TFC-ENG-SB-C-01, Safety Basis Issuance and Maintenance · 2019. 1. 18. · ENGINEERING SAFETY BASIS...

RPP-27195

SAFETY BASIS ISSUANCE AND

MAINTENANCE

Manual

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TFC-ENG-SB-C-01, REV F-1

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Ownership matrix

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE ................................................................................................................ 2 2.0 IMPLEMENTATION ..................................................................................................................... 2 3.0 RESPONSIBILITIES ...................................................................................................................... 2 4.0 PROCEDURE ................................................................................................................................. 3

Safety Basis Change Development ..................................................................................... 3 Safety Basis Change Review and Submittal ....................................................................... 5 Incorporation of Documented Safety Analyses Page Changes ........................................... 7 Safety Basis Annual Update ............................................................................................... 8 Limited Duration Safety Basis Changes (Addenda, ESSs, and JCOs) ............................. 11

4.6 Safety Basis Implementation and Closeout ...................................................................... 14 5.0 DEFINITIONS .............................................................................................................................. 15 6.0 RECORDS .................................................................................................................................... 15 7.0 SOURCES ..................................................................................................................................... 16

Requirements .................................................................................................................... 16 References ......................................................................................................................... 16

TABLE OF ATTACHMENTS

ATTACHMENT A – GUIDANCE FOR LIMITED DURATION CHANGES ......................................... 18

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

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1.0 PURPOSE AND SCOPE (7.1.1, 7.1.2, 7.1.3)

This procedure describes the safety basis document issuance and maintenance process, including

amendments, annual updates, addenda, Evaluations of the Safety of the Situation (ESS), and

Justifications for Continued Operation (JCO). This process applies to the three documented

safety analyses (DSA) and technical safety requirements (TSR) for the Tank Farms, 242-A

Evaporator, and 222-S Laboratory.

Development of preliminary DSAs and new DSAs for new nuclear facilities or major

modifications to existing nuclear facilities is within the scope of TFC-ENG-SB-C-06.

The safety basis document issuance and maintenance process consists of the following functions:

Updating or amending the safety basis to keep it current (i.e., to reflect changes in the facility, the work, and the hazards as they are analyzed in the DSAs);

Annually submitting to the U.S. Department of Energy (DOE), Office of River Protection (ORP) either updated DSAs for approval or letters stating that there have been no changes

in the DSAs since the prior submission;

Incorporating page changes into the DSAs associated with negative unreviewed safety question (USQ) determinations and changes resulting from review of Chapter 1 and

Chapters 6 through 17 of the DSA (included in the annual update);

Updating or amending the safety basis for limited duration changes; and

Incorporating directed changes and conditions of approval from the ORP.

This procedure applies to Washington River Protection Solutions, LLC (WRPS) personnel and its

subcontractors.

2.0 IMPLEMENTATION

This procedure is effective on the date shown in the header.

3.0 RESPONSIBILITIES

Nuclear Safety Manager – Responsible for written approval of exceptions to requirements in this

procedure.

A request for an exception to a requirement in this procedure must be provided to the Nuclear

Safety Manager in writing providing:

The procedure requirement (i.e., the specific procedure section) for which the exception is being requested;

The safety basis document to which the requested exception is applicable; and

The basis for the exception.

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Detailed responsibilities are described in Section 4.0.

4.0 PROCEDURE

Safety Basis Change Development

This section describes the process for developing safety basis updates and amendments (see

Section 4.5 for discussions on limited duration changes). Safety basis changes include updates

and amendments resulting from the change control processes for facility or document changes.

Line Management 1. Identify the need for a facility or document change.

a. For DSA development for new nuclear facilities or major modifications to existing nuclear facilities, refer to

TFC-ENG-SB-C-06.

b. For controls needed for an operation with a known end point, identify the conditions under which it will no longer be

necessary.

2. Request Production Operations; Single-Shell Tank Retrievals; Waste

Treatment Plant Support; Tank Farm Projects; Chief Engineer;

Environmental, Safety, Health, and Quality; and Project Integration

Management review the proposed change for organizational impacts,

as applicable.

