Identifying requirements for a nonreactor nuclear facility
Process modeling and a bottom-up approach, along with effective scope management and other project management techniques, allowed the Nevada Test Site to comply with a new Defense Safety Board recommendation ahead of schedule and under budget.
by Dawn M. Starrett, David L. Schlick, Dennis L. Armstrong
THE DEPARTMENT OF ENERGY (DOE) has established a program called S/RIDs (Standards/Requirements Identification Documents) to identify appropriate environmental, safety and health protection standards and requirements for selected sites, facilities and activities. Identification of requirements improves facility management's ability to meet regulatory requirements while also reducing the total cost of managing radioactive wastes, and is considered a best management practice.
The Defense Nuclear Facility Safety Board Recommendation 90-2 requires that each nuclear facility identify S/RIDs. To comply with this requirement, the Nevada Test Site Area 5 Radioactive Waste Management Site (RWMS) developed a list of source documents containing applicable standards and requirements. During the process of developing this source document list, procedures were revised, processes were reviewed and modeled, standards and requirements were identified, and information documented in a final report. A graded approach and independent confirmation by subject matter experts was used to identify requirements applicable to the Area 5 RWMS. The source documents listed were assigned to one of 11 functional areas that were derived from the 20 functional areas outlined in the draft U.S. Department of Energy Environment Safety and Health Configuration Guidelines.
The Area 5 RWMS is the only facility at the Nevada Test Site (NTS) that has been declared a nonreactor nuclear facility. Several other facilities have attempted to identify requirements applicable to specific facilities under their control with mixed success. Most DOE field offices develop generic S/RIDs, then site-wide S/RIDs, before attempting facility S/RIDs. But project management techniques, with an emphasis on effective scope management, enabled preparation of source document lists at the facility level without the use of generic or site-wide S/RIDs for guidance—a bottom-up rather than a top-down approach. This project was completed ahead of schedule because of the time spent on the conceptual development prior to execution.
The Facility. The NTS was established with the primary mission of serving as a proving ground for the testing and development of nuclear weapons. It is a U.S. DOE nuclear testing facility occupying 1,350 square miles of federally owned land in southeastern Nevada's Nye County. The southeast corner of the facility lies about 65 miles northwest of the city of Las Vegas, Nevada. The site varies in width from 28 to 35 miles east to west and in length from 40 to 55 miles north to south.
Radioactive waste disposal operations began at the NTS in January 1961, when the first trench was opened at the Area 5 RWMS to dispose of accumulated test debris. In 1974, the NTS began to accept transuranic wastes for storage from an offsite generator. In 1976, DOE expanded waste management activities to include the disposal of low-level wastes produced at other DOE facilities. The Area 5 RWMS, established in 1978, is located in the southeastern part of the NTS. The Area 5 RWMS consists of 92 fenced acres with a total of 732 acres available, with 142 acres designated for waste disposal. The remainder of the area is reserved for future use. This complex contains Low-Level Radioactive Waste Management Units for near-surface disposal of packaged waste and a transuranic waste storage cell for aboveground storage of packaged transuranic wastes.
The NTS presently serves as a principal disposal site for defense low-level wastes generated by several DOE facilities and as an interim retrievable storage site for transuranic wastes pending opening of and eventual shipment to the Waste Isolation pilot plant in southeastern New Mexico. Because some of the waste containers may contain regulated hazardous constituents, the transuranic storage pad meets construction standards set by the Resource Conservation and Recovery Act.
Procedures. Procedures are designed to control activities and to ensure that requirements are addressed at each level of the process. These processes should be as efficient as possible. An evaluation of various activities within the Area 5 RWMS reviews the “process” aspects of those activities. This evaluation is called “process modeling.” The effort entails a study of the existing procedures, activities and processes detailed by procedures, and all of the documentation necessary to achieve the outcome required by the customer. This approach facilitates work flow, procedure simplification, documentation of activities, necessary education and training, barriers to compliance, and the products that result from each activity. It enables the identification of process interfaces for the Area 5 RWMS.
Exhibit 1. One result of the process modeling approach used at the Nevada Test Site was this work flow model, which provides a way to review the existing radioactive waste management activities and identify areas for potential process improvement.
For the initial phase of this project, procedures were revised in anticipation of the site being designated as a nonreactor nuclear facility, and procedures were developed to control activities at the Area 5 RWMS to the rigorous level required for a nonreactor nuclear facility. Other procedures that impacted Area 5 RWMS activities were also revised to reflect current practices. The procedure revision process began more than a year before requirements identification activities were initiated. Procedures were revised to ensure that current work practices were reflected. During the procedure revision and development process, 86 procedures were reduced to 47 procedures. It was essential that procedures reflect current practices at the Area 5 RWMS before the processes at that facility were closely examined.
