Impacts of Facility Design in Facility Management by mmz11521

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									Integrating Management Systems across
    Life-Cycle and Functional Areas:
        DOE Savannah River Site
      Salt Waste Processing Facility
        Presenter: Dr. Tom Helms, Parsons
                     Sponsors
 James McCullough, DOE-SR Federal Project Director
David Amerine, Parsons Senior VP and Project Manager
 Jack Kasper, Parsons VP and Design/Build Manager
              Introduction
   Salt Waste Processing Facility
    (SWPF) is a DOE Capital Acquisition
    Project
   Presently in Final Design/Limited
    Construction Life Cycle Phase
   Approved Documented ISMS (Phase
    I) for Design and Construction
                  Purpose
   Describe the importance and central
    elements of ISMS in the Design Phase for
    a DOE nonreactor nuclear facility

   Describe the interactions between Scope
    refinement, hazard analysis, hazard
    control selection and feedback
    mechanisms

   Discuss Lessons Learned and
    Recommendations for Improvement
    Background: SWPF Mission
   Decontaminate ~38 million gallons of
    Salt Waste stored in SRS H and F
    Tank Farms

   Salt Waste composed largely of
    fission products mixed with
    concentrated caustic (NaOH) +
    nitrate
Background: Regulatory Drivers

   Federal Facility Agreement Negotiated
    Pursuant to CERCLA

   Site Treatment Plan Developed
    Pursuant to the Federal Facility
    Compliance Act
         Background: Salt Waste
               Disposition
   Concentrate will be immobilized in
    glass/stainless steel
    • Interim Storage: Glass Waste Storage Facility
    • Final disposition: Geologic Repository


   Decontaminated salt waste will be
    immobilized in grout
    • Final disposition: SRS Saltstone Disposal
      Facility
        Background: Technological
               Challenge
   Reduce volume of caustic waste requiring
    vitrification

   Technological Challenge – separate 137Cs+1 ions
    from a solution dominated by Na+1 ions

   The 2 monovalent species “want” to go to the
    same places chemically speaking: what removes
    Cs+1 will tend also to remove Na+1
 Background: Basic Processes
 137Cs removal with Caustic Side Solvent Extraction
  (CSSX)
     Solvent contains BOBCalixC6: High affinity for Cs over both
      Na and K
     BOBCalixC6 is a crown ether developed at ORNL
     Dissolved an Isopar® solution (~ refined kerosene)


 90Sr + actinides removed with an adsorbent –
  filtration process
     Adsorbent – Monosodium Titanate (MST)
     0.1 micron crossflow filter
               Current Status
• Preliminary Design Completed

• Project ISMS Description Approved 2/07

• CD-2 Approved end of FY07

• Final Design Underway

• Early Construction Underway (“CD-3A”)

• Final Design Complete 8/08

• CD-3 Approval 9/08

• Construction Complete – 2012

• Operations Begins - 2014
           Phase approach to ISMS
               Implementation
   Conceptual Design              ISMS System Description
    Approved CD-1                   “concurred upon” – no
                                    verification

   Preliminary Design CD-2        ISMS System Description for
    Approval of Technical           Design and Limited
    Baseline                        Construction approved based
                                    on DOE Phase I Verification
                                    Assessment (Feb 07)
   Final Design Approved CD-       Phase II Verification for
    3 Start Construction        
                                    Construction
   CD-4 Start Hot Operations       Phase I/II Verification
                                    conducted with the ORR
      ISMS for the Design Phase
   We typically think of ISMS in the context of
    active hazardous situations – operations,
    construction, & maintenance

   The ISMS precepts fit very well with the design
    process for a Hazard Category II Facility,
    permitted as an Industrial Wastewater Treatment
    Facility

   The complex interplay between the various
    hazard analyses and design require close
    attention to Integration among the technical and
    safety disciplines
            Design versus
    Construction/Operations Phase
               Hazards
   Latent versus active hazards

   Knowledge worker errors versus
    crafts and labor incidents

   Lower frequencies/high consequence
    versus higher empirical frequencies
                                            Mission
                                   NEPA Record of Decision

                             Engineering, Procurement and
                                 Construction Contract


                        Preliminary Project Execution Plan
  Documented
ISMS for Design

                                              Design
                                              Control
    Scoping             Hazard              Functional            Change               Review,
   Documents          Analysis &           Classification         Control           Assessment,
                        ALARA               Procedures          Procedures              & CAP
                      Procedures                                                     Procedures


