IMPLEMENTING THE FOUNDATION FOR A DOE 5480.23 COMPLIANT AUTHORIZATION
BASIS: SUCCESS AT
DOE'S HANFORD SITE
Donald H. Alexander, Ph.D. and Carol L. Sohn
Department of Energy
P. O. Box 550, MS S7-51
Richland, Washington 99352
Fran DeLozier
Lockheed Martin Hanford Corp.
P.O. Box 1500
Richland, Washington 99352
James L. Homan
Duke Engineering Services
P. O. Box 550, MS S7-51
Richland, Washington 99352
David L. Nearing
WASTREN, Inc.
1050 Gilmore St., Suite C
Richland, Washington 99352
Nabil Morcos, Ph.D.
INEEL
P. O. Box 1625, MS 2114
Idaho Falls, Idaho 83415
ABSTRACT
On September 12, 1997, John Wagoner, Manager of the Department of Energy's (DOE) Richland Operations Office (RL), gave the go-ahead to begin using the updated safety basis for managing Hanford's high-level wastes in the Tank Farms. The new safety basis was implemented through the use of a new Basis for Interim Operations (BIO), new Technical Safety Requirements (TSRs) and some existing controls. This achievement is viewed as a landmark for reducing risks to workers and the public at Hanford.
Failed attempts to implement safety documentation in accordance with DOE Order 5480.23 and DOE Order 5480.22 have resulted in costly impacts throughout the DOE complex, ranging from shut downs across an entire Field Office to stalled startups of vital projects.
A series of innovations were engineered to avoid the pit falls and failures associated with the implementation of DOE Order 5480.23 safety documents at other sites. The first innovation builds on the strengths of the new Hanford Management and Integration (M&I) Contract managed by Fluor Daniel Hanford Co. Several firms were tapped (i.e., Fluor Daniel Hanford, Lockheed Martin Hanford, Duke Engineering Services, and WASTREN, Inc.) to access exceptional professional talent. In order to avoid "finger pointing" resulting from breakdowns in communications across numerous organizational boundaries, DOE and M&I management instituted a "special project" jointly staffed by DOE and the M&I to integrate the effort of implementing the authorization basis (AB). Success or failure was shared by all team members.
In order to avoid "non-compliance" shut downs resulting from inadvertent operation outside the authorization basis during transition elsewhere, the special project team introduced "transition windows." But the most significant innovation was instituted to avoid the "Go bring me another rock" syndrome. The innovation of a "strategic alignment" mechanism assured that DOE and M&I management expectations were aligned with implementation criteria, products, and performance through all facets of project planning, project management, and project execution.
Implementation of the Tank Farm's BIO was not just another paper chase. The translation of safety bases and requirements into appropriate actions had to be in conformance with DOE Order 5480.23, DOE Order 5480.22, DOE Standard 3009 and DOE Standard 3011. The bases and requirements embodied in the voluminous, highly complex technical document had to be translated and applied, in a traceable manner, via practical operating procedures that would be understood and owned by shift supervisors, operations, and maintenance personnel.
The Tank Farms BIO is designed to provide a safety envelope that is robust enough to assure that a wide range of activities are safely enabled. The Tank Waste Remediation System mission is to retrieve tank waste from both single shell tanks and double shell tanks for immobilization. Waste will be separated into high-level waste (HLW) and low-level activity waste (LLW) fractions. LLW will be immobilized and disposed of onsite. HLW will be immobilized for disposal in an off-site federal repository.
The BIO provides a well-defined and integrated set of safety controls for the Department's largest Tank Farm which includes 55 million gallons of high level waste in 177 tanks. This equates to about 200 million curies of radioactivity. Half of the single-shell tanks have leaked and the removal of the remaining wastes is hindered by the persistence of flammable gas, organic solvents, hazardous chemicals, and in tank quantities of fissile material sufficient for criticality.
In order to meet RL's Radioactive Tank Waste Goal of the Department's Ten Year Plan, all tank safety issues must be resolved by 2001. By 2006, waste removal will be initiated on 10 single-shell tanks and all tanks will have to be characterized to permit 6 million gallons of tank waste to be treated by privatized contractors in 2006. The implementation of the BIO safety basis is a crucial step in achieving these milestones at Hanford.
