Update on EM Corporate Strategic Issues related to Safety, Quality, and Security

Dr. Steven L. KrahnActing Deputy Assistant Secretary Safety and Security Programs, EM-20

December 10, 2009

Presentation to EFCOG Semi Annual MeetingDecember 9-10, 2009

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Briefing Overview

EM-20 Function and Corporate role

High Priority Corporate Issues• American Recovery and Reinvestment Act (ARRA) projects• Construction/Capital Projects• Standard Review Plan (SRP)• Generic quality assurance issues impacting EM projects

– Commercial grade dedication (CGD)– Application of graded approach– Procurement/Flow down– Monitoring of vendor and subcontractors performance– Capacity and adequacy of available NQA-1 qualified staff and vendors

• Work planning and control• Electrical safety update

Trends and observations

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EM-20 Overview

The mission of the Office of Safety & Security Program, EM-20, is to manage DOE/EM-wide Integrated Safety Management (ISM) implementation oversight activities, the Defense Nuclear Facilities Safety Board (DNFSB) recommendations and issues, standards assurance for major project planning and execution, operational safety and awareness programs, quality assurance programs. The Office manages the safeguards and security and emergency management activities for EM.

EM-20 Management Team• Safety Management, EM-21, Dr. Chuan-Fu Wu

– Responsible for ensuring proper implementation and continuous improvement of ISMS in the EM complex and to serve as a focal point for EM safety standards and policy development, interpretation, and interfaces with internal/external oversight organizations, including DNFSB .

• Safety Operations Assurance, EM-22, Dr. Robert Goldsmith– Responsible for determining the effectiveness of safety and health oversight programs and

management systems, such as operational awareness activities, conduct of operations, work planning and execution, and assessments; also, providing day-to-day awareness of operational safety issues, EM sites, and helps ensure timely identification and correction of deficient safety conditions.

• Standards & Quality Assurance, EM-23, Mr. Bob Murray– Responsible for ensuring that the necessary technical, and quality requirements and standards are

properly identified and adequately implemented for all line-item, EM capital projects and major operating projects and facilities in a timely and technically defensible manner.

• Safeguards & Security, EM-24, Mr. Karl Goodwin– Responsible for developing and overseeing the implementation of policy and guidance with respect

to safeguards, security, and emergency management.

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EM-20’s Operational Strategy

Corporate resource to advance safe execution of EM mission

• Build on and leverage partnership with the Field, Federal Project Directors, and EFCOG

• Serve as EM-HQ advocate to address institutional and generic safety, health, quality assurance, and security issues impacting EM projects

• Work in cooperation with Field management to address major site-specific safety, health, quality assurance and security issues

Balanced and Risk-informed Operational Approach--- Awareness, Assessment, Assistance

• A primary role of HQ is assisting the Field to achieve mission success • EM-20 contributes vitally to the achievement of mission outcomes and is

accountable for the quality, timeliness, and efficiency of its efforts, products, and support to the Field

• Assessment efforts and assistance provided to the Field are not intended to displace or supersede the authority, or accountability, of Field Managers for the performance of their mission

• The EM-20 Business Model emphases performing support functions in a proactive manner, not on simply identifying issues

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Implementation

Operational AwarenessOperational Awareness

Programmatic and Infrastructure

Programmatic and Infrastructure

INTEGRATED ANALYSIS

FOCUSED Audits and Technical Reviews

Awareness Assessment Assistance

SMEs, Risk-informed Decision-making, and

Outreach & Awareness

Field Managers Requests

Action to Continuously Improve Safety, Quality and Security

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High Priority Corporate Issues

• American Recovery and Reinvestment Act (ARRA) projects

• Construction/Capital Projects

• Generic Quality Assurance Issues Impacting EM Projects– Commercial grade dedication (CGD)– Application of graded approach– Procurement/Flow down– Monitoring of venders and subcontractors performance– Capacity and adequacy of available QA staff and NQA-1 qualified

venders

• Tailoring Security

• Work Planning and Control

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ARRA Projects

Unprecedented opportunity to accelerate cleanup activities• Reduce EM sites footprint, risk and future costs• Generate meaningful jobs for over 12,000 workers

EM senior management expectation to ensure ARRA work surge is planned and conducted to meet the high safety standards and performance expected within EM.

• Safety/Security must be integral and robust from the beginning of this effort.

Developed and implemented Project Safety Oversight Plan and Recovery Act Readiness Evaluation (RARE) process.

• Site-wide programs and processes in place, however, not sufficient to guarantee safe implementation of work .

• Requires increased Field oversight and focus on direct observation of work.

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Capital/Construction Projects

Focus on EM capital projects: DUF6, SRS Pit Disassembly and Conversion Facility and the Plutonium Preparation Project, WTP, SWPF, ORNL U-233 Disposition (Building 3019), K-Basin, IWTU

EM-10 now leads Validate readiness to proceed to the next project phase

• Review of project development and execution at each Critical Decision (CD) phase

• Verify that project progress and performance is consistent with agreed upon contract terms and conditions, project specifications, ES&H requirements, budget and schedule

Technical Cost, Schedule, and Risks Construction Process Management Environment, Safety, Health (ES&H) Quality Assurance Commissioning

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Commercial Grade Dedication

Commercial Grade Dedication (CGD) is performed to establish the acceptability of an item to perform its safety function.

