James J. Klos, Daniel C. Robertson, A. Jeanne Weyandt
Westinghouse Electric Corporation
Waste Isolation Division
U.S. Department of Energy
Carlsbad Area Office
P. O. Box 2078
Carlsbad, New Mexico 88220

To address safety management issues raised in Defense Nuclear Facilities Safety Board recommendations, the U.S. Department of Energy (DOE) and its contractors are institutionalizing controls necessary to achieve common environment, safety, and health objectives. The amended DEAR (Department of Energy Acquisition Regulation) Clause 970.5204-2, Integration of Environment, Safety, and Health Into Work Planning and Execution, is a modification incorporated into the Westinghouse Electric Company's Waste Isolation Division (WID) Fiscal Year 1998 performance-based contract for the management and operation of the Waste Isolation Pilot Plant (WIPP). This paper summarizes actions WID has taken to address requirements of the ES&H clause and position the division for Integrated Safety Management System Verification by a DOE Review Team.

WIPP is a geologic repository, constructed to provide underground disposal for DOE's defense generated transuranic waste. Located 2,150 feet (655 meters) below the earth's surface in bedded salt, the WIPP site occupies 10,240 acres (4,146 hectares) in southeastern New Mexico, approximately 26 miles (41.6 km) from Carlsbad. The fenced area within which most of the WIPP facility surface structures are located is known as the Property Protection Area and covers about 35 acres (14 hectares). The transuranic waste to be disposed of at WIPP comes from the DOE's nuclear weapons production and dismantlement, and research and development activities. Examples of transuranic waste range from unprocessed laboratory trash (such as tools, paper, glassware, or gloves) to solidified waste water treatment sludge contaminated with plutonium and other radioactive elements.

As the phased development of the WIPP facility progressed from siting to pre-disposal, safety was "woven" into every operation. Measures to protect the worker, the public, and the environment were factored into facilities and systems designs, operating procedures, and employees' job responsibilities and requirements. In preparation for opening this one-of-a-kind facility in 1998, the WID used a Line Management Assessment approach to achieving readiness for contact handled (CH) waste disposal operations. This approach consisted of a formal review and assessment of waste disposal and supporting processes, an integrated facility checkout (IFC), and a performance dry run (PDR) of the CH waste disposal process. The purpose of the IFC was to place WIPP in an "operational mode" so that planned waste disposal functions could be performed and assessed at anticipated waste receipt rates with simulated waste packages. The PDR evaluated waste disposal operations end-to-end, from a waste generator site to emplacement in the WIPP repository. The PDR also included an evaluation of the implementation of conditions and requirements from the WIPP Safety Analysis Report and Technical Safety Requirements Document. Since October, 1997, WIPP has been maintained in the Waste Handling Mode, a minimum of four days a week. Maintaining this operational mode enables each organization to know and understand its primary and supportive roles relative to the receipt of waste and to adopt an integrated approach to problem solving and issue resolution. Proper protocols are being followed as if actual waste containers are in waste handling, storage, and disposal areas. An evaluation of WID safety management practices has been an implicit part of WID's thorough reviews of the planned operation and oversight of the WIPP facility. Each of the 18 core requirements used by WID management for evaluating nuclear facility readiness addresses various aspects of the safety management principles and functions delineated in DOE P450.4, Safety Management System Policy. The paper entitled "A Process for Operational Readiness at the Waste Isolation Pilot Plant," authored by the WID General Manager, discusses the Line Management Assessment approach and lists the core requirements.

Contracting practices, negotiated in the context of Contract Reform and incorporated into WID contracts as early as Fiscal Year (FY) 1995, have kept environment, safety, and health in the forefront of WID operations and hold line managers accountable for the safe performance of work. These practices include the development of the list of applicable safety requirements, a DOE-approved Standards/Requirements Identification Document, and performance-based incentives encompassing worker protection actions and activities required to maintain the WID's Voluntary Protection program STAR status.

At the DOE Safety Management Systems Lessons Learned Workshop, held in Albuquerque, New Mexico in February 1998, an attorney from the Office of General Counsel, Civilian Nuclear Programs, reiterated the requirements of DEAR 970.5204-2, Integration of Environment, Safety, and Health Into Work Planning and Execution. The Westinghouse approach to meeting the requirements is discussed in this section.