 Define Scope        Analyze Hazards       Hazard Controls      Work within       Feedback for
                                                                controls          Improvement
 EIS/ROD            HAZOP                Functional  Class
 Contract           PDSA                  Documents                             Internal/External
                                                                Design Control
 S/RID              FHA                  P&ID Functional                        Design Review
                                                                Configuration
 WAC                Shielding   Models    Classification                        Assessment   Program
                                                                 Management
 Basis of Design    ALARA                 Boundaries                            Condition Reports
 Codes of Record    Emission   Models    Fire Protection                       Employee Concerns
 Functional Spec.   Code   Review         P&IDs                                 Lessons Leaned
 Conceptual &                                                                    Correct. Action Prog.
 Preliminary Draw.
    Summary of Hazards & Analyses
   Nuclear: Draft Preliminary Documented Safety Analysis & Draft
    Nuclear Criticality Safety Evaluation

   Fire: Fire Hazard Analysis

   Radiological: ALARA Analysis for Preliminary Design

   Environmental: Permits, Exemption Packages w/Emission Models,
    Impacts, Objectives, Targets, and EMPs

   Chemical & Standard Industrial: Industrial and Chemical Safety
    Design Review

   Natural Phenomena Hazards: Dynamic Structural Analyses

   “Integrated Hazard Analysis”: HAZOP
                  Nuclear Hazards
   Per DOE-STD-1027: Hazard Category 2 Nuclear Facility

   Evaluation Guide of 25 rem per DOE-STD-3009: Max. Off-Site
    TEDE is < 1 rem

   No Safety Class hazard controls credited in Draft PDSA

   Safety-related controls credited in Draft PDSA for facility
    worker: Safety Significant Systems, Structures and
    Components (SSCs)

   Criticality: Nuclear Criticality Safety Evaluation (NSCE) in
    development
          Radiological Hazards
   Confinement ventilation – radiological
    zoning

   Salt waste contains 137Cs and its
    daughter, 137Ba → g
   Shielding analysis is an integral
    component of the design process for
    safe operation and maintenance
              Chemical Hazards
   Process uses no highly hazardous chemicals per
    • 29 CFR 1910.119, Process Safety Management
    • 40 CFR 68, Chemical Accident Prevention

   Actinide/Sr removal uses aqueous, high pH (>14) caustic at
    “room temperatures and pressures”

   CSSX Solvent is predominantly hydrocarbon w/low vapor
    pressure, with a FP of 150 oC

   CSSX Solvent is not an “F Listed Solvent” or potential RCRA
    hazardous waste

   Cold Chemicals: Caustic, 20% Nitric Acid, Oxalic Acid
          Environmental Hazards
   Virtually no operational releases to environment

   Permitted as an Industrial Wastewater Treatment Facility
    (WTF)
    • “Intermediate Treatment Facility:” Discharges only to other
      permitted WTFs for final treatment and disposition

   No significant air emissions or air permits required
    • Room temperature processes
    • Offsite Dose from operations below 10-4 mrem/year
    • CSSX Solvent has very low vapor pressure (~0.3 torr or ~10 -4
      atm) with resulting low organic loss to atmosphere

   No wastewater discharges to the environment

   Chemical and fuel storage facilities covered and enclosed,
    i.e., no Industrial Storm Water issues
        Std Industrial Hazards
   Overhead Cranes
   Electrical
   Compressed Gases
   Walking & Working Surfaces
   Lighting
   Sanitation
   Combustible liquids
   Corrosive process chemicals
 Integrating Safety Into Design
The “I” in ISMS is critically import at all
  phase but is of penultimate importance
  during design

  • ES&H Disciplines must effectively Integrate
    with Design

  • ES&H Disciplines must effectively Integrate
    with each other

  • New Facilities must effectively integrate with
    the site infrastructure
SWPF Design: ISMS at the Facility-Level
                        Site

                       Facility
   Interface Control Documents 1-21

                      Activity NCSE
             PDAS       JHA
                         D
                         D      ALARA      Emergency
                        SWP
                               Analysis   Management
   Site        Facility
 Permits       Permits
                              FHA



            Security     Waste Management




           Site-Level Integration
Site Integration – Interface Control
            Documents
              SRS –SWPF ICDs
   ICD-02 Domestic Water System       ICD-12 Emergency Response
   ICD-03 Radioactive Solid           ICD-13 Telecommunications and
    Waste, Mixed Waste, and             Control Datalink System
    Hazardous Waste                    ICD-17 Fire Protection Water
   ICD-04 Stormwater                   Supply
   ICD-05 Radioactive Liquid          ICD-18 Work Controls
    Effluents                          ICD-19 Permitting and
   ICD-06 Liquid Sanitary Wastes       Monitoring Requirements
   ICD-07 Facility Siting             ICD-20 Training
   ICD-08 Electrical Power            ICD-21 Non-Radioactive Solid
    Distribution                        Waste
   ICD-09 Roads and Rail Systems      ICD-22 Document Control
   ICD-10 Waste Transfer System       ICD-23 Project Financial
   ICD-11 Waste Treatability           Reporting
    Samples                            ICD-25 Interface Management
                                        Plan
    Hazard & Scope are a functions of
              One Another
   Initial scope derives from CERCLA Hazardous Ranking Score
    (40 CFR 300): National Priorities List (NPL) Federal Facility
    Agreement (FFA) and Tank Farm Milestones

