carol l. sohn senior nuclear safety advisor, office of science, sc-33 1 may 5, 2011 review of...

Carol L. Sohn

Senior Nuclear Safety Advisor,

Office of Science, SC-33

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May 5, 2011

Review of Science SitesHazard Categorization

Independent verification to ensure that no Hazard Category 1, 2 or 3 nuclear facilities exist other than those previously declared by contractors across SC sites

Review SC sites analyses and verifications associated with hazard categorization (implementation of DOE-STD-1027)

Evaluation of bases for exemptions, exceptions and downgrades and deviations associated with hazard categorization

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Objectives

All radiological facilities at SC sites

Transportation activities involving radiological materials

Outdoor activities involving radiological materials

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Scope

Inadequate implementation of DOE-STD-1027 at some SC sites

Conducting extent of condition at the request of SC-3

Determine if additional Hazard Category 1-3 nuclear facilities exist

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Why did we conduct this review?

Criteria (synthesized)

Categorization of facilities is consistent with DOE-STD-1027, CN 1

Categorization is dependent upon threshold quantities (Table A.1) and consistent with DOE-STD-1027 ground rules

Final hazard categorization is based upon unmitigated release

Segmentation is consistent with ground rules Exclusions of sealed sources are consistent with ground

rules

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Criteria (continued)(synthesized)

Exclusions of commercially available products are consistent with ground rules

Exclusions of materials are DOT Type Bs is consistent with ground rules

Inventories that vary with time are based upon the maximum amounts

Categorization is consistent with potential for criticality Exemptions are consistent with 10CFR820 Subpart E

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Review Approach

Documentation» Radiological inventories and changes to inventories» Radiological inventory tracking system(s)» Radiological facilities hazards analyses» Information regarding containers including certificates of compliance and storage

conditions

» Information regarding testing of homemade sealed sources

» Exclusions/downgrades/exemptions of inventory

» Technical justifications (bases) for exclusions/exemptions/downgrades

» Correspondence from/between HQ/contractor and Site office on Site’s inventories regarding exemptions, downgrades or exceptions

» Site office verifications of inventory

» On-site shipping documentation

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Review Approach

Interviews» Radiological inventories and changes to inventories» Site office individual(s) who performed verifications» Site Office Manager or Deputy Manager» Contractor individuals who performed verifications/reviews» Contractor inventory managers» Contractor sealed source manager» Contractor shipping container manager» Contractor facility managers

Observations» Walkthroughs of facilities that may exceed threshold quantities dependent upon

exclusions/downgrades/exceptions/inventory

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Conduct of Review

Opening session presentation

Conduct reviews/interviews (Tuesday-Thursday)

End of the day discussions with contractor/site office on issues

Primary conclusions from review

Completion of report/provided for factual accuracy (~3 weeks following review)

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Issue Types

Level 1 FindingsThese are issues of major significance that warrant a high level of attention on the part of line management. Typically these reflect a gap in addressing requirements or a systemic problem with implementing the requirements. If left uncorrected, this level of finding could negatively impact the adequacy of operations and/or accomplishment of the SC mission.

Level 2 FindingsThese are issues that represent a non-conformance and/or deviation with implementation of a requirement. Multiple issues at this level, when of a similar nature, may be rolled-up together into one or more Level 1 Findings.

Level 3 Findings These are issues where it is recognized that improvements can be gained in process, performance or efficiency already established for meeting a requirement. This level of finding should also include minor deviations observed during oversight activities that have been promptly corrected on the spot and verified as completed.

Noteworthy PracticesPractice or tool that has shown significant notable improvement. The practice has the potential to benefit other sites/facilities and merits sharing.

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Results

Reports issued for all but one site Matrix

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Office of Science Review of Hazard CategorizationCriterion

Site 1 2 3 4 5 6 7 8 9 10 NotesSite A

Site B

Site C

Robust self assessment

SiteD

Robust self assessment

Site E

Site F

Robust self assessment

Site G

Robust self assessment

Site H

Site I

Site J

Key No Findings Criterion met with some findings Criterion not met

Issues» No inventory system for radiological facilities» Actual inventories not consistent with inventory reporting systems» Software quality assurance issues with inventory systems» Specific activities and threshold quantity values were not consistent with

DOE-STD-1027» Lack of accounting for decay/progeny» Lack of accounting for hold up» Not understanding potential for criticality (footnote in DOE-STD-1027)

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Types of Issues

Issues» Inappropriate crediting of mitigation for hazard categorization

determination» Insufficient special form documentation (sources) or ANSI 43.1

documentation» Lack of maintenance for sealed sources» Inappropriate segmentation of radiological facilities » Inappropriate use of time at risk» Inappropriate use of temporary storage allowances» Accelerator boundaries not always clear» Mindset of “no HC 1-3 nuclear facilities” therefore does not apply to my

site

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Types of Issues

Issues» On-site Transportation activities not evaluated» Transportation of radiological materials through radiological facilities

(nested facilities) and potential changes to inventory» Exclusion of packages without a current certificate of compliance» Lack of DOE approval for downgrades of hazard categorization to

radiological» Reliance upon expert based approach versus procedures» Need to include Hazard Category 2 thresholds as well as Hazard

Category 3 in inventory control and calculations

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Types of Issues

Noteworthy Practices

Strong expertise exists» Hazard categorization (e.g., Hazard Categorization “czar”)» Inventory systems (LBNL, ORNL)» Radiological Facility Review Board (ORNL)

Robust self assessments at several sites identified many issues

This set of evaluations forced many sites to look at the need for their materials and resulted in de-inventory efforts

Standardized procedures with single POC expertise avoided problems

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Conclusions

Improved understanding of DOE-STD-1027 across SC

Additional Hazard Category 2 or 3 nuclear facilities were identified

Significant differences in self assessment programs Advance briefings led to stronger self assessments,

self identification of issues and buy-in by Labs relative to issues

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Team Contact Information

Carol Sohn, team leader, (509) 420-3281 office /(509) 375-2320 cellcarol.sohn@science.doe.gov

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