Impacted

Organization

Representatives

3. Assist Line Management in the development of the change by

completing the following sub-steps.

a. Perform required analyses, evaluations, and calculations.

b. Modify impacted documents (including drawings, operating and administrative procedures, Functions and Requirements

Evaluation Documents, Safety Requirement Evaluation

Document, etc.).

c. Identify potential training and qualification impacts.

Line Management 4. Forward a description of the change to the Nuclear Safety Manager for

processing.

Nuclear Safety

Manager

5. Designate a Nuclear Safety Engineer or USQ Evaluator to coordinate

development and process the change.

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Nuclear Safety

Engineer/USQ

Evaluator

6. Review existing amendments, JCOs, ESSs, and addenda to determine

if they are impacted by the proposed change. If they are impacted:

a. Coordinate resolution of impacts and include within the scope of the change.

b. Consider interim configurations during installation of new equipment and removal of old equipment for operating

facilities.

7. Develop an update to the DSA hazard analysis (e.g., RPP-15188,

“Hazard Analysis Database Report”), as applicable.

8. If a Process Hazard Analysis is required to evaluate the hazards or if a

new hazard entry is required to be made to the DSA hazard analysis,

process in accordance with TFC-ENG-DESIGN-C-35 and TFC-ENG-

DESIGN-C-47.

9. Develop the draft safety basis change package (including DSA and

TSR redline/strikeout on the current released version of the DSA and

TSR) in accordance with the following:

Code of Federal Regulations (CFR) 10 CFR 830, “Nuclear Safety Management,” Subpart B, “Safety Basis

Requirements,” Section 830.202, “Safety basis”; (7.1.1)

DOE G 421.1-2, “Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B

of 10 CFR 830”; (7.1.2)

DOE G 423.1-1, “Implementation Guide for Use in Developing Technical Safety Requirements”; (7.1.3)

DOE-STD-3009-94, “DOE Standard – Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility

Documented Safety Analyses”; (7.1.7)

DOE-STD-1186-2004, “DOE Standard – Specific Administrative Controls”; (7.1.5) and

DOE-STD-1189-2008, “DOE Standard – Integration of Safety into the Design Process,” as appropriate. (7.1.6)

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10. Verify that existing documents added to a DSA as references in a

safety basis change are not listed in RPP-27195, “Tank Operations

Contractor Unreviewed Safety Question Process Out of Scope

Documents and Facilities.”

a. If the document is listed in RPP-27195, revise RPP-27195 to remove the document prior to implementation of the safety

basis change.

11. If, upon application of the USQ process as outlined in TFC-ENG-SB-

C-03, it is determined that the change does not require ORP approval,

attach the safety basis page changes to the USQ and exit this

procedure.

Safety Basis Change Review and Submittal

NOTE: The following steps apply to DSA changes that require ORP approval

prior to implementation (i.e., either the USQ determination performed in accordance with

TFC-ENG-SB-C-03 shows a “positive” result, or the USQ was not conducted because the

change is defined as requiring ORP approval, such as a TSR change).

NOTE: Documents should be through the review process of the providing

organization so that the DSA changes are based on accurate information.

Nuclear Safety

Engineer

1. Obtain documents used to develop the safety basis amendment.

2. Obtain peer review of safety basis amendment package by WRPS Nuclear Safety Engineer(s) who shall complete the following sub-

steps:

a. Review the change and complete the “Peer Review Checklist for Existing Safety Basis Documents” (DSA, TSRs,

Addendum, JCO, ESS) form (A-6007-121).

NOTE: Comments may be submitted via SmartPlant®1

Foundation (SPF), electronic file (with redlines and

strikeouts), hard copy (mark-up), or e-mail.

b. Provide review comments to Nuclear Safety Engineer responsible for safety basis amendment package, if applicable.

3. Provide the safety basis amendment to the Safety Basis Change Review Board (SBCRB) administrator and request SBCRB review.

4. Present safety basis amendment package to SBRCB and resolve comments.

1 SmartPlant is a registered trademark of Intergraph Corporation d/b/a Hexagon Safety & Infrastructure,

Madison, Alabama.

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5. Present safety basis amendment package briefing to Plant Review Committee (PRC) and resolve comments.