Realization of the Department's ambitious Ten Year Plan within RL's Tank Farms requires the introduction of innovative institutional, regulatory, and management efficiencies, as well as fresh approaches for resolving long-standing safety issues. Management efficiencies, such as an Integrated Safety Management System, privatization of tank waste vitrification, and Department-wide streamlining of policies, orders, and contracts and achieving stretch goals (accomplishing more scope in the same time frame) are being implemented in the face of down-sizing.
The innovative strategies and tactics developed for implementation of the Tank Farms BIO have broad applications for project management throughout the Department. Application of the out-of-the box thinking, developed through Tank Farms BIO implementation, will be essential to realize the goals established by the Ten Year Plan.
Based on the lessons learned at the Hanford Site, it is recommended that a DOE Standard be developed and issued to provide a road-map for implementing authorization bases across the weapons complex.
INTRODUCTION
Reengineering is the fundamental rethinking and radical redesign of project processes to achieve dramatic improvements in critical, contemporary measures of performance such as cost, quality, service, and speed. - M. Hammer and J. Champy, "Reengineering the Corporation," p. 95.
During 1997, the Hanford Tank Waste Remediation System (TWRS) successfully transitioned from an Interim Safety Basis (ISB) to a Basis for Interim Operations (BIO). The new safety document replaces more than a hundred safety documents, many of which originated over the past four decades and have been found to be inconsistent, duplicative, out-dated, and in some cases, incomplete. When compared to the ISB that it replaced, the BIO's main achievement is in the reduction, integration, and consolidation of requirements and controls.
Over one thousand ISB requirements were evaluated against the process to assure that no necessary requirements were lost. As a result, 11 safety limits (SLs) were reduced to 1, 39 limiting conditions of operations (LCOs) were reduced to 12, and 90 administrative controls (ACs) were reduced to 24 in the BIO. In the process, approximately 400 operations and maintenance procedures were developed or revised and implemented. Approximately 1050 hazardous conditions were evaluated and 29 representative accidents were evaluated.
The reduction of requirements provides significant cost savings and authorization basis (AB) management efficiencies. However, the substantial number of improvements in the AB presented a significant challenge for their implementation. The challenge was met by implementing a number of technical and administrative innovations to assure that a smooth transition would be realized.
The success of BIO implementation relied on: 1) establishing and empowering a special project management (SPMT) team for leadership; 2) aligning organizations and expectations; 3) creating a strategic plan and vision; 4) project preparation (Window I); 5) pre-transition (Window II); 6) validating transition point activities; 7) completing post transition activities (Window III); and 8) follow-up surveillance activities.
This paper presents methods and innovations developed at Hanford for implementing authorization bases upgrades which have applications elsewhere in the DOE complex.
SPECIAL PROJECT TEAM
Joint DOE and M&I ownership and commitment are essential to successful management and sustained cultural transformation. Empowerment is the vehicle for action........... The job of management is not supervision, but leadership. - Dr. W. E. Deming
DOE and the M&I contractor created a "Special Project" to achieve joint ownership and commitment. This is viewed by the participants as the single most important factor that led to the successful implementation of the TWRS BIO. The special project was staffed by participants representing DOE, the M&I, and subcontractors (i.e., Fluor Daniel Hanford , Lockheed Martin Hanford, Duke Engineering Services, and WASTREN, Inc.). Since success or failure of the team would reflect equally on all participants, a spirit of ownership was created. This team ownership avoided the "finger pointing" so typical of high pressure initiatives. As the project matured, the team developed an "esprit de corps."
Because of the "esprit de corps" the SPMT exhibited collectively "The 7 Habits of Highly Successful People," S. R. Covey, 1989:
The special project management team (SPMT) established the mission, vision, and strategic plan for the project. The SPMT became the communication bridge among participating organizations.
Empowerment through delegation of decision-making authority to the SPMT was the key to success. Without empowerment, the SPMT would not have been able to complete more than a thousand management decisions during BIO Implementation.
Senior management was kept abreast of decisions on a weekly basis throughout the process. When issues required senior management decisions, the SPMT developed alternative solutions for their consideration. This avoided inefficient micro-management. As a result, senior management was only called in to disposition a dozen of the more than one thousand decisions made in the course of the process.
Building ownership was a critical objective of the SPMT. Although the AB is developed by the TWRS safety organization, it is of limited value unless it is understood and utilized by operations on a daily basis. Therefore, M&I and DOE operations, maintenance, and engineering personnel; shift management; and DOE Facility Representatives were involved in BIO development, preparing the plant, and determining readiness to transition to the new AB.