Integrated Safety Management (ISM) serves as the umbrella program for the WID and encompasses environment, safety, and health functions and activities that protect employees, the public, and the environment. Safety-related initiatives are tools used to implement ISM. WID's "STAR" status recognition from DOE's Voluntary Protection Program in October 1994, for example, is the methodology used to demonstrate the importance of our health and safety programs. The division's Environmental Management System, which was certified to International Standards Organization 14001 criteria in August 1997, is the methodology used to focus on environmental excellence. Within WP 02-EC.0, Environmental Management System Implementation Document, both pollution prevention and waste minimization are addressed. Recent efforts to ensure that safety management remains part of each work activity, rather than something "in addition to" or "on top of," include the use of Enhanced Work Planning Concepts by the Electrical Surface Maintenance organization. The focus on safe work practices is shared by both WID and subcontractor employees. A subcontractor's commitment to safe work practices and confirmation of its employee's qualifications are confirmed during the WID procurement process.

As stated in Management Policy 1.28, Integrated Safety Management, WID will systematically integrate safety into management and work practices at all levels of the organization so that the WIPP mission is accomplished while protecting the worker, the public, and the environment. Guiding principles for integrated safety management listed in the WID policy track those listed in DOE P450.4, Safety Management Systems Policy.

Assessments are the primary tools used by WID to confirm that work is being performed safely. Assessments range from verifying readiness for safe operation within specified controls prior to initiating work to periodic monitoring to explicitly confirm that specified controls remain in place. Prior to initiating work, for example, employees conduct pre-job briefings, attend Plan-of-the-Day meetings, and review work packages. In addition, employees complete procedures such as WP 04-AD3001, Facility Mode Compliance, and WP 04-HO1002, Salt Handling Waste Hoist Operation. Procedures such as WP-04AD3026, Self-Rescuer Inspection, WP 04-EM1602, Quarterly Operational Test of Underground Seismic Monitoring System, and WP 02-EC3201, Environmental Compliance Assessment Program guide periodic assessments of equipment and processes.

Work definition, hazard analysis, controls development, and controls implementation functions are periodically reviewed and deficiencies/opportunities for improvement are identified. As outlined in Management Policy 1.20, Assessments, WID managers are encouraged to use a graded approach in planning assessments. The scope, frequency, and documentation of an assessment is to be commensurate with the risk of the activity to workers, the environment, and the health and safety of the general public. All deficiencies identified in management and independent assessments are reported and tracked to closure via the site's Systematic Tracking and Action Reporting System.

The WID's integrated procedures management system is the primary mechanism which defines how the safety management functions are performed. Administrative and technical procedures which describe the processes used to ensure that program functions are effectively integrated and that program requirements are appropriately applied are summarized in DOE/CAO-DRAFT-2276 Westinghouse Waste Isolation Division Integrated Safety Management System Description. WID procedure WP 15-RA 3002, Regulatory Requirements Impact Assessments and Comments, provides instructions for determining the impact of new, revised, and draft regulatory requirement documents relative to the operations of the WIPP. Changes required to ensure continual compliance are incorporated into documents using WP 15-PS3002, Review, Approval, and Cancellation of WID Controlled Documents, and WP 15-PS3003, Document Change Process.

Each year, WID participates in the DOE CAO program-wide data development, evaluation, and validation process. Authorization to execute the scope of work is obtained through CAO approval of the Statements of Work/Work Authorization Directives and the associated Cost Account Plans. Once the CAO has approved the scope, schedule, performance measures, and costs, all changes are controlled through WP 15-FC3207, Change Control System Procedure. Performance-based incentives are also negotiated annually for incorporation into the contract. In the FY 1998 contract, for example, Worker Protection is a performance-based incentive. Elements of the fee determination include the CAO annual worker protection program assessment and results of Mine Safety and Health Administration quarterly inspections.