NOTE: DSA changes resulting from negative USQ determinations shall not

be submitted with Safety Basis amendments (i.e., e-mail drafts and official

submittals) without prior ORP concurrence. DSA page changes with negative

USQ determinations can either be incorporated into the DSA via separate

release documents, or may be added to the release documents for DSA

amendments approved by ORP, and put the ORP reviewers on distribution for

the release.

6. Forward e-mail draft of safety basis amendment package to the ORP.

a. Arrange face-to-face discussions with the ORP technical staff for complex safety basis amendments, when required.

7. Address ORP comments from the e-mail draft package, if applicable, by completing the following sub-steps:

a. Coordinate resolution of ORP comments with impacted organization representatives.

b. Revise amendment, if necessary.

c. If amendment has been revised and requires an additional review, coordinate a review with the impacted organization

representatives.

d. Revise and finalize amendment, as appropriate.

e. Repeat Section 4.1, Step 10, if necessary.

f. Receive e-mail documentation from the ORP that all comments have been closed satisfactorily.

Impacted

Organization

Representatives

8. Revise documents used to develop safety basis amendment, as applicable, and obtain approval.

9. If changes to the document results in a positive USQ, issue the document as part of the safety basis amendment implementation.

Nuclear Safety

Engineer

10. Ensure that the official submittal package (with the amendment attached) is prepared in accordance with TFC-BSM-AD-C-03.

WRPS Project

Manager

11. Approve and submit amendment to the ORP for approval.

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Nuclear Safety

Engineer and

Impacted

Organization

Representatives

12. Upon receipt from the ORP, review safety evaluation report and approval letter with consideration for the following:

Any directed changes or conditions of approval

Safety evaluation report implementation date is consistent with date requested.

WRPS Project

Manager

13. Notify the ORP if directed changes or conditions of approval cannot be implemented as specified in the safety evaluation report, or cannot

be implemented in a timely manner.

Nuclear Safety

Engineer

14. Coordinate resolution of ORP directed changes or conditions of approval, if applicable.

15. Proceed to Section 4.6 for safety basis amendment implementation and closeout.

Incorporation of Documented Safety Analyses Page Changes

NOTE: DSA page changes processed per this section must be submitted to ORP in

redline/strikeout format with the annual update processed per Section 4.4.

This section describes the process for incorporating DSA page changes for which negative USQs

have been determined.

Nuclear Safety

Engineer

1. Consolidate outstanding update changes (e.g., DSA page changes associated with negative USQs) into individual safety bases sections

and incorporate the changes into a redline/strikeout format.

2. Verify that existing documents added to a DSA as references during incorporation of a negative USQ determination are not listed in

RPP-27195.

a. If the document is listed in RPP-27195, revise RPP-27195 to remove the document prior to incorporation of the DSA page

change.

3. IF the wording being incorporated is different from the wording attached to the negative USQ determination:

a. IF the change is not an inconsequential change per TFC-ENG-SB-C-03, revise the USQ determination in

accordance with TFC-ENG-SB-C-03 by attaching the actual

incorporated page change to the USQ determination prior to

incorporating the change.

b. IF the change is an inconsequential change per TFC-ENG-SB-C-03, revise the DSA page change and

document that GCX-2 was applied for the change (e.g., on the

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document release form for the revised DSA) per

TFC-ENG-SB-C-03 (Section 4.4, Step 1).

4. Obtain peer review of safety basis update package by WRPS Nuclear Safety Engineer(s) who shall complete the following substeps:


Addendum, JCO) form (A-6007-121).

b. Provide review comments to Nuclear Safety Engineer responsible for safety basis update package, if applicable.

Comments may be submitted via SPF, electronic file (with

redlines and strikeouts), hard copy (mark-up), or e-mail.

5. Proceed to Section 4.6 for safety basis update implementation and closeout.

6. Include the safety basis update package within the annual update package as part of Section 4.4.

Safety Basis Annual Update

This section describes the process for developing the annual safety basis update. The annual

safety basis update includes the following types of changes:

Changes attached to negative USQ determinations;

Editorial changes; and

Changes to Chapter 1 and Chapters 6 through 17 of the DSA, as applicable.

Nuclear Safety

Manager

1. Determine the need for the preparation of one of the following

documents annually:

Updated DSA for ORP approval or

A letter to the ORP stating that there have been no changes in the DSA since the date of the previous annual safety basis

update or letter. (7.1.1, 7.1.2)

2. Designate a Nuclear Safety Engineer to coordinate the annual update

or to develop the letter.

