permits, and other safety documents, form the authorization basis 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.
2.2.3 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 ISM
guiding principles and core functions into detailed mission performance in the field.
TFC-ESHQ-S_SAF-C-02 (“Job Hazard Analysis”) provides supplemental guidance to assure
effective hazard analysis.
Working documentation is prepared by means of process-trained, team-based worker
involvement practices (e.g., walk-downs, comparison to General Hazard Analyses, work
packages, procedures, engineering change notices, Unreviewed Safety Question (USQ)
screenings), and safeguards (TFC-BSM-IRM_SE-C-03, “Data Security”). Work is scheduled and
communicated at the plan of the day meetings, and fieldwork 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
mechanisms (e.g., processes and procedures) that implement the five core functions.
Guiding Principles 1 through 3 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.”
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Guiding Principles 4 through 7 align with specific core functions as illustrated in Table 1, and are
discussed in Section 4.0.
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.
2.4 ISMS Core Functions
The five core functions 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 basis] 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
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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
(VPP)), Safe Work Environment (SWE), 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) and the
EMS, complement ISMS implementation and support the ISMS continuous improvement
objective. Table 1 illustrates the correlation between ISMS and several other structures.
The EMS component of the ISMS drives implementation of the applicable environmental
requirements in a manner consistent with the requirements of DOE O 450.1A. 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-PLN-73, “Environmental Protection and Compliance Plan;” TFC-POL-30,
“Environmental Management Policy;” and TFC-PLN-123, “Environmental Management System
Description;”), the Waste Services organization (TFC-PLN-33, “Waste Management Basis”), by
Operations consisting of line management, and the Safety organization (TFC-PLN-58, “Chemical
Management Plan” and TFC-PLN-13, “Fire Protection Program”). These documents also
address EMS elements not directly implemented by WRPS.
Since contract transition, WRPS has expanded upon a comprehensive work planning process.
Teamwork is used at multiple stages of the work control life cycle for project performance.
Incorporating lessons learned and best practices, robust hazard analysis and control is 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; a graded approach to work management based on risk and complexity, worker
involvement, and integrated work planning teams.
As a part of this process, workers – in multi-disciplinary teams – are directly involved 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 Human Performance Improvement (HPI) as an approach to error
reduction that has been developed in other sectors of the DOE and nuclear industry at large.
WRPS maintains its awareness current in DOE-wide HPI activities through participation with the
Energy Facility Contractors Operating Group (EFCOG) – this includes active collaboration with
many DOE elements that share interest in improved work execution performance.
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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. Policy
2. Planning
3. Implementation
and Operation
1. Management
Leadership
1. Program
2. Clear Roles and
Responsibilities
2. Employee
Involvement 1. Program
3. Competence per
Responsibilities
5. Safety and
Health Training
1. Program
2. Personnel Training
and Qualification
4. Balanced Priorities 1. Define Scope of
Work
1. Program
2. Identify and
Analyze
Hazards and
Environmental
Impacts
3. Worksite
Analysis
5. Work Processes
6. Design
5. Identification of Safety
and Environmental
Standards
6. Tailor Hazard and
Environmental Controls
to Work
3. Develop and
Implement
Hazard and
Environmental
Controls
4. Hazard
Prevention and
Control
5. Work Processes
7. Procurement
8. Inspection/Acceptance
Testing
7. Operations (safety and
environmental)
Authorization
4. Perform Work
Within Controls
4. Documents/Records
5. Work Processes
5. Feedback and
Continuous
Improvement
4. Checking and
Corrective Action
5. Management Review
All Five Elements
3. Quality Improvement
9. Management
Assessments
10. Independent
Assessments
Human factors and performance considerations are variables considered during the work
planning process (TFC-OPS-MAINT-STD-02, “Work Planning and Work Instruction
Development”). Planners enter limitations, precautions, safety concerns, and other information
that will enhance field performance for the specific job, and planners are cautioned to not assume
that a given work activity will necessarily be performed by a particular individual or team. HPI
awareness in the work control process is addressed in Attachment B (Error Precursors) to
TFC-OPS-MAINT-C-02, which identifies unfavorable conditions at the job site that create a
mismatch between the task and the individual. The error precursor elements considered (work
environment, individual capabilities, task demands, and human nature) are addressed during
pre-job briefings when discussing work activity critical steps.
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The QA program is established and implemented in compliance with 10 CFR 830, Subpart A,
“Quality Assurance Requirements,” and DOE O 414.1C, “Quality Assurance.” The QA program
is documented in TFC-PLN-02, “Quality Assurance Program Description,” and ATS-MP-1032,
“222-S Laboratory Quality Assurance Project Plan.,” and reflects the QA requirements imposed
by the Contract and regulatory requirements. The QAPD is organized to address the
management, performance, and assessment criteria of paragraph 830.122.
The Quality Assurance Program Key Implementing Documents table is contained within the
QAPD, and is developed to provide a correlation between regulatory consensus standards
invoked for implementation of the QA criteria (ASME-NQA-1-2004), QA program requirements,
and implementing documents. The QAPD key implementing documents table 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 U.S. Department of Energy Voluntary Protection Program (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.
STAR status is the highest level of recognition awarded within the VPP for outstanding
contractor safety and health programs that have successfully implemented the program elements.
Several WRPS facilities have received STAR recognition under the DOE VPP. WRPS has set a
goal for achieving STAR recognition for the remainder of the company. The WRPS VPP
program is defined in TFC-PLN-47, “Worker Health and Safety PlanSafety and Health
Program.”
The VPP initiatives minimize safety impacts, proactively ensure compliance, and effectively
respond to worker needs. Open and effective communication between management, workers,
and support professionals is essential to achieve human/environment protection and regulatory
compliance. To assist in effective communication and issue resolution, WRPS utilizes the
Hanford Atomic Metal Trades Council (HAMTC) Safety Representative Program, which
provides bargaining unit employees another path for raising safety concerns. The HAMTC safety
representatives work closely with management to resolve worker issues.
WRPS has created the ISMS/VPP Enhancement Task Force as defined in TFC-CHARTER-02,
“WRPS Safety Councils.” The purpose of the ISMS/VPP Task Force is to foster worker
involvement in ISMS improvement and achieve consistent VPP implementation across the TOC.
This group developed an upgrade of the Expectations for Implementation of ISMS
(Attachment A). Focus areas include achievement of VPP STAR recognition for the entire
company, promote and instill a healthy ISMS safety culture, integrate and support the activities of
the EAPC VPP subcommittees, and participate in creation and input to the ISMS improvement
process.
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, “Worker Safety & Health
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Program,” 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
(ESH&Q) 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 executed between DOE-ORP and WRPS. The document hierarchy (TFC-PLN-80,
“Procedure Program Description”) employs a tiered graded approach: Policies convey company
position on important to safety topics, and 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 ISM 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, and ISMS implementing
documents.
The organizations responsible for these documents implement requirements that include
environmental requirements, derived from the Authorization Agreement into their internal
procedures. Figure 2 is the document hierarchy as established by WRPS.
Figure 2. Management System.
TFC-PLN-100, “Tank Operations Contractor Requirements Basis Document,” identifies
implementing documents associated with the WRPS Contract, Attachment J.2, requirements. As
implemented by the TOC, TFC-PLN-100 includes applicable laws and regulations, as well as the
applicable requirements from DOE orders, directives, or standards. As part of this process, any
IMPLEMENTING DOCUMENTS
AUTHORIZATION AGREEMENT
AUTHORIZATION BASIS
SAFETY BASIS REQUIREMENTS BASIS ENVIRONMENTAL BASIS
Policies Charters PlansManagement
Directives
CONTRACT
ProceduresInterface Agreements/
External Procedures
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exceptions, clarifications, or alternate means of implementation for these requirements will be are
identified in TFC-PLN-100.
External implementing documents for activities controlled by other site contractors as described
in Contract Section J.3 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 sludges 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 3).
Figure 3. 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, the U.S.
Department of Energy, Office of River Protection (DOE-ORP) has three DOE 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, and initiation of post-closure monitoring of the tank farms. Bechtel National,
Inc. is the Waste Treatment Plant Contractor (WTPC) responsible for designing, constructing,
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and commissioning of the Waste Treatment Plant. Advanced Technologies and Laboratories
International, Inc. (ATL) 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.