During Fiscal Year 1998-to-date, the DOE CAO's primary emphasis has been on preparations for the DOE Operational Readiness Review (ORR) at the WIPP, occurring March 2 through 11, 1998. The ORR will be conducted to verify the readiness of plant equipment, personnel, and procedures to operate within the approved authorization basis. A review of the WID's safety management system will be an implicit part of this ORR. With respect to the explicit review of the safety management system, the DOE CAO has had preliminary discussions with the contractor, targeting late-spring/early-summer as the time frame for the Integrated Safety Management System Phase 1 Verification Review. The review will confirm that the ISMS has been integrated with the WID's business processes for work planning, budgeting, authorization, execution, and change control.

Attachment G to the WID FY 1998 contract contains the list of laws, regulations, and DOE directives appropriate for work conducted under this contract. This Attachment addresses DEAR 970.5204-78, Laws, Regulations, and DOE Directives, requiring: (a) compliance with the requirements of applicable Federal, State, and local laws and regulations, including DOE regulations (List A); (b) compliance with DOE directives (List B); and (c) tailored environment, safety, and health (ES&H) requirements be developed as appropriate for the work and associated hazards at the site using any Department-approved process. The requirements described in paragraph (c) were determined by a DOE-approved Standards/Requirements Identification Document (S/RID) process. The WID S/RID is incorporated by reference into Attachment G. In defining the Statements of Work included in the contract, text specifically states that ES&H work shall be performed in accordance with the DOE-approved initial or subsequent DOE-approved revisions of the WID S/RID.

Management control procedure WP 15-RA3003, External Oversight Agency Reviews, provides instructions for WID employees to use in identifying, evaluating, and resolving deficiencies and recommendations made by oversight groups, official review teams, audit organizations, and the WID. Coordination of reviews by nonfinancial auditing/surveying agencies is the responsibility of the Quality and Regulatory Assurance (Q&RA) Department. As issues are identified in the reviewer's final assessment report, the issues are compiled and formatted into an Action Plan in which the responsible department, action parties, and responses are identified. Commitments generated as a result of approved action plans are entered and tracked on a site-wide database. Documented evidence of completed commitments are routed through Q&RA for coordination of the verification with the auditing agency. Deficiencies adverse to quality that are identified by WID are documented and tracked through closure in accordance with WP 13-QA3003, Corrective Action Program.

WID, as managing and operating contractor, is responsible for compliance with the ES&H requirements of the contract, regardless of the performer of the work. In accepting this requirement, however, the WID negotiated a clarification regarding the phrase "performer of the work." As clarified, "performer of the work" means all parties who are doing work within the fenced area, which is defined as the Property Protection Area. Further, with respect to the area within the WIPP Site but outside the fenced area, which is defined as the WIPP Land Withdrawal Area, the phrase "performer of the work" means all parties, including visiting scientists and students, for whose activities the contractor is responsible by virtue of a contractual or other formal arrangement. WID may deny access to the Property Protection Area to any entity who refuses to comply with the WIPP Site ES&H requirements.

The philosophical approach to safety management at WID stresses pre-work planning per prescribed practices to establish requisite safety measures tailored to the hazards rather than on assessing results after the fact. This approach is consistent with the essence of integrated safety management envisioned by the Defense Nuclear Facilities Safety Board in its Recommendation 95-2 and articulated by DOE in Policy P 450.4, Safety Management System Policy. Guidance contained in WID manuals such as WP 12-IH.02, WIPP Industrial Hygiene Program, WP 12-IS.01, Industrial Safety Program, WP 12-2 WIPP ALARA Manual, and WP 12-5, WIPP Radiation Safety Manual, is the basis for this pre-work planning.

An internal Westinghouse self-assessment indicates that the mechanisms used by WID to implement its safety management program address the criteria which DOE personnel may use in reviewing WID's Integrated Safety Management System. In many cases, a procedure will only need minimal additions or changes to meet the criteria. In other cases, a procedure will require a substantial re-write. Continued dialogue with CAO counterparts, continued review of information readily available by accessing the DOE's Integrated Safety Management Program Home Page at http://tis-nt.eh.doe.gov/ism/, and making the required changes to WID procedures are three of the actions WID employees will take in preparation for a DOE Integrated Safety Management System Phase 1 Verification Review in late-spring/early-summer of 1998.

Processing and final preparation of this paper were performed by the Westinghouse Electric Company's Waste Isolation Division, the management and operating contractor for the Waste Isolation Pilot Plant, under U.S. Department of Energy Contract DE-AC04-86AL31950.

BACK