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Nuclear Safety

Engineer

3. Complete the following sub-steps if a “no changes” letter is being

developed; otherwise proceed to Step 4.

a. Prepare the letter.

b. Ensure the letter for ORP submittal is processed in accordance with TFC-BSM-AD-C-03.

c. Exit this procedure; no additional actions are required.

NOTE: The annual safety basis update and annual USQ determination

summary report developed per TFC-ENG-SB-C-03 require separate transmittal

letters to ORP.

4. Consolidate outstanding update changes (e.g., DSA page changes

associated with negative USQs) into individual safety bases sections

and incorporate the changes into a redline/strikeout format.

5. IF the wording being incorporated is different from the wording

attached to the negative USQ determination:

a. IF the change is not an inconsequential change per TFC-ENG-SB-C-03, revise the USQ determination in accordance with

TF-ENG-SB-C-03, or distinguish the change within the safety

basis update package and submit the change to ORP for their

approval if agreed to by ORP.

b. IF the change is an inconsequential change per TFC-ENG-SB-C-03, revise the DSA page change and document that GCX-2

was applied for the change (on the document release form for

the revised DSA) per TFC-ENG-SB-C-03 (Section 4.4, Step

1).

6. Identify and include in the annual update any changes already

implemented into the safety basis per Section 0.

7. Review Chapter 1 and Chapters 6 through 17 of the DSA, to determine

whether updates are required.

a. If DSA changes are required, include in a USQ determination with DSA page changes or the safety basis annual update

package if agreed to by ORP.

8. Develop the safety basis update, including a summary of changes.

9. Develop and include a list of negative USQ determinations with DSA

page changes issued by March 31 (to meet the July 31 transmittal date)

with the annual safety basis update package, and include safety basis

change incorporation information (e.g., whether the page changes are

incorporated, and the reasoning if not incorporated).

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10. Obtain peer review of safety basis update package from WRPS

Nuclear Safety Engineer(s) who shall complete the following sub-

steps:


Addendum, JCO) form (A-6007-121).

b. Provide review comments to Nuclear Safety Engineer responsible for safety basis update package, if applicable.

Comments may be submitted via SPF, electronic file (with

redlines and strikeouts), hard copy (mark-up), or e-mail.

Nuclear Safety

Manager

11. Determine if PRC review is required:

a. If PRC review is not required, proceed to step 12.

Nuclear Safety

Engineer

12. Present safety basis update package briefing to the PRC and resolve

comments.

13. Forward an e-mail draft of the safety basis update package to the ORP

(e.g., by June 30 to meet the July 31 transmittal date).

a. Arrange face-to-face discussions with the ORP technical staff for complex safety basis updates (or complex USQ

determinations), when required.

14. Resolve any comments received from the e-mail draft submittal.

15. Receive e-mail documentation from the ORP that all comments have

been closed satisfactorily.

16. Ensure that the official submittal (with the annual safety basis update

and summary attached) is prepared in accordance with

TFC-BSM-AD-C-03.

WRPS Project

Manager

17. Approve and submit the safety basis update to the ORP for approval

by July 31 of each year.

Nuclear Safety

Engineer

18. Upon receipt from the ORP, review the safety evaluation report and

approval letter with consideration of any identified directed changes or

conditions of approval.

WRPS Project

Manager

19. Notify the ORP if directed changes or conditions of approval cannot

be implemented as specified in the safety evaluation report, or cannot

be implemented in a timely manner.

Nuclear Safety

Engineer

20. Coordinate resolution of the ORP directed changes or conditions of

approval, if applicable.

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21. Proceed to Section 4.6 for safety basis update implementation and

closeout.

Limited Duration Safety Basis Changes (Addenda, ESSs, and JCOs)

This section describes the process for developing limited duration safety basis changes. Limited

duration safety basis changes result from the design change process for non-permanent facility or

document changes (i.e., for a short duration or “one-time” activity in the nuclear facility, allowing

for an expedient removal of the change at the completion of the activity) (i.e., addenda), or from a

discovery as a result of a positive USQ issue (i.e., JCO or ESS).