As a result, the real customers have taken ownership. The SPMT has led to a cultural transformation within Tank Farms.
STRATEGIC ALIGNMENT
Coming together is a beginning. Keeping together is progress. Working together is success. - Henry Ford
The SPMT realized the need for strategic alignment of DOE and M&I organizational functions and expertise. But more importantly, the team worked immediately to align DOE expectations with M&I activities and products. Since the M&I and DOE would make independent determinations of readiness, the SPMT also worked to align performance criteria.
The alignment of expectations, products and activities, and the criteria to judge them by, was another key to the successful implementation of the BIO AB.
STRATEGIC PLANNING
Strategic Planning provides the vision of the end-state and the road-map to attain it.......The essence of a visionary team comes in the translation of its core ideology and its own drive for progress into the very fabric of the organization - into goals, strategies, tactics, policies, cultural practices, management, and job design. - J. Collins and J. Porras, "Built to Last," p. 201.
The vision of the SPMT was to implement a consolidated TWRS AB that is managed under configuration control and that fits within the TWRS Integrated Safety Management System (ISMS). Ideally all AB controls and requirements would flow in a traceable manner to the operating documents in the work place. The implemented AB must be owned by program management, safety management, and field operations. Three primary components of strategic planning include: barrier analysis, strategic approach, and efficient project phasing.
Barrier Analysis
To achieve the vision, the SPMT identifies barriers that must be overcome and define strategic solutions for each... Even if it seems unreasonable, we believe we can do it nonetheless. - J. Collins and J. Porras, "Built to Last," p. 97.
Barrier analysis is the critical phase in laying out the project because barriers overlooked or unforseen can undermine schedules or availability of human and monetary resources. Examples include:
Strategic Approach
Once the barriers are defined, the SPMT sets the scope and course for the project.
The SPMT elected to achieve the requirements of DOE Order 425.1, Startup and Restart of Nuclear Facilities, even though the project was neither a startup nor a restart. It was determined that in order to meet the overall vision, the requirements set forth in the order provide the necessary performance measures for the project. This was also important to assure compatibility with future amendments to the TWRS AB which would also be subjected to Operational Readiness Reviews (ORRs).
Because of the shear magnitude of the effort, the SPMT innovated a "windows" approach to sequence the effort. The four windows defined for the implementation of the TWRS BIO include:
The Transition Point occurred after completion of Window II. The Transition Point marks the moment in time at which transition occurs. All activities before the Transition Point were conducted under the ISB AB. All activities after the Transition Point are conducted under the BIO AB. This was coordinated with the 6:30 A.M. shift change on Monday morning, September 29, 1997.
Well defined sets of related activities were managed within each window. For each window, a punch list of activities was established and controlled by the SPMT. Items on the punch list were jointly dispositioned by DOE and the M&I on the basis of objective evidence. The SPMT attempted to complete punch list items projected for upcoming windows to reduce the load.
WINDOW I: PLANT PREPARATION
In order to make the overwhelming magnitude of the plant preparations manageable, the SPMT divided window I activities into manageable phases that could be assigned to specialty teams.
Preparation for BIO implementation was planned as a ten phased project: 1) mpre-validation of implementation processes; 2) requirement mapping; 3) MORT success tree analysis; 4) documentation and hardware; 5) compliance assessment; 6) identification of compliance deficiencies; 7) plant readiness; 8) Readiness Assessment and Declaration of Readiness; 9) DOE Management Assessment; and 10 ) RL Manager's Review and Certification of Readiness.
One year was allowed for the implementation of the new AB (phases 1 through 10) because of the size and complexity of the effort. These ten phases leading to Certification of Readiness are referred to as Window I activities.
PHASE 1 - Pre-validation of Implementation Processes
Pre-validation of processes avoids the costly consequences of the "Go bring me another rock" syndrome.
DOE conducted an earlier "heads-up" review of the processes proposed by the M&I in a BIO Compliance Implementation Plan (CIP). Based on the review, the proposed MORT success tree process was "pre-validated." Likewise, other processes, such as the process to map ISB requirements to the BIO were also pre-approved. The performance criteria that would be used to determine readiness were also pre-approved. This pre-approval approach avoided the "Go bring me another rock" syndrome.
