INTEGRATED ENVIRONMENT, SAFETY, AND Manual … · The scope of this document includes the WRPS ISMS policies, programs, processes,

USQ #13-0660-S

INTEGRATED ENVIRONMENT, SAFETY, AND

HEALTH MANAGEMENT SYSTEM

DESCRIPTION FOR THE TANK OPERATIONS

CONTRACTOR

Manual

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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

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HEALTH MANAGEMENT SYSTEM DESCRIPTION

FOR THE TANK OPERATIONS CONTRACTOR

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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

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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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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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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.”

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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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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.

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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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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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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.”

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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.”

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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.”

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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




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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




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RPP-MP-003, REV 6d

Page 58 of 59

May 22, 2013

MANAGEMENT PLAN




Document

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Issue Date

RPP-MP-003, REV 6d

Page 59 of 59

May 22, 2013