NOTE: Per TFC-ENG-SB-C-03, an ESS providing a final evaluation of the problem and

specifics of how the facility has been/will be within the DSA may be submitted in lieu of a JCO

for positive USQs that can be promptly resolved (< 1 month), or the facility is in a TSR safe

mode, and no controls other than operational restrictions are required.

Line Management 1. Identify the need for a limited duration facility or document change.

2. Request Production Operations; Single-Shell Tank Retrievals; Waste

Treatment Plant Support; Tank Farm Projects; Chief Engineer;

Environmental, Safety, Health, and Quality; and Project Integration

Management review the proposed change for organizational impacts, as

applicable.

Impacted

Organization

Representatives

3. Assist Line Management in the development of the change by

completing the following sub-steps:

a. Perform required analyses, evaluations, and calculations.

b. Modify impacted documents (drawings, operating and administrative procedures, Functions and Requirements

Evaluation Documents, Safety Requirement Evaluation

Document, etc.).

c. Identify potential training and qualification impacts.

Line Management 4. Forward a description of the change to the Nuclear Safety Manager for

processing.

Nuclear Safety

Manager

5. Designate a Nuclear Safety Engineer or USQ Evaluator to coordinate

development and process the change.

Nuclear Safety

Engineer/USQ

Evaluator

6. Review existing amendments, JCOs, ESSs, and addenda to determine if

they are impacted by the proposed change. IF they are impacted,

coordinate resolution of impacts and include within the scope of the

change.

7. Develop revision to DSA hazard analysis (e.g., RPP-15188), as

applicable.

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8. IF a Process Hazard Analysis is required to evaluate the hazards or IF a

new hazard entry is required to be made to the DSA hazard analysis,

process in accordance with TFC-ENG-DESIGN-C-35 and

TFC-ENG-DESIGN-C-47.

9. Develop draft safety basis change package in accordance with

Attachment A.

10. IF upon application of the USQ process as outlined in

TFC-ENG-SB-C-03, it is determined that the change does not require

ORP approval, attach the safety basis change pages to the negative

USQ and exit this procedure.

NOTE: The following steps apply to DSA changes that require ORP approval

prior to implementation (i.e., either the USQ determination performed in

accordance with TFC-ENG-SB-C-03 shows a “positive” result, or the USQ

was not conducted because the change is defined as requiring ORP approval,

such as a TSR change).

11. If the positive USQ from a PISA can be promptly resolved (

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Impacted

Organization

Representatives

15. Review the change by completing the following sub-steps:

a. Review the change.

b. Provide review comments, if applicable. Comments may be submitted by an electronic file (with redlines and strikeouts), a

hard copy (mark-up), or via e-mail.

16. Obtain peer review of documents used to support development of the

safety basis addendum/JCO/ESS.

Nuclear Safety

Engineer

17. Present safety basis addendum/JCO/ESS briefing to SBCRB and

resolve comments.

18. Present the safety basis addendum/JCO/ESS briefing to the PRC and

resolve comments.

19. Forward e-mail draft of safety basis addendum/JCO/ESS to the ORP.

a. Arrange face-to-face discussions with the ORP technical staff for complex safety basis amendments, when required.

20. Address ORP comments from the e-mail draft, if applicable, by

completing the following sub-steps:

a. Coordinate resolution of ORP comments with impacted organization representatives.

b. Revise safety basis addendum/JCO/ESS, if necessary.

c. If safety basis addendum/JCO/ESS has been revised and requires an additional review, coordinate a review with the

impacted organization representatives.

d. Revise and finalize safety basis addendum/JCO/ESS, as appropriate.

e. Receive e-mail documentation from the ORP that all comments have been closed satisfactorily.

Impacted

Organization

Representatives

21. Revise documents used to develop safety basis addendum/JCO/ESS, as

applicable, and obtain approval.

22. If a change to the document results in a positive USQ, issue the

document as part of the safety basis implementation.

Nuclear Safety

Engineer

23. Ensure that the official submittal package (with the safety basis

addendum/JCO/ESS attached) is prepared in accordance with

TFC-BSM-AD-C-03.

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WRPS Project

Manager

24. Approve and submit safety basis addendum/JCO/ESS to the ORP for

approval.