PHASE 2 - Requirement Mapping
Laying a firm foundation is the key to success. - Anonymous
Prior to BIO implementation, DOE authorized operation of the TWRS facilities based on the requirements of over one hundred documents collectively referred to as the Interim Safety Basis (ISB). In order to ensure that all necessary ISB requirements and controls were included in the BIO AB, a panel was assembled to: 1) determine whether the BIO and associated TSRs provide a control that adequately addressed the pre-existing ISB requirement; 2) disposition old ISB requirements or controls that were no longer needed; and 3) provide a documented basis for decisions reached.
Approximately 1300 existing requirements and controls were evaluated by engineering, maintenance, operations, quality assurance, and safety personnel. Each requirement was "mapped" from the ISB to the BIO AB by comparing the basis, applicability, and description of the old and new controls/requirements. ISB AB controls and requirements with more than one basis were listed once for each basis. Disposition of the existing controls were as follows:
The mapping of requirements was subjected to two independent reviews to assure that the old requirements were properly translated and dispositioned. Although mapping of requirements and controls was completed early in the process, the ISB remained in force until readiness was validated and authorized by DOE.
PHASE 3 - MORT Success Tree Analysis
Success Tree Analysis provides a traceable and systematic mapping of requirements to actions.
A BIO Implementation Team (BIT) was formed using Subject Matter Experts (SME) to define the relevant AB requirements and conduct the MORT analysis. This team was comprised of members form the following organizations:
The BIT extracted the requirements from the BIO AB documents and any controls rolled forward from the ISB. Requirements were extracted from TSR controls, hardware configurations, assumptions, conditions, and processes used in establishing the accident analyses, commitments, and DID items.
The BIT defined action statements and review approaches for each requirement. Through this step each requirement was wired to one or more field implementing document, operating procedure, or action. The BIT used a MORT success tree to organize the requirements and corresponding action statements. The tree includes three major Groups: Programs, Personnel, and Hardware. The hierarchy for each group is:
Functions (upper tier)
Elements (middle tier)
Basic Events (lowest tier).
The program requirements and actions were aligned with the DOE ES&H Configuration Guide for S/RIDs consisting of the following categories:
The hardware requirements and actions were organized by 13 types of Tank Farm facilities within the scope of the BIO including: instrumentation & monitoring systems, support systems, and utilities.
The personnel requirements and actions were aligned with the following categories of personnel:
A MORT dictionary was developed that provided descriptions and/or boundaries for each of the elements and basic events on the success tree. The BIT SMEs binned the action statements by Basic Event based on the MORT dictionary and engineering judgement.
Once the final action statements were entered into the MORT database by Basic Event, the action statements became the Basic Event success criteria. These success criteria had to be satisfied (formally closed with a signed affidavit) before the Basic Event could be deemed ready. The success tree was also used as a graphic statusing tool.
PHASE 4 - Documentation and Hardware
Successful implementation of requirements to appropriate field actions depends on a careful MORT analysis.
The major element of plant preparation was the revision of 181 plant maintenance and operations procedures and more than 1500 maintenance data sheets. More than 400 procedures were reviewed to ensure that all relevant procedures were revised to incorporate the new BIO controls. Each procedure was revised, reviewed and walked down for compliance/operability prior to approval. The approved procedures were placed in readiness for implementation pending transition to the BIO AB on September 29, 1997.
During the BIO Implementation phase (prior to transition to the BIO controls) the existing procedures remained in effect. Revisions to the existing ISB AB procedures necessary for day to day operations were tracked and incorporated into the staged BIO AB procedures until the Transition Point.
Existing equipment in the tank farms required modification to be compliant with the new controls. This included replacing more than 210 leak detector and level detector relays with intrinsically safe relays, installing latches and locks on 35 valves, and modifying the waste characterization trucks to be in compliance with the ignition controls for potentially flammable tanks. New equipment was also required, including new exhaust stack continuous air monitors (CAMs) on several ventilation systems, service water pressure detectors, and flammable gas monitors.
PHASE 5 - Compliance Assessment
Compliance with requirements is achieved through a self-evaluation of MORT action statements.