Figure 4 shows the line authority from the U.S. Department Energy-Headquarters (DOE-HQ)
Secretary of Energy to the Manager of the DOE-ORP to WRPS, and interfaces at Hanford.
Figure 4. Organizational Relationships for the DOE-ORP.
3.2 Project Integration
Support to the DOE-ORP is provided in managing the RPP integrated baseline (TFC-PLN-84,
“Tank Operations Contract Project Execution Plan”), 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, “Risk and Opportunity
Management Plan”). This function also assists with the RPP integration activities among
DOE-ORP, WTPC, and the Analytical Technical Laboratory (ATL). WRPS performs cost
effective integration of RPP activities. This is done by establishing processes/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, “Assurance System Program Description”). 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 U.S. Department of Energy, Richland Operations Office (DOE-RL) and Pacific
Northwest Science Office (PNSO). WRPS relies on support services from the other Hanford
DOE-HQ Secretary of
Energy
DOE-HQ Asst. Secretary for
Environmental ManagementUnder
Secretary for Nuclear Security
Manager, Richland
Operations
Office
Manager, Office Of River
Protection
Tank Operations Contractor
Waste Treatment
Plant Contractor
Analytical Technical Laboratory
RCCC PRC
CSCAMHHOHS JCI
MSA MSC Unitech
DOE-HQ Asst. Secretary for
Office of Science
Manager, Pacific Northwest Science
Office
Pacific Northwest National
Laboratory
DOE-HQ Asst. SecretarySenior
Advisor for Environmental Management
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contractors in order to meet our mission commitments (TFC-BSM-CP_CPR-C-17, “Interface
Management”). WRPS interfaces with many other DOE prime contractors for services as
outlined in the Attachment J.3 of the TOC contract.
These contractors and some of the services they provide to the TOC include the following.
• The Mission Support Alliance (MSA) which provides most of the Hanford Site
infrastructure support services (Mission Support Contract [MSC]) 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.
• Bechtel National Incorporated (BNI) manages the design and construction of the Waste
Treatment Plant (WTP) project, managed being acquired 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 from the TO Contractor.
• CH2M HILL Plateau Remediation manages the Plateau Remediation Contract (PRC),
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 (LLW) and mixed low level waste (MLLW)
treatment, storage, and disposal; operation and maintenance of the Solid Waste Integrated
Forecast Technical database (SWIFT); etc.
• Washington Closure Hanford manages the River Corridor Closure Contract (RCCC),
which performs treatment, storage, and disposal of Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) waste and operates ERDF.
• CSC Hanford Occupational Health ServicesHPMC Occupational Medical Services
manages the Hanford Site occupational health services for Hanford workers. CSCHPMC
provides medical qualifications, medical monitoring, and occupational medical services.
• ATL International is the Analytical Services Production Contractor (ASPC), which
provides analytical laboratory services to the TOC.
• Johnson Controls (JCI) provides the TOC with steam service.
• Unitech Services Group provides contaminated laundry services to the TOC.
• Pacific Northwest National Laboratory (PNNL) 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 (AIAs), Interface Controls Documents (ICDs), and 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, “TOC Interface
Management Plan.”
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Section 4.8.4, “Subcontractor ISMS Flow down,” identifies mechanisms by which WRPS flows
down ISMS requirements and performs oversight.
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.
4.0 WORK EXECUTION WITHIN ISMS
The preceding portions of this document discussed the basic structure of an ISMS and the RPP.
Expectations are communicated, and 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 of complex work is identified, planned, approved,
controlled, and executed. TFC-PLN-100 cross-references specific TOC implementing standards
to the contract requirements each satisfies. Figure 5 provides an illustration of example
documents that implement the ISMS Core Function standards.
The hazards and complexity of the work determine 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
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
Regulates all treatment/storage/disposal
activities under Resource Conservation
and Recovery Act (RCRA), Toxics
Substance Control Act (TSCA),
Comprehensive Environmental
Resource Conservation Liability Act
(CERCLA), Tri-Party Agreement
(TPA), Solid Waste Management Act
(SWMA), and the Washington State
Hazardous Waste Management Act
X X
Regulates radioactive air emissions X
Regulates non-radioactive air emissions X
Regulates liquid effluents X X
Regulates offsite transportation of
radioactive and non-radioactive
hazardous wastes
X X
Ensures and enhances the safety of
DOE’s defense nuclear facilities
operations
X
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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. It is important
to clearly define the term “line management” so that the safety management roles and
Figure 5. Examples of Documents that Implement ISMS for WRPS.
responsibilities are understood. As published in DOE G 450.4-1B, Volume 1, line management is
defined as “any management level within the line organization, including contractor
management, that 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 our ISMS, WRPS has implemented the attributes of a healthy safety
culture to enhance our ISMS, 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-CHARTER-34, “Safe Work
Environment Charter,” identifies the ISMS attributes associated with a healthy safety culture
focused on the safety of the work force. These attributes include providing an environment where
Integrated Safety
Management System
Core Functions
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individuals will feel free to raise safety concerns without fear of harassment, intimidation,
retaliation, or discrimination (HIRD). These attributes are visible to all WRPS employees who
perform work under a clearly defined set of ISMS expectations (Attachment A) which are aligned
with these safety culture attributes.
4.1.1 WRPS Flow down 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 (see Figure 6).
Figure 6. WRPS Organization Chart.
Within the work area organizations, Integrated Project or job-specific teams are used in the
planning and execution of work in accordance with a comprehensive complexity and safety-
significance-graded process (TFC-OPS-MAINT-C-01). This integration mechanism employs
subordinate procedures the detail how planners and multi-disciplinary teams are selected; these
are employed to ensure the ISMS Guiding Principles and Core Functions are reflected in the
work documents used by line supervisors and workers for individual hazardous activities in the
field (e.g., TFC-ESHQ-S_SAF-C-02).
Depending upon the type of work and the nature of project or hazard significance the WRPS
employs several chartered group review mechanisms to provide defense in depth assurance that
work controls reflect participant concerns, control schemes with a high likelihood of success, and
that in process controls, such as hold points or verifications are incorporated. Examples of these
team-based review mechanisms include: TFC-ESHQ-RP_ADM-C-11, “Joint Review Group;,”
and TFC-CHARTER-33, “Safety Basis Change Review Board;” and TFC-CHARTER-21,
“Chemical Vapor Solutions Team.”
Under the TOC procedures, based on a job complexity approach, line management uses
operators, crafts, technicians, engineers, and other subject matter experts in work planning to
assist with:
• Identifying work scopes and hazards
• Performing job hazard analyses
• Conducting As Low As Reasonably Achievable (ALARA) reviews to minimize
radioactive and non-radioactive hazard exposure
• Implementing the necessary controls to ensure protection of the worker, the public, and
the environment
• Performing and implementing self-assessments
Project Manager
Workforce Resources Manager
ESH&Q Manager
Employee Concerns Program
Project Operations
Manager
Project Integration Manager
Business Operations
Manager
External Affairs
Manager
Base Operations
Manager
Tank Farm Projects Manager
General Counsel &
Internal Audit Manager
SST Retrieval & Closure Manager
WTP Support
ManagerOne System
Chief Engineer
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• Providing input and output for continuous improvement
• Performing facility walk down inspections.
To assure incorporation of the ISMS Core Functions, TFC-OPS-MAINT-C-01, contains process
flow charts for each distinct grade/category of work type; these clearly indicate each value-added
and review step in the process for designating work directions. Training and qualification
materials draw from these systematic descriptions of how work controls are tailored to the
hazards and complexity of the work – from understanding of these multiple development paths
supervisors and workers gain basic understanding of the overall strategy and approach to work
control and change management.
Field direction flows down through the cognizant line manager and fieldwork supervisors for the
work activity. The Shift Manager is responsible for releasing work and ensuring that the work to
be performed is within the authorization basis. When the TOC or a TOC subcontractor
organization is performing work in tank farms, that organization’s line management ensures the
safe conduct of the work in accordance with documented interface protocols in keeping with the
comparative responsibilities designated in Appendix J.3, Hanford Site Services and Interface
Requirements Matrix.
4.1.2 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, “Conduct of
Operations Implementation Plan”).
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, “Stop Work”).
Business Services manages the non-nuclear facilities on the tank farms, and is responsible for
procurement of materials and contract services.