Nuclear Safety

Engineer and

Impacted

Organization

Representatives

25. Review safety evaluation report and approval letter, upon receipt from

the ORP, with consideration for the following:

Any directed changes or conditions of approval and

Safety evaluation report implementation date is consistent with date requested.

WRPS Project

Manager

26. Notify the ORP if directed changes or conditions of approval cannot be

implemented as specified in the safety evaluation report, or cannot be

implemented in a timely manner.

Nuclear Safety

Engineer

27. Coordinate resolution of the ORP directed changes or conditions of

approval, if applicable.

28. Proceed to Section 4.6 for safety basis implementation and closeout.

4.6 Safety Basis Implementation and Closeout

This section describes the release, processing, and closeout of approved safety basis changes.

Nuclear Safety

Engineer

1. Ensure ORP approved safety evaluation report is posted on the WRPS Safety Basis Website on the Hanford Intranet, if applicable.

2. Develop a safety basis bulletin with consideration of any directed actions or conditions of approval in the safety evaluation report and

approval letter and how they relate to the USQ process.

3. Ensure the safety basis bulletin is posted on the WRPS Safety Basis Website on the Hanford Intranet.

Safety Basis

Compliance Officer

4. Process change implementation in accordance with TFC-OPS-OPER-C-02, if applicable.

5. Notify the Nuclear Safety Manager when ready to make DSA amendment effective.

Technical

Writer/Editor

6. As part of safety basis implementation, incorporate the safety basis amendment, update pages, or addendum into the safety basis for

release.

NOTE: Technical reviews have previously been performed so the purpose of

the final check in the following step is to verify that the safety basis

amendment/addendum page changes are consistent with those approved by

ORP or the safety basis update page changes are consistent with those in the

associated negative USQ determinations and to verify that all the associated

paperwork is in order.

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Nuclear Safety

Engineers

7. For safety basis amendments, safety basis updates, or addendums, complete the following sub-steps:

a. Prepare release paperwork in accordance with TFC-ENG-DESIGN-C-25 and TFC-ENG-DESIGN-C-06.

b. Check release paperwork per TFC-ENG-DESIGN-C-52 and TFC-ENG-DESIGN-P-54.

Technical

Writer/Editor and

USQ Coordinator

8. After implementation, complete the following sub-steps:

a. Validate the distribution list for the safety basis revision and submit the approved document to a Document Service Center

for controlled copy release on the first work day following the

activity.

b. Ensure safety basis record copies are updated and consistent with documentation requirements.

c. Ensure the WRPS Safety Basis Website on the Hanford Intranet is updated with the new revision.

Nuclear Safety

Engineer

9. For JCOs/ESSs, check the JCO/ESS to ensure text is consistent with that approved by ORP.

Technical

Writer/Editor or

USQ Coordinator

10. Ensure the JCO/ESS is posted on the appropriate WRPS Safety Basis Website on the Hanford Intranet.

5.0 DEFINITIONS

Safety Basis Amendment. A safety basis change that requires approval from the ORP prior to

implementation. TSR changes are categorized as amendments.

Safety Basis Update. A safety basis change that does not require approval from the ORP prior to

implementation. Safety basis updates are submitted to the ORP on an annual basis for approval.

6.0 RECORDS

The following records are generated during the performance of the procedure:

222-S Laboratory Documented Safety Analysis (HNF-12125)

222-S Laboratory Technical Safety Requirements (HNF-14733)

242-A Evaporator Documented Safety Analysis (HNF-14755)

242-A Evaporator Technical Safety Requirements (HNF-15279)

Tank Farms Documented Safety Analysis (RPP-13033), and

Tank Farms Technical Safety Requirements (HNF-SD-WM-TSR-006).

The records custodian identified in the Company Level Records Inventory and Disposition

Schedule (RIDS) is responsible for record retention in accordance with TFC-BSM-IRM_DC-C-

02, “Records Management.”

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7.0 SOURCES

Requirements

1. 10 CFR 830, “Nuclear Safety Management,” Subpart B, “Safety Basis Requirements,” Section 830.202, “Safety basis.”

2. DOE G 421.1-2, “Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR 830.”

3. DOE G 423.1-1, “Implementation Guide for Use in Developing Technical Safety Requirements.”

4. DOE G 424.1-1B, Chg 1 (March 20, 2013), “Implementation Guide For Use In Addressing Unreviewed Safety Question Requirements.”