The MORT action statements (Basic Event success criteria) were structured in a checklist by Basic Event. The appropriate assessment review methods or approaches were developed to ensure that the BIO requirements relating to Programs, Personnel, and Hardware were adequately implemented. These methods included documentation reviews, field inspections/walk downs, performance assessments, personnel interviews, and other methods. In many cases, multiple review approaches were developed for a single action statement. Each Criterion and Review Approach (CRA) contained a single review approach with its respective action statement and AB requirement. The CRAs contained an intelligent numbering system that allowed future sorts by: 1) the source document of the requirement; 2) associated Core Requirements; 3) type of requirement (e.g., LCO, AC, DID, etc.); 4) functions, elements and basic events; and 5) types of personnel and hardware.
A Plant Readiness Plan describing the assessment methodologies that line management used to assess compliance to the AB requirements, was developed. The plan included 711 CRAs from the MORT process.
A self evaluation of readiness was performed by a Plant Readiness Team (PRT) including operations, maintenance, safety, engineering and quality assurance personnel. The self evaluation consisted of a 100% validation of the 711 Criteria and Review Approaches (CRAs).
The validation was completed by including the required information on the CRAs, attachment of necessary compliance documentation and/or affidavits, and signature by the reviewer and the team leader. The affidavits were then incorporated into certification packages sorted by Core Requirement to be used by the Readiness Assessment (M&I) and Management Assessment (DOE) teams in the future. The completed CRAs were the input forms for tracking non-compliant conditions.
PHASE 6 - Identification of Compliance Deficiencies
Corrective actions are prioritized in a Corrective Action Status Report (CAR) and are scheduled for correction based on timing and costs.
The PRT was given the task of verifying whether each action statement/AB requirement had been met through a formal compliance assessment or self evaluation. The PRT used the 711 CRAs as the audit base. Closure required that objective evidence be provided for the audit file. The PRT recommended corrective actions for each of the non-compliant or open items identified. Compensatory actions were defined in cases where compliant conditions could not be accomplished in the desired time due to fiscal year funding constraints or acquisition of long lead time hardware items. These items were deferred to Window IV.
Cost estimates and a resource-loaded schedule for the completion and closure of all corrective actions were developed and issued in a Corrective Action Status Report (CAR).
PHASE 7 - Plant Readiness
Corrective actions and personnel training are completed before declaring readiness.
Readiness to implement the BIO was declared after assurance that the Programs, Personnel, and Hardware Groups were ready. Each Group was declared ready when its required Functions were also identified as ready. The PRT worked with the BIT to implement the corrective actions identified in the CAR. Open items were tracked to ensure that their respective corrective actions were dispositioned. The corrective actions were linked to the respective success criteria and Basic Events from which they were derived.
All Tank Farms personnel were formally trained on the format and content of the BIO and its associated TSRs prior to the transition from the ISB to the BIO AB.
PHASE 8 - M&I Readiness Assessment and Declaration of Readiness
The Readiness Assessment provides the objective evidence for declaring readiness.
An independent M&I Readiness Assessment (RA) was conducted to validate the plant readiness for transition to the new AB and to validate the self-evaluation process used for BIO implementation. The RA Plan, approved by plant management, was organized according to the Core Requirements of DOE Order 425.1. The CRA action statements and requirements were mapped to the Core Requirements of the order. Validation of the BIO AB implementation process included a sampling of more than 25% of the 711 CRAs. Once the RA was completed, a Final RA Report was submitted to DOE-RL.
PHASE 9 -DOE Management Assessment
The Management Assessment (MA) conducted by DOE TWRS confirmed M&I Readiness.
DOE-RL's independent MA validated the M&I's MORT process, logic, and CRAs. This, in turn, assured the M&I's readiness for transition to the new AB with respect to Personnel, Procedures, and Hardware Groups. This entailed verification that TSRs and associated controls were properly linked to implementing controls, conditions, procedures, work processes, design, training and qualifications. The M&Is self evaluation and readiness assessment processes were also evaluated. The MA team also audited the M&I configuration management system.
Upon successful completion of the M&I RA and the DOE MA, the M&I issued a Declaration of Readiness to transition to the new BIO AB. The Declaration of Readiness included a punch list of approximately 20 items that would be completed prior to September 29, 1997.
PHASE 10 - RL Manager's Review and Certification of Readiness
The RL Manager's independent review team concluded their review with no formal audit findings. This was a first at Hanford, which was magnified by the enormity and complexity of the effort.