4.1.3 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 (PERs). 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’s safety leadership councils. The
Employee Accident Prevention Councils (EAPC) and the ISMS/VPP Enhancement Task Force
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are subcommittees to the President’s Accident Prevention Council (PAPC) and provide employee
leadership, and ensure employee involvement, thereby achieving maximum accident prevention
and injury reduction by application of the VPP and ISMS principles. The VPP Champions
Teams are subcommittees to the EAPCs. The ALARA Committee is a subcommittee of the
PAPC and reports on ALARA Committee activities periodically.
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 this procedure. 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 the ORP.
Radiological Control Forum (TFC-CHARTER-13) evaluates radiological-related technical and
administrative matters and to confirm recommendations for the development, implementation,
and control of the Radiological Control Program within the TOC organization.
Safety Meetings (TFC-ESHQ-S_SAF-CD-10) are scheduled regularly for the TOC employees
(including selected subcontractors). The meetings promote safety by addressing different health
or safety topics, including information on basic issues, control methods, and established
programs. Employees are encouraged to ask questions and participate 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 that work documents categorized as high risk are comprehensive and
thoroughly reviewed, including contingency plans for emergent situations. The Group 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:
Flammable Gas Equipment Advisory Board (TFC-CHARTER-09) reviews proposed
activities and equipment for compliance with the flammable gas ignition control requirements of
the TOC safety basis, and to apply the safety basis definitions of tank regions to specific
configurations not delineated in the safety basis. The scope of the Flammable Gas Equipment
Advisory Board’s review is limited to flammable gas safety basis controls in areas not classified
in accordance with National Fire Protection Association (NFPA). For areas formally classified in
accordance with NFPA, rulings on compliance will continue to be made by the Hanford Electrical
Codes Board.
Peer Safety Observer Program (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, thereby preventing injuries. This program is proactive
and provides positive reinforcement of good safety behaviors and practices.
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Chemical Vapors Solution Team (TFC-CHARTER-21) is a joint management/employee
initiative to improve WRPS’s hazard identification, controls, training, and communication for
tank farm chemical odors and vapors.
Electrical Safety Committee (TFC-CHARTER-27) is a management/union partnership to
ensure the effective implementation of electrical safety throughout the company and to assist in
the continuous improvement of electrical safety for WRPS and subcontractor activities. This
committee embodies the principle of worker involvement in safety. Electrical workers own the
electrical safety program and their focus is safety. This charter, along with other WRPS
procedures, implements the requirements for an electrical safety program under NFPA 70E,
Article 110.7, “Electrical Safety Program.”
Safe Work Environment Charter (TFC-CHARTER-34) identifies the attributes of a healthy
ISMS and safety culture focused on the safety of the work force, which includes any individual
feels encouraged and free to raise safety concerns without fear of harassment, intimidation,
retaliation, or discrimination (HIRD). These attributes are clearly defined in a set of behavior
based expectations, demonstrating ISMS accountability through desired behavior in the
workplace.
Lockout/Tagout Hazardous Energy Control Committee Charter (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 (PRC) (TFC-ENG-SB-C-09) applies to multiple committees
established for field operation organizations. Among other duties, the PRC will review
unreviewed safety question (USQ) screenings and determinations for proposed activities (if
requested), reportable occurrences, and new information (e.g., potential inadequacy in the safety
analysis (PISA), safety basis amendments, justification for continued operations, etc.) presented to
the PRC by the USQ screener, evaluator, core USQ evaluator or designee against the TOC safety
basis.
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 perspective 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 the 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 majority of the senior management roles and responsibilities at the company level are
included in TFC-CHARTER-01, “Tank Operations Contractor Charter.” The majority of
individual worker’s roles and responsibilities at the activity level are included in the Collective
Bargaining Agreement (CBA), position descriptions, job descriptions, individual performance
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expectations, procedures, training qualifications, and work packages. TFC-CHARTER-01 also
reflects the differences in the line and functional organization roles and responsibilities.
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. Expectations for Implementation of Integrated Safety Management
System clearly describe expectations for personal accountability which apply to all WRPS
employees (Attachment A).
The “ISMS Expectations for Implementation of the Integrated Safety Management System” have
been 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, Peer Safety Observer Program training, Anti-
Harassment Training, Supervisory Skills, Safe Work Environment program, Human Performance
Improvement activities, and VPP activities. Posters containing these expectations are displayed
throughout the various WRPS-controlled locations. WRPS has also emphasized the expectations
in WRPS’s Safety Slogan: “Safety by Choice, not by Chance!” The annual performance
appraisal process (TFC-BSM-HR_EP-C-01, “Employee Development Planner”) 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, “Management Observation Program,” provides interaction between
management and the work force 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 participate 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 a
safe work environment. 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.
First line 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. Their focus is on the programmatic and facility
level, with support to senior management on company level matters. Managers ensure barriers
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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 is responsible for the overall management and safe operation of the TOC
and is supported by the Work Area and Functional Senior Managers.
ORP interfaces with WRPS to ensure continued excellence in mission execution and ESH&Q
management. The 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 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, and management determines the staffing, training,
and qualification requirements for the organization’s positions. For exempt and non-exempt
positions, position descriptions and/or job descriptions are established that define position titles,
education, and experience requirements for similar positions and those with job progression
structure. New position or job descriptions are generated as needed. Job candidates may come
from sources within or outside the company depending on the specialization of the position.
Individual training, education, and experience of job candidates are evaluated before personnel
are selected to fill a position to ensure each worker meets the predefined requirements
(TFC-BSM-HR_EM-C-02, “Employment Staffing”). Once a candidate is selected to fill a
position, their manager determines any additional job specific training, and qualifications
required in addition to that required by the position or job description. For subcontracts, the
buyer’s technical representative (BTR) ensures subcontract personnel have training and
qualifications commensurate with the responsibilities (TFC-BSM-CP_CPR-C-05, “Procurement
of Services”). Bargaining unit position descriptions are defined within the CBA and identify
minimum standards for each craft. Selection and progression of bargaining unit positions are
defined and controlled by the CBA.
Within the Workforce Resources organization, the Training organization supports management in
this activity by establishing the company level management plan TFC-PLN-61, “Tank Operations
Contractor Training and Qualification Plan,” to ensure employees are trained to safely,
competently, and effectively perform their job functions. The Training organization also
maintains an Integrated Training Electronic Matrix (ITEM) Web Portalelectronic training
database for the implementation of training requirements and enhancements.
ITEM The electronic training database and the employee job task analysis (EJTA) process
(TFC-ESHQ-S_IH-C-17, “Occupational Medical Qualification and MonitoringEmployee Job
Task Analysis”) assists managers in determining:
• Training requirements based on working conditions (i.e., hazards to which the individual
will be exposed, such as bloodborne pathogens or heat stress)
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• 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 (SAT) 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. The individual processes of the ADDIE model are briefly described below. A graded
approach is applied to the degree necessary to ensure efficiency, but still adequately transfers
knowledge and skills to the workforce. The SAT process may be applied to other training
programs as deemed necessary by the TOC training management and instructional staff. (See
TFC-BSM-TQ_ADD-C-01, “Conduct of Training Adminstration”)
TOC and 222-S Laboratory each have an approved TIM: the “River Protection Project Tank
Farms Contractor Matrix” and ATS-MP-1006. The TIM identifies which DOE O 426.2
requirements are applicable and allows exceptions and clarifications. The TIMs areis approved
by the DOE Office of River Protection (ORP) and become the only contractually bounding
DOE O 426.2 requirements for TOC and 222-S Laboratory.
The Aapproved TIMs for the TOC and 222-S Laboratory identify operations and support
personnel who require a qualification program as 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
(TFC-ESHQ-RP_ADM-C-15, “Entry and Exit Controls” or ATS-310, 1.5, “Entry Control” 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,
the Project Integration support organization assists project 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 controls processes
provide for uncertainty reduction as detailed planning progresses (e.g., by early worker
involvement and risk register development in sub-projects). As efforts reach the stage of physical
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Applicable Guiding Principles
1. Line Management Responsibility
2. Clear Roles and Responsibilities
3. Competence per Responsibilities
4. Balanced Priorities
work in the field, uncertainties have been 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
Applicable standards and requirements for the conduct of TOC work are identified in the contract
Appendix J.2, Lists A and B. TFC-PLN-100 is identified in the ORP-WRPS Authorization
Agreement as the mechanism by which the flowdown of laws, regulations and DOE directives
into WRPS implementing plans, procedures 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 ensure
that all applicable requirements are incorporated into these ultimate 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, “Graded Approach to Quality”). The variety of mission
activities within the TOC Projects results 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. As indicated
previously, procedures such as TFC-OPS-MAINT-C-01 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 Earned Value Management System
(RPP-7725, “WRPS LLC Project Control System Description”), 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 (ref. 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 applicable procedures.