5. DOE-STD-1186-2004, “DOE Standard – Specific Administrative Controls.”

6. DOE-STD-1189-2008, “DOE Standard – Integration of Safety into the Design Process.”

7. DOE-STD-3009-94, Change Notice No. 3, “DOE Standard – Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses.”

References

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

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

3. RPP-15188, “Hazard Analysis Database Report.”

4. RPP-27195, “Tank Operations Contractor Unreviewed Safety Question Process Out of Scope Documents and Facilities.”

5. RPP-48900, “242-A Evaporator Hazard Evaluation Database Report.”

4. TFC-BSM-AD-C-03, “Correspondence Preparation and Control.”

5. TFC-BSM-IRM_DC-C-02, “Records Management.”

6. TFC-ENG-DESIGN-C-06, “Engineering Change Control.”

7. TFC-ENG-DESIGN-C-10, “Engineering Calculations.”

8. TFC-ENG-DESIGN-C-25, “Technical Document Control.”

9. TFC-ENG-DESIGN-C-35, “Process Hazard Analysis Determination and Technique Screening.”

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

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11. TFC-ENG-DESIGN-C-52, “Technical Reviews”

12. TFC-ENG-DESIGN-P-54, “Checking of Engineering Documents.”

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

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

15. TFC-OPS-OPER-C-02, “Safety Basis Implementation Checklist Preparation, Review, and Approval.”

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ATTACHMENT A – GUIDANCE FOR LIMITED DURATION CHANGES

Limited duration safety basis changes may be processed as a Justification for Continued Operation (JCO)

or an Evaluation of the Safety of the Situation (ESS), (if part of a discovery from the Unreviewed Safety

Question [USQ] process), or as an addendum for a limited duration planned activity. (7.1.1, 7.1.2, 7.1.3, 7.1.4)

The ESS for a positive or negative USQ should include the following information:

Title

Description of occurrence or discovery and any immediate compensatory actions taken (i.e., operational restrictions).

Date PISA was discovered and ORPS report number.

Results of immediate safety assessment (including discussion of probability and consequence risk factors) and of USQD (positive/negative). Reference relevant

documents.

Results of any subsequent safety analysis developed to further support conclusions as to safety of the facility with and/or without operational restrictions/compensatory measures.

Path forward. Discuss if additional work is to be performed to resolve the issue, and anticipated completion date.

The ESS for a positive USQ should include the following additional information:

Current operational status of the facility.

Clear identification of all operational restrictions needed to maintain the facility in a safe condition.

Analysis that addresses the safety impact of the PISA with the operational restrictions removed (or with the operational restrictions in place if their removal is not proposed).

Path forward for restoring the facility into compliance with the DSA (e.g., by revising the DSA or by correcting the discrepant condition).

Summary of recommendations and conclusions.

The limited JCO and addendum duration change should include the following information, or address

why it is not necessary.

1.0 PURPOSE

The purpose of a JCO limited duration change is to document the bases for continuing to operate

facilities on a limited duration basis before the resolution of a condition that is outside of the

approved safety basis, or to permit resumption of activities that were suspended when the

condition that is outside the approved safety basis was declared. Include a brief summary of the

issue and the reason that the limited duration change is being written. Cite the ESS that transmits

or precedes the JCO, as applicable. The summary should contain a history of the problem.

Specify the condition and/or date of the JCO change closure. For example:

The safety basis amendment to be approved by the U.S. Department of Energy (DOE) Office of River Protection (ORP).

The condition that initiated the USQ or JCO change that must be resolved.

The anticipated duration of the limited duration JCO change.

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ATTACHMENT A – GUIDANCE FOR LIMITED DURATION CHANGES (cont.)

The purpose of a limited duration addendum change is to consolidate the hazard and accident

analyses, and required additional controls (if any) for a temporary change to the nuclear facility

(i.e., temporary equipment change or operational activity) and to facilitate the removal of the

change when the equipment is restored to its original condition or the operational activity is

completed.

For the addendum, specify:

The equipment modification and/or operational activity to be approved by the ORP and

The anticipated duration of the limited duration addendum change.

NOTE: Limited duration changes are temporary until the activity is completed and the addendum

is canceled.