   Scope is further refined through Alternatives Selection and
    the NEPA Environmental Impact Statement (EIS): a
    quantitative evaluation of the risk and hazards of each
    Alternative

   DOE Contract contains further scoping through qualitative
    judgments about the hazards that lead to the stipulated
    ES&H design criteria and standards to protect the worker,
    public and environment

   Final refinements to the scope occurs as the various hazard
    analyses are initiated, refined and completed to support the
    conceptual, preliminary and final design
            Simplified View of the Design Phase ISM

                                  EIS Alternatives          Record of
         Mission Need




                                                                             Define Scope
                                     Analysis               Decision

                                     Contract


                   Feedback                             Feedback




                                                                                            Design Change
                                      S/RID
                                  Codes of Record




                                                                                                Control
(Perform Work)
 Engineer Safety




                   Draft Design                 Hazard Analyses:
   Into Design




                                                     PDSA
                                                      FHA
                     Revised        Feedback         NCSE
                     Design                     Shielding Models    Authorization Basis
                                                Emission Models      • DSA/TSR
                                                                     • Safety Management
                   Final Design                   Engineered           Programs
                                                Hazard Controls      • FHA
                                                                     • Permits
     Conceptual Design
     PFD, GA, P&ID                                    Preliminary Hazard Analysis
   Critical Decision 1
                                           Design Input


     Preliminary Design
     PFD, GA, P&ID       Rev A, B, C, …x             Draft PDSA    Rev A, B, …y
                                                     FHA
                                                     ALARA
                                                 Hazard Controls


   Critical Decision 2




     Final Design
     PFD, GA, P&ID       Rev A, B, C, …0
                                                            PDSA Rev A, B,…0
                                                             FHA
Simplified view of the                                       ALARA
Integration of
Design and Safety
Analysis
   Hazard Controls Interactions

            ALARA                Interlocking between the
           Confine &              respective hazard analyses &
            Shield                controls requires effective
    Air
                                  integration between ES&H
                                  disciplines
  Emission PDSA        NCSE
   Models
                                 In design of a nuclear facility
             FHA                  balancing priorities is a day-to-
Chemical                          day reality
Hazards
                                 The control selection preference of
       Industrial                 one ES&H discipline may be
        Hazards                   anathema to another
      Examples of Hazard Control
             Interactions
   Dynamic seismic analysis for piping and,
    ALARA and radiation shield modeling
          Bends and curves enhance seismic stability but
           increase potential dose during future maintenance
           evolutions (less pipe is better)


   Deflagration prevention requirements and
    environmental emission requirements
          Radiolytic explosive gas generation
            • Environmental – Preference for inert gas blanket to
              eliminate emissions
            • Safety – Active ventilation to avoid use asphyxiates
           Integration Tools
   Organizational Structure

   Mandatory Intra Discipline Reviews

   HAZOP Reviews at each life cycle
    phase
    Integration Tools: Organization
•   Organizational Paradigm in Operating Facilities or
    Construction Projects is to place ES&H Disciplines in a
    separate ES&H Organization

•   During design phase, the hazard analyses conducted for
    nuclear safety, fire protections, radiation protection,
    environmental protection, etc. have direct input into the
    line product: Design

•   SWPF Nuclear Safety and Fire Protection have such a
    significant role in the design, they are in the Design Build
    organization

•   ESH&Q Manager and ES&H Subject Matter Experts have a
    strong oversight role through the Inter Discipline Review
    process and the Design Change process
            Integration Tools:
      Intra Discipline Review (IDR)
   All design outputs are reviewed (IDR) by the
    respective environmental, safety and health
    SMEs to verify that controls are integrated in
    design

   Comments from ES&H SMEs and all reviewers
    must be addressed and the resolution formally
    concurred upon by the reviewer

   Design Change Control Process: Multidiscipline
    Design Change Request review process and
    Change Control Board
       Integration Tools: HAZOP
   HAZOP - HAZard and OPerability analysis

   The Project has conducted in depth HAZOP Reviews with
    each design phase and life cycle phase

   HAZOP conducted over 3 week period with members of all
    disciplines:
    • Sponsored by the Design Build Manager
    • Nuclear Safety, Radiation Protection, Fire Protection,
      Environmental Protection, Industrial Hygiene and Safety
    • Operations, Maintenance, Process Engineering, Balance of Plan
      Engineering: Structural, Piping, HVAC, I&C

   Formal multidiscipline, step-by-step review of facility design
   Integration Tools: HAZOP
                  (Continued )
Senior Management tracks the closure of HAZOP
recommendations as a Monthly Key Performance Indicator
       ISMS Through Life Cycle Phases