4.8 Core Function 1 – Define the Scope of Work
Defining work scope 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,
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as the facility owner, defines the mission and requirements. The contractor 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.
Sections 4.4.1 through 4.4.4 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.
4.8.1 Translate Mission into Work
The processes, tools, and controls used to translate the TOC life-cycle baseline into contract period
plans and execution year work is described in RPP-7725. Execution year work is captured and
authorized by the 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 life-cycle baseline is an integral subset of the RPP integrated baseline, which describes
the combined activities of the ORP, WTC, ASPC, and the TOC. The scope and requirements of
the TOC life-cycle baseline are described and assigned 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:
• RPP-7725, “WRPS, LLC Project Control System Description”
• TFC-BSM-CP_CPR-C-17, “Interface Management”
• TFC-OPS-MAINT-C-01, “Tank Operations Contractor Work Control”
• TFC-PLN-03, “Engineering Program Management Plan”
• TFC-PLN-39, “Risk Management Plan”
• TFC-PLN-84, “Tank Operations Contract Project Execution Plan”
• TFC-PLN-102, “TOC Interface Management Plan.”
• TFC-PRJ-PC-C-02, “Work Breakdown Structure and WBS Dictionary Sheet
Development and Administration”
• TFC-PRJ-PC-C-05, “Estimating”
• TFC-PRJ-PC-C-12, “Baseline Change Control”
• TFC-PRJ-PM-C-02, “Project Management”
• TFC-PRJ-STD-02, “Control Account Manager Responsibilities and Duties.”
The processes described in these plans and multi-disciplinary teams comprised of technical,
operational, management, ESH&Q, customer representatives, and subject matter experts
implement procedures.
During this process, these team members implement ISMS principles through the:
• 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
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• Safe performance of the work
• Continuous feedback that leads to changing how the work is performed with particular
attention to the 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.
4.8.2 Set Expectations
The work breakdown structure development process establishes the expectations for
accomplishing work, prioritizing tasks, and allocating resources. A hierarchy of mechanisms is
used such that each successively 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 (see Attachment A for performance expectations). 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.
4.8.3 Prioritize Tasks and Allocate Resources
Potential hazards are considered in prioritizing and scheduling work during the integrated
planning process (RPP-7725) and work package preparation (TFC-BSM-FPM_PR-C-03, “Work
Control – General Purpose Facilities;” TFC-OPS-MAINT-C-01; 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-MAINT-C-09). Work scheduled beyond the Plan of the Week timeframe is planned
and scheduled in the Integrated Management Meeting and other departmental scheduling
meetings.
4.8.4 Subcontractor ISMS Flow down
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 flow down
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 written and managed within two major categories:
1) products that include materials, supplies, equipment and commercial items, and 2) services
that are 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 upon 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 governed by the following procedures:
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• TFC-BSM-CP_CPR-C-05, “Procurement of Services”
• TFC-BSM-CP_CPR-C-06, “Procurement of Items (Materials).”
A 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/clarification to the subcontractor to ensure performance of all elements in
accordance with the statement of work 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, SES, protective forces,
environmental, Price-Anderson Amendments Act, 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, “Subcontractor Oversight”). When applicable, the task is evaluated
against the approved safety basis in accordance with TFC-ENG-SB-C-03, “Unreviewed Safety
Question Process.”
4.8.5 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 participation by
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 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 (verbally directed, routine, planning required, work planning with Joint
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Applicable Guiding Principles
1. Line Management Responsibility
2. Clear Roles and Responsibilities
3. Competence per Responsibilities
Review Group 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 the
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 are
identified as part of baseline development, a process that continues throughout the facility or
project life-cycle. 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.
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 within the work
scope and responsibility of other Hanford prime contractor service organization (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 General Hazards Analysis (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 Radiation
Work Permit (RWP), for radiological work, no additional hazard analysis is required. Work
processes and hazard identification and controls are integrated with Human Performance
Improvement 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.
At the activity level, the workers have been 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 Job Hazard Analysis (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 subject matter experts 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 the 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, and Safety/Industrial
Hygiene. Hazards and hazard controls are subsequently validated during the procedure validation
walkdown.
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The process to develop, implement, and maintain the primary facility safety basis is contained in
TFC-ENG-SB-C-06, “Safety Basis Development,” and TFC-ENG-SB-C-01, “Safety Basis
Issuance and Maintenance.” Similarly, the TOC environmental basis is administratively
implemented by TFC-PLN-73 and 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, “ALARA Decision Making Methods,” addresses radiological aspects
of new designs. Multidisciplinary design review teams help identify and resolve design and
life-cycle 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 analysis are
performed per TFC-ESHQ-S_SAF-C-02.
For Level 1 work packages (ref. TFC-OPS-MAINT-C-01) and new technical procedures or major
revisions to technical procedures (ref. TFC-OPS-OPER-C-13), and non-repetitive administrative
building maintenance governed by TFC-BSM-FPM_PR-C-03, a walkdown of the job site with
the supervisor is performed to identify potential hazards relating to tasks to be performed. The
supervisor ensures participation by the worker representative(s), which may include Industrial
Safety, Health Physics Technician (HPT), Environmental Representative, and other subject
matter experts (SMEs), as determined necessary by the planner/procedure writer and supervisor.
Work activities classified as high risk receive review by the Joint Review Group (JRG) to ensure
that the relevant work documents are comprehensive and thoroughly reviewed, including
contingency plans for emergent situations (TFC-ESHQ-RP_ADM-C-11). This review of work
activities is intended to be independent upon the mechanism (e.g., work instructions, procedures,
work plans, etc.) used to control the process. Bargaining unit personnel attending 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 has adequately addressed 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 analysis, applicable supplemental analyses, and approved site-wide categorical
exclusions are prepared under NEPA.
4.9.1 Identify the Hazards
WRPS’s EMS and Authorization Basis require identification of hazards to the workers, public,
and the environment, as described in DOE G 450.4-1B, Vol. 1.
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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 Job Hazard Analysis Checklist is
applied as a tool to identify specific hazards and safety work requirements.
For lower risk work, workers, supervisors and appropriate subject matter experts review and
approve identification of hazards (TFC-OPS-MAINT-C-01, TFC-BSM-FPM_PR-C-03, 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 and TFC-BSM-FPM_PR-C-03). 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 involved in job planning, pre-job walk downs, 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, “Hazard
Communication,” and TFC-ESHQ-S_IH-C-47, “Chemical Management Process”); 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 supervisor 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, and Safety/Industrial Hygiene organizations are involved in the review of hazard
identification and mitigation content.
The process for providing formal written work instructions for the performance of work in
general purpose facilities (Administrative Facilities) managed and performed by WRPS Facilities
& Property Management is provided in TFC-BSM-FPM_PR-C-03. This procedure also describes
the degree of planning that is required and uses a graded approach to implement these
requirements; the hazard analysis process described in TFC-ESHQ-S_SAF-C-02 (for either a
GHA or a JHA) is invoked. The list of facilities that this procedure applies is provided in the
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HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
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Memorandum of Understanding document RPP-34909, “CH2M General Facilities Maintenance
Agreement.”
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 applied 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.
4.9.2 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 plan the work and establish
appropriate processes to perform the work. Identification and mitigation of hazards (radiological
safety, industrial safety, fire protection, chemicals, criticality and nuclear safety, 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 involvement 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.
• TFC-PLN-58, “Chemical Management Plan”
• TFC-PLN-34, “Industrial Hygiene Exposure Assessment Strategy”
• TFC-ESHQ-S_IH-C-02, “Hazard Communication”
• TFC-ESHQ-S_IH-C-47, “Chemical Management Process”
• TFC-ESHQ-RP_RWP-C-03, “ALARA Work Planning.”