Due to current nuclear market realities, there is greater reliance for EM capital projects (construction and operation) on the procurement of components either through alternative suppliers or by purchasing commercial grade items and dedicating them for safety-related use.

Critical for all EM projects within EM to assess their own vendors and suppliers for how CGD is currently being defined and implemented.

EM-2 memorandum dated October 6, 2009

• An evaluation of CGD practices and actions should be conducted across the entire scope of construction and operational projects at EM sites, from prime contractors to vendors, to suppliers and their sub-tier suppliers, with first a focus on construction projects that are procuring items and materials for nuclear grade applications

• Summary of the results of the evaluations were due by November 30, 2009

• Need EFCOG support to ensure all sites follow-up

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QA Corporate Board

Current QA Corporate Board efforts– Closeout of subgroups from FY-2009– Determine top 3-4 project focus areas for 2010– Revise project plan– Update QA Corporate Board Charter– Meeting scheduled for February 9, 2010, in Las Vegas to vote on path

forward

EFCOG support of QA Corporate Board– EFCOG support of the above subgroups– Review of deliverables

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Safety Trends and Observations

Trends and observations in operational and worker safety issues,• Electrical safety• Industrial accidents• Attachment graphs/charts• Need for focus on “routine work” conducted in “hazardous environments”

Update on Safety Conscious Work Environment (SWCE) Rulemaking• Rulemaking process• EFCOG role and support

Update on ISM and QA Annual Declaration, Goals/commitments• Most sites have provided ISMS Declarations/Descriptions• EM-20 has started multi disciplinary review of submittals• Comments addressing continuous improvement of the EM process welcome

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Safeguards and Security Trends and Observations

Trends and observations in safeguards and security

• Key performance issues

- Development of performance metrics/milestones vs. LOE

- Succession planning

- Balancing protective force capabilities with evolving/redefined threat

• Emerging issues

- Interagency Security Committee (ISC); led by GSA and HS, looking at protection standards for non-military Federal facilities

- Continuing need for risk – informed approaches

• EFCOG role and support

- Best practices

- Realism in exercises – both security and emergency management

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Work Planning and Control

Work planning issues and challenges• Key performance issues• Emerging issues

- what gets into ‘the system”

- feedback of experience

DNFSB March 2009 Letter on this topic referenced:• Incomplete hazard analyses• Complex and confusing work planning directives,• Errors in the development of work packages for routine but not necessarily simple or low-

hazard tasks, and • Inappropriately modified hazard controls .

EFCOG role and support

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Electrical Safety Activities

EM appreciates EFCOG Electrical Safety Working Group’s many improvement activities and development of tools that helped make DOE-wide electrical safety improvements since 2005.

EM Recent Improvement Actions:• Issued memorandum to field to implement new provision in 2009

edition of NFPA 70E regarding protection from “look alike” equipment and encourage use of 2009 NFPA 70E.

• Developed and directed field use of CRAD to evaluate electrical safety practices and work activities.

• Shared Oak Ridge arc flash lessons learned with EM Field Managers• Challenge of ARRA work

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EM Electrical Safety Performance

EM performance shows improvement long term EM made progress in maintaining improved performance in avoiding

electrical hazards typical of D&D work (excavation and overhead electric line strikes; drilling/striking facility electrical lines)

FY09 showed slight overall improvement over FY08; however, recent increasing occurrence trend shows:• Large increase in LTA LOTO execution• Increasing involvement by prime contractor electrical workers in

occurrences• Concern due to frequency and increased severity of events (3 arc

flashes; 1 with serious burns since March)

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EM Electrical Safety Challenges

EM Electrical Safety Metrics(Normalized per 1000 worker-years)

00.20.40.60.8

11.21.41.6

Shock

Burn

Arc F

lash

LOTO

Excav

ation

Cuttin

g/Drill

ing

Vehicl

e

Subco

ntra

ctor

Electri

cal W

kr

Non-E

lectri

cal W

kr

Elec R

epor

ts

Incident Metrics

Inc

ide

nt

Re

po

rts

pe

r 2

Mill

ion

W

ork

ho

urs

FY 2008 FY 2009

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EM Electrical Arc Flash Events – Learning Points

Little or no work planning for electrical work; deviated from work package; weak work pre-briefings; too much reliance on skill of the craft

Working on energized equipment or failure to test equipment to ensure it is de-energized prior to working

Not recognizing “look alike” equipment that may be energized

Not wearing electrical personnel protective equipment or wearing inadequate PPE for the electrical hazard

Lack of supervision or supervisory intervention when needed

Failure to stop work after recognized changing conditions

LTA LOTO

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Key Takeaways

EM-20 operational approach is based on a balanced and risk-informed approach to ensure EM corporate priorities, expectation, and requirements are effectively and efficiently met

EM-20’s function is to serve as a corporate advocate to ensure consistency, stability, and technical transparency in corporate decision making

• Promotes accountability, cost-effectiveness, and efficient execution of EM mission

Our collective success depends on active EFCOG and contractor community participation, input, and engagement