                            Design                   Construction
                             Phase                      Phase




1.   Scope              Contract/Design Rev. n-1   Work Package
2.   Hazard Analysis    Latent Hazards             Active Hazards
3.   Hazard Control     Engineered Control         More Admin/PPE Controls
4.   Ensure Readiness   Change Control             Pre Job Briefings
5.   Work within        Configuration              Oversight &
     Controls           Management                 Self-Assessment


                        Feedback and Improvement
    ISMS and Lifecycle Transitions
   Design – Facility Level ISMS + Interface Control

   Construction – Activity Level ISMS + Interface
    Control

   The Management System Elements that support
    effective ISMS stay the same across lifecycle
    transitions

   Whether a JHA or a PDSA the Safety Culture is
    the fuel that drives an Effective ISMS
       Transition Across Life Cycles




                                                                                                                       Organization
                                                                                                     Project Control
Fundamental       Assessment                                     Safety Conscious
Management         Program                                       Work Environment




                                                                                                     Planning &
   System
                             Qualifications




                                                                    Action Manage.



                                                                                     Configuration
                                                  Expectations
                                                  Management




                                                                                     Management
                  Training




  Elements


                                                                      Corrective
Are the Pillars
& Foundation
That Support
 Transitions
   between
  Life Cycle                                  Standard/Requirements
                                                   Management
            Lessons Learned
   DOE Directives provide a solid framework
    for analyzing latent hazards in the design
    process

   The expectations for selecting and
    developing hazard controls could be
    refined

   The least glamorous ISMS Core Function,
    “DEFINE SCOPE OF WORK” is where we
    need to focus for design-build projects
    DOE Directives Define Scope That
     Directly Impacts Facility Design
   Laws, regulations, and …even DOE Directives have conflicts
    and ambiguities that require interpretation by Lawyers,
    Managers and Subject Matter Experts

   Variation in interpretation is inevitable: GREAT MINDS DO
    NOT ALWAYS THINK ALIKE

   In matters other than statutes and regulations, there may
    be no clear authority for adjudication on points of difference

   Licenses, Permits, and Consent Agreements are used to
    assure mutual understanding between regulators and the
    regulated

   DOE is not quite a regulator (Title 10 aside)

   DOE is commonly a contracts manager
      PC-2 vs PC-3 DOE-STD-1021
  Performance Category (PC). Classification using a graded
  approach in which structures, systems, or components in a
  category are designed to ensure similar levels of protection …
  during natural phenomena hazard events. DOE G 420.1-2

  DOE-STD-1021
                                       SWPF has no safety class SSC
PC-3:
SSC failure has adverse release
consequences greater than
safety-class SSC Evaluation
Guidelines, but not severe
enough to place it in PC-4.

                                       SWPF has safety significant SSC
PC-2:
SSC is classified “safety-
significant.”

                                                SWPF is PC-2?
    PC-2 vs PC-3 DOE G 420.1-2
DOE G 420.1-2                             Based on DOE-STD-1021,
PC-3 SSCs whose failure to perform        SWPF Preliminary Design
their safety function could pose a               was PC-2
potential hazard to public health,
safety, and the environment
                                               SWPF is PC-3?
because radioactive or toxic
materials are present and could be
released from the facility as a result
of that failure.                          After Preliminary Design,
                                         SWPF was classified as PC-3

PC-2 SSCs are meant to ensure the
operability of essential facilities
(e.g., fire house, emergency             Enhanced Preliminary Design
response centers, hospitals) or to
prevent physical injury to in-facility
workers.
           Recommendation
   Operations Authorization Agreement
    • Established in DOE M 411.1-1C: Defines
      the terms and conditions by which DOE
      approves and the contractor conducts
      the safe operation of a nuclear facility,
      e.g., TSRs, USQ Process, etc.


   Why not a “Design Authorization
    Agreement”?
Design Authorization Agreement
• Establish the criteria to be used in the design
  of nuclear and any other hazardous facility @
  CD-1 or the start of Preliminary Design

• Conceptual Design and PHA completed – first
  order hazards should be well characterized

• Reviewed and approved by DOE CTA, Chief
  Operating Officer and Field Element Manager,
  and with concurrence from the DNFSB, and
  state and Federal environmental regulators
                       Summary
   The framework for ISMS is well established for DOE Design
    Build Projects

   Integration among ES&H Functional Areas and the Design
    Organization is crucial

   Multidiscipline HAZOP provides effective tool to enhance
    integration

   ES&H Disciplines need to be part of or closely aligned with
    the line organization during design – hazard analyses are a
    design input

   Recommend development of a “Design Authorization
    Agreements” to preclude “in process” scope changes for
    future Design Build Projects

								
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