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
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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
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 consider hazards, including natural phenomena, hazards that can initiate and
contribute to the uncontrolled release of radioactive or hazardous material, or that may affect the
workers, the public, and the environment. The identification, evaluation, and classification of
risks associated with the TOC facilities are performed per TFC-ENG-DESIGN-C-47, “Process
Hazard Analysis.” Radiological and hazardous material inventories, facility processes, and
planned operations, in part, determine the facility hazard classification and required hazard
baseline documentation. For industrial facilities (e.g., shop, warehouse, laboratory, and test
facility), a hazard baseline checklist is completed. The hazard baseline checklist ensures that the
facility does not inadvertently increase its hazardous material inventory and/or processes to a
level where a safety analysis and controls that are more rigorous are required.
The greatest rigor is applied to nuclear facilities. For nuclear facilities, hazard analyses evaluate
hazards associated with the construction, modification, operation, and decontamination and
decommissioning of the facility. The process to perform these analyses is documented in safety
analysis reports (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 (see
Section 4.6.2 of this document).
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.
4.9.3 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-BSM-FPM_PR-C-03, TFC-OPS-MAINT-C-01). Work
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INTEGRATED ENVIRONMENT, SAFETY, AND
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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
4.10.1 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 Basis, 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 WRPS 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, “Engineering Program Management
Plan,” that defines the technical baseline (products, processes, structures, systems and
components), design baseline (design of structures, systems, and components and their
processes), operations baseline (operational, maintenance, and material handling processes), and
implementing procedures.
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).
4.10.2 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
(TFRCM).” Controls necessary to prevent and/or mitigate radiological exposures or release of
radioactive contamination are developed and inserted into the work control document and/or
governing radiological work permit. Field work practices are monitored for compliance with
prescribed controls and limits.
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
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At the company level, the Authorization Basis 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 addresses items of significant importance in establishing and supporting the
Authorization Basis and serves as the mechanism whereby the 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 states: “Managing, operating, constructing,
and performing work within the Authorization Basis is required.”
The Authorization Basis has three integral components:
• The safety basis
• The requirements basis, and
• The environmental basis.
The requirements basis is discussed in Section 4.6.1; discussion of the safety basis and the
environmental basis is provided below.
The safety basis includes the DSAs, as amended and TSRs for the tank farms, the 242-A
Evaporator, and the 222-S Laboratory. The DSAs document the analyses that identify the
radiological and toxicological hazards to facility workers, onsite workers, and the offsite public
for the respective facility. 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 prevents or mitigates the DSA-identified hazards and thereby
ensures 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 safety basis is updated as necessary to reflect facility modifications or changes in mission or
operations (TFC-ENG-SB-C-01). Proposed changes to the facility or operations are evaluated
through the Unreviewed Safety Question process defined in TFC-ENG-SB-C-03 to determine
whether the changes require 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 ORP approval in accordance with the USQ process and submitted to ORP for
approval. Note that the USQ process is not used for changes to the TSRs because all changes to
the TSRs require prior 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
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• 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, “Safety Basis Implementation Checklist Preparation, Review, and
Approval”). 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, TFC-PLN-49, “Tank Farm Contractor Nuclear Criticality
Safety Program,” is one of the safety management programs required by the DSA, and ensures
that fissionable material in the tank farm facilities remains subcritical under expected (i.e., normal
and credible abnormal) conditions and configurations. This is accomplished by imposing waste
acceptance criteria on external waste generators and ensuring compliance with those criteria via
HNF-SD-WM-OCD-015, “Tank Farms Waste Transfer Compatibility Program,” as well as
ensuring that new activities and projects are evaluated for nuclear criticality safety according to
TFC-ENG-CHEM-P-04, “Criticality Safety Evaluations.”
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-OPSESHQ-EP-C-01) uses facility hazards and environmental impact
analyses as a technical basis for planning emergency response training, drills, and exercises, and
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 and
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 life-cycle 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
specific controls that are applied to managing work within acceptable bounds. These include
administrative controls as specified in HNF-IP-1266, radiological controls, new engineered
controls, and permits that are identified and specified in the JHA. Personnel are briefed on
hazards and controls prior to performing work (TFC-OPS-MAINT-C-02, “Pre-Job Briefings and
Post-Job Reviews”).
TFC-PLN-7123 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. This document, plusTFC-PLN-123
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and TFC-POL-30 and TFC-PLN-123 also discuss Environmental Programs in a way that matches
the Environmental Management System (EMS) implementing structure identified in guidance for
DOE O 450.1A. 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-100.
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 subject matter expert support to projects, 3) reviewing proposed work
against applicable requirements, 4) generating appropriate permit applications, 5) providing
subject matter expert 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 (WS) group manages the TOC solid waste and provides transportation and
packaging services, and pollution prevention/waste minimization programs support services
(TFC-CHARTER-01). The program includes transportation and packaging, and the pollution
prevention/waste minimization programs. The group ensures that 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.
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ISMS implementing Waste Services procedures include:
• A-6004-166, “Radioactive Waste Compliance Checklist”
• A-6004-167, “Non-Radioactive Waste Compliance Checklist”
• A-6004-227, “Radiological Evaluation for Release”
• TFC-PLN-33, “Waste Management Basis”
• TFC-OPS-WM-C-01, “Waste Planning Checklist”
• TFC-OPS-WM-C-10, “Contaminated Equipment Management Practices”
• TO-100-052, “Perform Waste Generation, Segregation, Accumulation and Clean-up”
• Waste Services Records Material Controls Worksheets.
Controls specific to the 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:
1. Preparing operating specification documents (TFC-ENG-CHEM-P-14, “Operating
Specification Documents”)
2. Using temporary modifications or bypasses of equipment (TFC-OPS-OPER-C-11,
“Equipment Temporary Modifications and Bypasses”)
3. Replacing equipment in safety class/safety significant systems
(TFC-ENG-DESIGN-C-15, “Commercial Grade Dedication”)
4. Addressing USQs (TFC-ENG-SB-C-03, “Unreviewed Safety Question Process”)
5. Preparing and using Operations and Maintenance procedures (TFC-OPS-OPER-C-13,
“Technical Procedure Control and Use”).
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 supervisors confirm that designated work controls
are included in the work package. The team approach uses a multidisciplinary 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 and work instructions are documented for work media
(TFC-OPS-MAINT-C-01 and TFC-BSM-FPM_PR-C-03) and are communicated to the work
force (TFC-OPS-MAINT-C-02).
The Procedure process (development, verification and validation (V&V) and approval) uses a
team approach that includes an appropriate mix of worker expertise, Field Work Supervisor,
Engineering, and Subject Matter Experts (e.g., Radiological Control, Environmental, Safety, and
Criticality Safety). Throughout the process, Human Performance Improvement (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
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Applicable Guiding Principles
1. Line Management Responsibility
2. Clear Roles and Responsibilities
3. Competence per Responsibilities
7. Operations Authorization
reduce potential exposures and limit the need for personal protective equipment (PPE). AIHA
guidance to resolve uncertainties will be applied on a work area or tank farm basis.
Workers are heavily involved in the resolution of vapor exposure issues through participation on
the Chemical Vapors Solution Team as discussed in Section 4.1.3 (TFC-CHARTER-21).
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. CSC Hanford
Occupational Health Services (CSC)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). CSC 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
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.
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.
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 identified
requirements contained in DOE O 5480422.19, “Conduct of Operations Requirements for DOE
Facilities.” and delineated in TFC-PLN-05, “Conduct of Operations Implementation Plan.”
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Operations policies, expectations, roles and responsibilities, and a specific implementation matrix
are contained 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, “Nuclear Maintenance Management Program”).
Construction activities are conducted in accordance with the facility construction program,
TFC-PRJ-CM-C-01, “Construction Management.” 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
(Administrative Facilities) managed and performed by WRPS is outlined in
TFC-BSM-FPM_PR-C-03. Dependent 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 asfalling 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.