2.0 SCOPE

Define the bounds of applicability. Define the projects, facilities, and any specific areas or

operations contained therein that are covered under the scope of the subject limited duration

change.

Include for the JCO, as necessary, a brief discussion of the safety impact of the nonconforming or

degraded condition (e.g., noncompliance with the Tank Farms Technical Safety Requirements

[TSR] [HNF-SD-WM-TSR-006,]) or regulatory noncompliance, relative to the capability of the

facility to be operated in accordance with the current safety basis.

Include for the addendum, as necessary, a brief discussion of the mission impact of the temporary

equipment modification and/or operational activity (e.g., necessity of new technology retrieval

activity for tank waste conditions).

3.0 PROPOSED COMPENSATORY MEASURES

Define the allowed operating conditions and the limited duration restrictions and controls

imposed as requirements of the limited duration change to ensure acceptable safety risk based on

the best available information, analysis, and engineering judgment, including:

For the JCO ‒

A list of terminated operations and/or specific criteria for identifying terminated operations;

Prohibitions against the performance of activities;

Limitations on the uses of the JCO change to authorize additional work or activities;

The scope of activities that will be allowed to continue under the control of the JCO change;

The credited purpose for each compensatory measure;

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The method for implementing and controlling (tracking) compensatory measures; and

Controls in the form of compensatory measures (i.e., administrative, physical, or procedural controls).

NOTE: Compensatory measures should be written in accordance with the format of

Code of Federal Regulations (CFR) 10 CFR 830, Subpart B, “Safety Basis

Requirements,” Section 830.202, “Safety basis”; DOE G 421.1-2, “Implementation

Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR

830”; DOE G 423.1-1, “Implementation Guide for Use in Developing Technical Safety

Requirements”; DOE-STD-3009-94, “DOE Standard – Preparation Guide for

U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses”;

DOE STD-1186-2004, “DOE Standard – Specific Administrative Controls”; and

DOE-STD-1189-2008, “DOE Standard – Integration of Safety into the Design Process”

as a Limiting Condition for Operation (LCO) or Administrative Control (AC), as

appropriate. This should include a description of potential conditions, required actions,

completion times, and surveillances, as necessary. The bases for the required actions

should be provided. (7.1.1, 7.1.2, 7.1.3, 7.1.5, 7.1.6, 7.1.7)

For the Addendum ‒

A list of equipment modifications and/or operational activities to be authorized within the scope of the addendum;

Prohibitions against the performance of activities, if applicable;

Limitations on the uses of the addendum to authorize additional work or activities; and

Any additional or modified controls required to conduct the activities outlined in the addendum.

Compensatory measures should be written in accordance with the format of 10 CFR 830,

Subpart B; DOE G 421.1-2; DOE G 423.1-1; DOE-STD-3009-94; DOE STD-1186-2004; and

DOE-STD-1189-2008 as an LCO or AC, as appropriate. This should include a description of

potential conditions, required actions, completion times, and surveillances, as necessary. The

bases for the required actions should be provided. (7.1.1, 7.1.2, 7.1.3, 7.1.5, 7.1.6, 7.1.7)

4.0 TECHNICAL JUSTIFICATION

Provide the technical justification and basis for approval of the risk for the allowed operations

and controls imposed by this limited duration change. That is:

Discuss why approval of the limited duration change is necessary and

Discuss why the risk of the limited duration change is acceptable.

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Risk discussions should be quantified using a method consistent with the current safety basis. As

appropriate:

Provide an estimate of the risk associated with continued normal operation after identification of the USQ (applicable to JCOs). (Reference the applicable hazard

analysis.)

Provide an estimate of the risk associated with the limited duration operation upon implementing the proposed limited duration controls. (Reference the applicable hazard

analysis.)

The justification should describe how the existing facility hazard controls/restrictions, in

conjunction with additional limited duration controls/restrictions, would maintain safe conditions

during the proposed continued operation.

If a USQ determination is not associated with the limited duration change, provide supporting

analysis to quantitatively or qualitatively identify the increase in risk that the ORP is requested to

approve.

The USQ determination questions should be used as guidance. Discussion should be provided for

those questions that would be answered “Yes.”

The justification should describe any special conditions or time constraints that pertain to the

operation of the facility.

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