The RL Manager's safety staff conducted an independent review of BIO AB readiness. The independent team was staffed by reviewers from Battelle's Pacific Northwest National Laboratory (PNNL). The independent team made no formal audit findings. This was a landmark achievement for Hanford safety programs, which was magnified by the size and complexity of the effort.
Based on the independent review, the RL Manager issued a Certification of Readiness in accordance with an SPMT Transition Plan. The Manager's Certification of Readiness signaled completion of Window I preparations and approved the plan to initiate a series of specified items and conditions through Window II (actual AB transition).
WINDOW II: TRANSITION
A well defined transition plan and a carefully managed punch list of transition items and conditions were essential for completing all required transition actions within ten working days.
Several precautionary measures were taken during the two week period preceding September 29, 1997. A Work Authorization Review Team (WART) was instituted to review all ongoing and planned activities for compliance to BIO/TSR controls. The WART consisted of experienced engineering, operations, maintenance and quality assurance personnel familiar with the BIO/TSRs. All active Work Packages were removed from the field and reviewed by the WART before the transition date.
A Senior Supervisory Watch was also initiated prior to transition. This entailed requiring a Senior Supervisor to assure that the new BIO/TSR controls were adhered to on every shift. Shift personnel were provided on-the-job training for new procedures, processes, and systems. New procedures were color coded as BIO procedures. The staff was also trained to the new Administrative Control manual during the Pre-Transition Window.
M&I RA and DOE MA teams validated completion of the punch list items. All Window II punch list items were completed prior to transition to the new BIO controls. This was documented in Certification Packages.
TRANSITION POINT
Validation of all transition punch list items and conditions is absolutely essential to avoid AB non-compliance.
The transition to the new BIO controls occurred at 6:30 A.M. on September 29, 1997. Between midnight and 6:30 A.M. a team of M&I personnel removed the now obsolete ISB documents from the shift offices and replaced them with the new BIO AB documents. They also replaced all of the obsolete procedures with the new/revised BIO compliant procedures, including the Unresolved Safety Question (USQ) procedure, which contained the new BIO AB documents list. An M&I and DOE-RL management team witnessed the transition. Walk downs were conducted in three locations: East Tank Farms, West Tank Farms, and the Characterization Project Office. All items were successfully validated.
At the beginning of the 6:30 AM shift, the plant was officially operating to the new BIO AB.
WINDOW III: POST-TRANSITION
Oversight and careful management of plant activities are closely monitored for ninety days after the transition point as an additional precaution.
During the ninety day period following the transition point, all work authorization packages were evaluated by the WART. All work authorization packages were checked to assure that they were developed according to the new AB procedures before the work was placed in the field. In order to provide an additional precaution, the M&I continued to impose the Senior Supervisory Watch and DOE continued to conduct management walk throughs. No BIO AB non-compliances occured throughout Window III.
During Window III, corrective actions were instituted to:
DOE established a formal "docket process" for amending the BIO AB during Window III. The docket process is modeled after the same process used by the U.S. Nuclear Regulatory Commission to amend reactor licenses.
WINDOW IV: SURVEILLANCE
Deferred activities, long range activities, and routine activities beyond ninety days are placed under surveillance.
Measures associated with implementation that weren't needed immediately after transition, were deferred for completion in Window IV. These include:
Remaining observations and actions were placed in the Hanford Action Tracking System to assure thorough closure.
RECOMMENDATIONS AND CONCLUSIONS
The greatest obstacle to discovering the shape of the earth, the continents and the ocean was not ignorance but the illusion of knowledge. - Daniel J. Boornstin
The implementation of the Tank Farms BIO AB occured without a hitch largely because the SPMT was determined to achieve a win-win. This is attributed to careful planning, systematic preparations, attention to timing, and monitored implementation. The SPMT maintained a broad view of the playing field, constantly checking the paradigm of the moment and its performance measures.
The innovative strategies and tactics developed for the implementation of the Tank Farms BIO have broad applications for project management throughout the Department. Application of the out-of-the box thinking, developed through Tank Farms BIO implementation, will be essential to realize achievement of goals established by the Ten Year Plan.
The lessons learned from the transition to the new BIO AB are:
Based on the lessons learned at the Hanford Site, it is recommended that a DOE Standard be developed and issued to provide guidance for implementing authorization bases across the weapons complex.
REFERENCES