4.11.1 Confirm Readiness
The TOC has readiness review processes that verify the readiness of facilities, processes, or
project (TFC-PLN-16, “Operational Readiness Program Plan”). 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 is 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 425.1CD,
“Startup and Restart of 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 system/facility/processfacilities, 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
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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
system/facility/processfacilities, 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 implementation weaknesses, management declares the
system/facility/processfacilities, activities, or operations ready for operations. An independent
team, with no line responsibility for the system/facility/processfacilities, activities, or operations
on which the review is performed, then validates management’s declaration of readiness. This
review is either an Operational Readiness Review (ORR) or a Readiness Assessment (RA). A
DOE ORR follows the Contractor ORR. The DOE ORR verifies the contractor’s validation of
readiness, determines the effectiveness of the contractor’s ability to assess their own readiness,
and verifies DOE is ready to manage and oversee the new system/facility/processfacilities,
activities, or operations. The Contractor RA may or may not be followed by a DOE RA.
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
an RA, an operational readiness checklist is prepared by management responsible for the
system/facility/processfacilities, activities, or operations prior to start up or restart. Depending on
the complexity of the facility/ system/processfacilities, 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 determine there are errors in the procedures or conditions that may change
the controls needed to safely perform the work. They also actively participate in developing and
changing the procedures or work guidance documents. Employees understand that they not only
have the right, but the obligation, to stop work if, at any time, they are aware that an unsafe
condition exists, or an unsafe act is being performed. Additionally, employees understand that
they have the responsibility to report any concern related to an environmental compliance and
protection concern (Attachment A). 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 and TFC-PRJ-CM-C-07, “Construction Notice of Intent”). 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.
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4.11.2 Operations Authorization
Authorization to conduct operations of a category 2 nuclear facility (WRPS is a Category 2
facility) is granted by DOE in the form of an executed Authorization Agreement. An
Authorization Agreement is the mechanism whereby the ORP and WRPS jointly clarify and
agree to key conditions for conducting work safely and efficiently. 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. WRPS’s
Authorization Agreement undergoes an annual review 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 (sections 4.3.5, Operations Pre-work
Review, and 4.4, Scheduling and Work Order Release), 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 have been met and after ensuring work can be performed within the boundaries of
the authorization agreement.
4.11.3 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 are reviewed with the worker. Work is performed in a disciplined manner
with strict adherence to procedures.
As noted previously, work planning, authorization and conduct for work performed in general
purpose facilities (Administrative Facilities) managed and performed by WRPS is outlined in
TFC-BSM-FPM_PR-C-03. Work control documents such as the JHA provide the safe
framework for conduct of the work activities.
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
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Applicable Guiding Principles
1. Line Management Responsibility
2. Clear Roles and Responsibilities
3. Competence per Responsibilities
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, “Administrative
Document Development and Maintenance;” TFC-OPS-OPER-C-13,; ATS-310, Section 1.1,
“Administrative Procedure Control Process;” and ATS-310, Section 11.16, “Technical Procedure
Control Process”).
4.12 Core Function 5 – Provide Feedback and Continuous Improvement
DOE has established that DOE line oversight and
contractor self-assessments together ensure
adequate implementation of ISMS. At a minimum,
a credible contractor self-assessment program
addresses the following elements:
• Performance measures and performance indicators
• Line and independent evaluations
• Compliance with applicable requirements
• Data collection, analysis, and corrective actions
• Continuous feedback and performance improvement.
4.12.1 Collect Feedback Information
WRPS has contractual and corporate commitments to continuously improve in executing the
TOC mission (TFC-POL-16). The process of feedback and continuous improvement involves
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 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:
Work management feedback
Management and Specialty assessments
Independent assessments
External assessments
Event investigations/critiques
Problem Evaluation Requests
Trend analysis
Peer Safety Observer Program.
Safety councils
Performance indicators
VPP surveys/assessments
Occurrence reporting
Risk management
Lessons Learned
Organizational all-hands meetings
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At the company level, the ESRB (TFC-CHARTER-32) reviews PER resolutions for significant
deficiencies and provides feedback to the PER owner. PER resolutions that are determined to
warrant further investigation and/or actions are returned to the PER owner for revision.
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 team to evaluate near misses, and 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.
4.12.2 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.
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 (POMC) 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,
“Performance Indicator Program”). Periodically, senior management establishes goals to achieve
the mission in a safe manner (discussed in Section 4.4.1). 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, and trended by line management 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 ORP to provide meaningful and relevant performance
measurements.
4.12.3 Identify and Implement Improvement Opportunities
As defined in the beginning of Section 4.12, the WRPS ISMS includes a Feedback for
Continuous Improvement component to measure the adequacy of work performed in satisfying
the applicable quality requirements and expectations established in the TO 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 ESH&Q
organization is represented by Contractor Assurance managers in each principal project
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organization; this practice provides for continuity of assessment perspective and effective liaison
for tracking of priority issue resolution. The project CA managers are members of the quarterly
Collective Significance Review (CSR) process (TFC-CHARTER-44, “Collective Significance
Review”).
The oversight component enhances the ISMS principle that employees are accountable for
working safely and 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 for consultation on employee concerns. The employee concerns program
ensures appropriate attention and response to any concern relative to safety, health, SES, quality,
environmental protection, business ethics, compliance with laws and regulations, fraud, abuse,
mismanagement, and/or physical working conditions.
WRPS Safety Slogan is, “Safety by Choice, Not by Chance!” 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 has been established
to facilitate consolidation of observations, findings, problem evaluation report results and other
operational lessons learned.
Each quarter, a team of experienced line and functional managers gather to conduct a Collective
Significance Review to assure that significant information regarding both concerns and
opportunities are being factored with the ordinary operational perspectives of key project
managers. This practice assures a robust and timely mechanism is at work to identify
crosscutting issues and to promote transfer of lessons learned across project boundaries. The
Review Team provides the conclusions of its deliberations to the Executive Safety Review Board
who in turn provide an added level of critical self-assessment. The interaction between the CSR
team members and the ESRB provides an important regular forum for exchange of project
performance information in the context of the total effectiveness of protection plans and practices.
Internal independent quality program audits and 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 total assessment program is described in TFC-PLN-10,
“Assessment Program Plan.” Independent assessments are described in TFC-ESHQ-AP-C-02,
“Independent Assessments/Audits.” Management and specialty assessments are described in
TFC-ESHQ-AP-C-01.
The assessment program compiles performance observations into the established issues
management mechanisms, supports continuous improvement, and integrates ESH&Q with
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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.
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/analysis hazards,
implement controls, perform work within controls, and provide feedback and continuous
improvement). 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
analysis of feedback effort 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 deficiency or process evaluation
(TFC-ESHQ-Q_C-C-01, “Problem Evaluation Request”). The process uses a web-based
Electronic Suspense Tracking and Routing System (E-STARS) that is a desktop tool to route,
receive, respond, and status PER tasks and generate reports. Certain processes, such as the Non-
Conformance Report, WRPS reporting to the Non-compliance Tracking System and the
Occurrence Report Processing System will continue to be maintained, as well. Adverse results of
assessments (management, independent, and external) are documented on PERs for evaluation
and trend analysis. Investigating a problem, understanding why it happened, applying
appropriate corrective actions, and monitoring the effectiveness to mitigate recurrence are
essential for ensuring a continuously improving culture.
Several revisions have recently been implemented to the corrective action management process
(TFC-ESHQ-Q_C-C-01) to enhance application of ISM principles, including the following:
• Peer to peer correction or work team self-correction is encouraged and does not constitute
a basis for a negative observation requiring a PER to be initiated.
• The training criteria for management, employees, and root cause team lead personnel that
support the corrective action process have been clarified.
• Issues reflecting housekeeping or minor maintenance items in an administrative facility
(i.e., office building) can rely upon Help Desk assistance, rather than application of the
PER process.
• For significant PERs, the need for a Level 1 Manager to be designated as the PER
Responsible Manager has been removed.
• A causal analysis no longer needs to be performed for a PER prior to submittal of the
PER.
• Causal analyses for all Significant PERs will receive all relevant reviews and approvals
prior to submittal to the ESRB.
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• An alternative is provided to close a PER to a work order if no additional analysis beyond
completion of the maintenance activity is needed.
• PER initiator input is more actively sought for PER resolutions.
• PER initiation criteria have been clarified and expanded.
• Procedures to process PERs, perform causal analyses, and write effective PERs have
been combined into a single procedure.
• Clarified the roles and responsibilities of the Contractor Assurance Manager and line
managers in application of the PER process.
• The process to roll up a PER to an existing PER has been proceduralized.
• Expectations to process improvement opportunities as PIE/CIM PERs have been
proceduralized.
• Expectations for processing of all classifications of PERs have been clarified and
expanded.
• Procedural direction has been provided for processing of PERs and corrective action
plans resulting from externally identified issues.
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 lessons learned program (TFC-OPS-OPER-C-28, “Lessons Learned”) 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.
At the activity level, management presence in the field and observation of activities are an
effective means of feedback. Pre-job briefings, post-job review, and management observations
provide the opportunity for face-to-face two-way communication between the worker and
management. The system engineers provide continuous operational and maintenance support
including system walk downs (routine, comprehensive, outage), and evaluating their assigned
system performance. The system engineer’s performance monitoring program
(TFC-ENG-FACSUP-P-01, “Conduct of System Engineering”) 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.
4.12.4 Oversight and Enforcement
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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, “Cooperating with Outside Audits, Inspections, and Investigations”).
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 Independent Oversight and
Performance Assurance perform 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 and issues, and opportunities for improvement.
The U.S. Environmental Protection Agency (EPA), Region X, provides oversight of air
emissions, and RCRA and Toxic Substance Control Agency (TSCA) units on the Hanford Site.
EPA participates in joint inspections of tank farm facilities with the State of Washington,
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.
4.12.5 Contractor Assurance Program
TFC-PLN-83 describes the TOC processes that implement the contractor requirements of
DOE O 226.1A, “Implementation of Department of Energy Oversight Policy.” The primary
focus areas of this assurance system include environment, safety, and health; safeguards and
security; and emergency management. This management plan describes the WRPS assurance
system to identify and address program and performance deficiencies and opportunities for
improvement, provide the means and requirements to report deficiencies, establish and effectively
implement corrective and preventive actions, and share lessons learned.
These activities include assessments (including self-assessments, management assessments, and
internal independent assessments as defined by laws, regulations, and DOE directives such as
quality assurance program requirements) and other structured operational awareness activities
(e.g., management walkthroughs), lessons learned programs, accident investigations, worker
feedback mechanisms, performance indicators/measures, incident/event reporting processes, and
issues management, including analysis of causes, identification of corrective actions and
recurrence controls, corrective action tracking and monitoring, closure of corrective actions and
verification of effectiveness, analysis of trends, and identification of continuous improvement
opportunities.
The Contractor Assurance element of the ESH&Q 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 Problem Evaluation Report process, the assembly of
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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 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 exists to provide added confidence in the communication, analysis, and follow
through on aggregate performance information insights about adverse trends and improvement
opportunities. The Manager – Contractor Assurance is a full member of the ESRB and provides
the recording Secretary functions for the Board to ensure advance delivery of review materials to
members, regularly scheduled meetings with established agendas and mechanisms for action
designation in the area of all Problem Evaluation Reports that are considered “significant” and
thus requiring a detailed level of causal analysis as well as review of those analyses conclusions
and recommendations by the ESRB.
5.0 MAINTAINING AND SUSTAINING ISMS
In writing the implementation plan for DNFSB Recommendation 95-2 (Safety Management),
DOE sought to institutionalize an ISMS that would facilitate accomplishment of the various site
missions, while ensuring adequate protection of the workers, the public, and the environment. To
institutionalize the ISMS, DOE Acquisition Regulations were enacted, which established the
system requirements. The TOC has met the DOE objective and established contract requirements
for institutionalizing the ISMS for work and operations conducted at tank farms. 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.
DOE O 450.1A drives implementation of a robust environmental management component within
the ISMS. The TOC has incorporated applicable requirements from DOE O 450.1A and has
incorporated required elements of the enhanced EMS into its ISMS and supporting documents.
The ISMS Description (RPP-MP-003), Declaration of Readiness Report, and performance
objectives/measures/commitments (POMCs) are submitted to the DOE-ORP annuallyin
accordance with contract requirements. The Declaration of Readiness Report, which details
changes to the ISMS over the previous year as well as changes planned for the next fiscal year., is
also submitted annually to DOE. The ISMS documentation is revised as necessary to reflect
significant improvements, changes, or requirements.
Both WRPS internal processes and DOE external processes as previously described in
Section 4.8, “Core Function 5 – Provide Feedback and Continuous Improvement,” oversee the
effectiveness of establish the TOC ISMS structure. The DOE annual reviews coupled with the
facility representative program provide valuable oversight and input to maintaining and
continuously improving the ISMS structure that is in place.
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Institutionalizing ISMS is accomplished through effective processes and a safety culture that is
owned by the TOC personnel. Each matures 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 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. 29633-ESQ-AA-0001, “Authorization Agreement.”
6.2 References
1. A-6004-166, “Radioactive Waste Compliance Checklist.”
2. A-6004-167, “Non-Radioactive Waste Compliance Checklist.”
3. A-6004-227, “Radiological Evaluation for Release.”
4. ASME-NQA-1-2004.
5. ATS-310, Section 1.1 “Administrative Procedure Control Process.”
6. ATS-310, Section 1.5, “Entry Control.”
7. ATS-310, Section 11.16, “Technical Procedure Control Process.”
8. ATS-310, Section 6, Environmental Procedures.”
9. ATS-MP-1006, “Training Implementation Matrix.”
10.9. ATS-MP-1007, “222-S Laboratory Complex Dangerous Waste Training Plan.”
11.10. ATS-MP-1032, “222-S Laboratory Quality Assurance Project Plan.”
12.11. Contract DE-AC27-08RV14800.
13.12. 10 CFR 830, Subpart A, “Quality Assurance Requirements.”
14.13. 10 CFR 851, “Worker Safety & Health Program.”
15.14. 48 CFR DEAR 970.5204-2, “Laws, Regulations, and DOE Directives.”
16.15. 48 CFR DEAR 970.5215-3, “Conditional payment of fee, profit, or incentives.”
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17.16. 48 CFR DEAR 970.5223-1, “Integration of Environment, Safety, and Health into Work
Planning and Execution.”
18.17. DOE 0343, “Stop Work.”
19.18. 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.”
20.19. DOE M 450.4-1, “Integrated Safety Management System Manual.”
21.20. DOE O 226.1A1B, “Implementation of Department of Energy Oversight Policy.”
22.21. DOE O 450.1A, “Environmental Protection Program.”
23.22. DOE O 425.1CD, “Startup and Restart of Nuclear Facilities.”
24.23. DOE O 426.2, “Personnel Selection and Training and Qualification Requirements for
DOE Nuclear Facilities.”
25.24. DOE O 414.1C, “Quality Assurance.”
26.25. DOE O 5480422.19, “Conduct of Operations Requirements for DOE Facilities.”
27.26. HNF-5183, “Tank Farm Radiological Control Manual (TFRCM).”
28.27. HNF-12125, “222-S Laboratory Documented Safety Analysis.”
29.28. HNF-14733, “222-S Laboratory Technical Safety Requirements.”
30.29. HNF-14755, “242-A Evaporator Documented Safety Analysis.”
31.30. HNF-15279, “242-A Evaporator Technical Safety Requirements.”
32.31. HNF-IP-1266, “Tank Farm Operations Administrative Controls.”
33.32. HNF-MP-5184, “Washington River Protection Solutions LLC Radiation Protection
Program.”
34.33. HNF-SD-WM-OCD-015, “Tank Farms Waste Transfer Compatibility Program.”
35.34. HNF-SD-WM-TSR-006, “Tank Farms Technical Safety Requirements.”
36.35. RPP-7725, “WRPS, LLC Project Control System Description.”
37.36. RPP-8411, “WRPS Procurement Process Description.”
38.37. RPP-13033, “Tank Farms Documented Safety Analysis.”
39.38. RPP-34909, “CH2M General Facilities Maintenance Agreement.”
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40.39. RPP-ENV-32855, “National Environmental Policy Act (NEPA) Checklist.”
41.40. RPP-ENV-32857, “Washington State Environmental Policy Act (SEPA) Checklist.”
42.41. RPP-ENV-32858, “Cultural/Ecological Review Checklist.”
43.42. TFC-BSM-AD-C-01, “Administrative Document Development and Maintenance.”
44.43. TFC-BSM-CP_CPR-C-05, “Procurement of Services.”
45.44. TFC-BSM-CP_CPR-C-06, “Procurement of Items (Materials).”
46.45. TFC-BSM-CP_CPR-C-17, “Interface Management.”
47.46. TFC-BSM-FPM_PR-C-03, “Work Control – General Purpose Facilities.”
48.47. TFC-BSM-HR_EM-C-02, “Employment.”
49.48. TFC-BSM-HR_EP-C-01, “Employee Development Planner.”
50.49. TFC-BSM-HR_EP-C-02, “Employee Discipline.”
51.50. TFC-BSM-IA-C-02, “Cooperating with Outside Audits, Inspections, and Investigations.”
52.51. TFC-BSM-IRM_SE-C-03, “Data Security.”
53.52. TFC-CHARTER-01, “Tank Operations Contractor Charter.”
54.53. TFC-CHARTER-02, “WRPS Safety Councils.”
55.54. TFC-CHARTER-09, “Flammable Gas Equipment Advisory Board.”
56.55. TFC-CHARTER-13, “Radiological Control Forum.”
57.56. TFC-CHARTER-15, “Joint Test Group.”
58.57. TFC-CHARTER-20, “Peer Safety Observer Program.”
59. TFC-CHARTER-21, “Chemical Vapors Solution Team.”
60. TFC-CHARTER-27, “Electrical Safety Committee.”
61.58. TFC-CHARTER-32, “Executive Safety Review Board.”
62.59. TFC-CHARTER-34, “Safe Work Environment Charter.”
63.60. TFC-CHARTER-41, “Lockout/Tagout Hazardous Energy Control Committee Charter.”
64.61. TFC-CHARTER-44, “Collective Significance Review.”
65.62. TFC-ENG-CHEM-P-04, “Criticality Safety Evaluations.”
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 54 of 59
May 22, 2013
66.63. TFC-ENG-CHEM-P-14, “Operating Specification Documents.”
67.64. TFC-ENG-DESIGN-C-15, “Commercial Grade Dedication.”
68.65. TFC-ENG-DESIGN-47, “Process Hazard Analysis.”
69.66. TFC-ENG-FACSUP-P-01, “Conduct of System Engineering.”
70.67. TFC-ENG-SB-C-01, “Safety Basis Issuance and Maintenance.”
71.68. TFC-ENG-SB-C-03, “Unreviewed Safety Question Process.”
72.69. TFC-ENG-SB-C-06, “Safety Basis Development.”
73.70. TFC-ENG-SB-C-09, “Plant Review Committee.”
74.71. TFC-ESHQ-AP-C-01, “Management and Specialty Assessments.”
75.72. TFC-ESHQ-AP-C-02, “Independent Assessments/Audits.”
76.73. TFC-ESHQ-AP-C-03, “Management Observation Program.”
77.74. TFC-ESHQ-FP-STD-06, “Fire Hazard Analysis and Fire Protection Assessment
Requirements.”
78.75. TFC-ESHQ-Q_C-C-01, “Problem Evaluation Request.”
79.76. TFC-ESHQ-RP_ADM-C-11, “Joint Review Group.”
80.77. TFC-ESHQ-RP_ADM-C-15, “Entry and Exit Controls.”
81.78. TFC-ESHQ-RP_RWP-C-03, “ALARA Work Planning.”
82.79. TFC-ESHQ-RP-STD-03, “ALARA Decision Making Methods.”
83.80. TFC-ESHQ-S_IH-C-02, “Hazard Communication.”
84.81. TFC-ESHQ-S_IH-C-17, “Occupational Medical Qualification and Monitoring.”
85.82. TFC-ESHQ-S_IH-C-47, “Chemical Management Process.”
86.83. TFC-ESHQ-S_SAF-C-02, “Job Hazard Analysis.”
87.84. TFC-ESHQ-S_SAF-CD-10, “Safety Communications.”
88.85. TFC-ESHQ-EP-C-01, “Emergency Management.”
89.86. TFC-OPS-MAINT-C-01, “Tank Operations Contractor Work Control.”
90.87. TFC-OPS-MAINT-C-02, “Pre-Job Briefings and Post-Job Reviews.”
91.88. TFC-OPS-MAINT-STD-02, “Work Planning and Work Instruction Development.”
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 55 of 59
May 22, 2013
92.89. TFC-OPS-OPER-C-02, “Safety Basis Implementation Checklist Preparation, Review,
and Approval.”
93.90. TFC-OPS-OPER-C-11, “Equipment Temporary Modifications and Bypasses.”
94.91. TFC-OPS-OPER-C-13, “Technical Procedure Control and Use.”
95.92. TFC-OPS-OPER-C-28, “Lessons Learned.”
96.93. TFC-OPS-WM-C-01, “Waste Planning Checklist.”
97.94. TFC-OPS-WM-C-10, “Contaminated Equipment Management Practices.”
98.95. TFC-PLN-01, “Integrated Environment, Safety, and Health Management System.”
99.96. TFC-PLN-02, “Quality Assurance Program Description.”
100.97. TFC-PLN-03, “Engineering Program Management Plan.”
101.98. TFC-PLN-05, “Conduct of Operations Implementation Plan.”
102.99. TFC-PLN-07, “Dangerous Waste Training Plan.”
103.100. TFC-PLN-10, “Assessment Program Plan.”
104.101. TFC-PLN-13, “Fire Protection Program.”
105.102. TFC-PLN-16, “Operational Readiness Program Plan.”
106.103. TFC-PLN-29, “Nuclear Maintenance Management Program.”
107.104. TFC-PLN-32, “Tank Operations Contractor Safety Management Programs.”
108.105. TFC-PLN-33, “Waste Management Basis.”
109.106. TFC-PLN-34, “Industrial Hygiene Exposure Assessment Strategy.”
110.107. TFC-PLN-39, “Risk and Opportunity Management Plan.”
111.108. TFC-PLN-47, “Worker Safety and Health Program.”
112.109. TFC-PLN-49, “Tank Farm Contractor Nuclear Criticality Safety Program.”
113.110. TFC-PLN-58, “Chemical Management Plan.”
114.111. TFC-PLN-61, “Tank Operations Contractor Training and Qualification Plan.”
115.112. TFC-PLN-71, “NESHAP Quality Assurance Program Plan for Tank Operations
Contractor Radioactive Air Emissions.”
116. TFC-PLN-73, “Environmental Protection and Compliance Plan.”
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 56 of 59
May 22, 2013
117.113. TFC-PLN-80, “Procedure Program Description.”
118.114. TFC-PLN-83, “Assurance System Description.”
119.115. TFC-PLN-84, “Tank Operations Contract Project Execution Plan.”
120.116. TFC-PLN-100, “Tank Operations Contractor Requirements Basis Document.”
121.117. TFC-PLN-102, “TOC Interface Management Plan.”
122.118. TFC-PLN-116, “Subcontractor Oversight.”
123.119. TFC-PLN-123, “Environmental Management System Description.”
124.120. TFC-POL-16, “Integrated Environment, Safety, and Health Management System Policy.”
125.121. TFC-POL-30, “Environmental Management Policy.”
126.122. TFC-PRJ-CM-C-01, “Construction Management.”
127. TFC-PRJ-CM-C-07, “Construction Notice of Intent.”
128.123. TFC-PRJ-PC-C-02, “Work Breakdown Structure and WBS Dictionary Sheet
Development and Administration.”
129.124. TFC-PRJ-PC-C-05, “Estimating.”
130.125. TFC-PRJ-PC-C-11, “Performance Indicator Program.”
131.126. TFC-PRJ-PC-C-12, “Baseline Change Control.”
132.127. TFC-PRJ-PM-C-02, “Project Management.”
133.128. TFC-PRJ-PM-C-03, “Project Categorization and Tailoring.”
134.129. TFC-PRJ-STD-02, “Control Account Manager Responsibilities and Duties.”
135.130. TO-100-052, “Perform Waste Generation, Segregation, Accumulation and Clean-up.”
136.131. Waste Services Records Material Controls Worksheets.
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 57 of 59
May 22, 2013
ATTACHMENT A - EXPECTATIONS FOR IMPLEMENTATION OF THE INTEGRATED
SAFETY MANAGEMENT SYSTEM
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 58 of 59
May 22, 2013
MANAGEMENT PLAN
INTEGRATED ENVIRONMENT, SAFETY, AND
HEALTH MANAGEMENT SYSTEM DESCRIPTION
FOR THE TANK OPERATIONS CONTRACTOR
Document
Page
Issue Date
RPP-MP-003, REV 6d
Page 59 of 59
May 22, 2013