Process Modeling. Process modeling was used during conceptual development of the project. A tool that can be used to understand and document the information requirements and information flow between various functions of a facility, modeling requires that written and verbal information be translated into an illustrative model that incorporates logic flow. The modeler is required to model from the perspective of those who work at the facility rather than from personal perspective. The model breaks a work process into separate pieces while maintaining the relationship of the process as a whole. The first step in modeling depicts the activities conducted, mechanisms used to perform the activities, data needed to perform the activities, and the controls on the facility that impose constraints on performance of the activities. The model provides a basis for management decisions about information. Through modeling, redundancies in information generated can be quickly identified. Eliminating redundant information and the associated costs for its storage and handling can be an immediate cost savings for a facility.
The modeling for the Area 5 RWMS used Integrated Computer Aided Manufacturing Definition Methodology to depict process activities and display the model. The software allows the modeler to graphically analyze information flow throughout a facility. A model enables the visualization of the interrelationships between activities. It facilitates understanding of what information needs to be managed, since, in many instances, facilities are lacking necessary information. The model depicts the interrelations among the current activities as elements of information. Modeling assists facilities in identifying information that goes nowhere, competing organizations producing the same information, data processing systems producing reports that are not used, or organizations needing information they cannot obtain.
Exhibit 2. This “crosswalk” shows how the 11 functional areas identified during process modeling correlate to the 20 functional areas outlined in DOE Environment, Safety and Health Guidelines.
The approach used for development of the Area 5 RWMS models was to review approved procedures used to control each activity. Drafts of the models were produced and then reviewed by facility staff who perform the activities depicted in the model. Comments received from facility staff were incorporated into the draft models until the model was determined to accurately and adequately reflect the activity depicted by the model. The model was given to a second reviewer to verify its validity. Any changes requested by the reviewer were discussed with facility staff and the model was then finalized. Modeling continued until a company-level document was identified as controlling a specific task, then modeling for that specific task was discontinued.
Eight pages resulted from the modeling process. Exhibit 1 depicts the highest level of decomposition for the work flow model and an overview of activities conducted at the Area 5 RWMS. It provides the perspective and purpose of the model. The result of the modeling process was a systematic review of radioactive waste management activities so that the process could be analyzed to discern areas for potential process improvement.
Source Document Identification. The objective of source document identification is to ensure the achievement of operational excellence and the protection of facility workers, the public, and the environment. The inclusion of source documents in the final list was based on the facility description and mission.
A review identified customer Reynolds Electrical and Engineering Company (REECo) Procedures, Safety Procedures, and Safety Codes and department-level Standard Operating Procedures that control activities at the Area 5 RWMS. These procedures and safety codes were reviewed using a graded approach for source document references. Of particular interest were DOE Orders, DOE Nevada Operations Office (DOE/NV) Orders, codes of federal regulation, acts, and industry standards that were potentially applicable to the Area 5 RWMS. A list of these source documents was compiled. Subject matter experts from the safety and environmental areas were enlisted to review the source document list for applicability to the Area 5 RWMS. Comments and changes by subject matter experts were incorporated in the source document list. (The selection of subject matter experts is a critical element to completion of this project. Appropriate review and comment cannot occur if the level of expertise for the subject matter expert(s) selected is not sufficient for the functional area(s) being reviewed. Subject matter experts consulted for this project were selected from within the department, from another department, and from a subcontractor organization.)
Functional Areas. The Area 5 RWMS requirements source documents were organized into 11 functional areas similar to those identified in the DOE Nevada Operations Office S/RID Process Implementation Plan. These 11 functional areas were derived from the 20 functional areas outlined in the draft DOE Environment, Safety and Health Configuration Guidelines. The correlation between the functional areas identified in these two documents is depicted in Exhibit 2. The functional areas were developed from the perspective of how they related to operations at DOE/NV facilities. The scope of each functional area identifies the boundaries of the requirements contained in the source documents listed in each functional area. The 11 functional areas are Management Systems, Science and Engineering, Emergency Preparedness, Environment, Safety and Health, Security, Administrative, Construction, Maintenance, Public Involvement, and Packaging and Transportation.
Each functional area includes DOE Orders as the highest-tier documents. DOE Headquarters and Field Office Orders and documents are followed by source documents that reference them. Codes of federal regulation were considered as secondary source documents. Industry standards were considered as third-tier source documents. The lowest-level documents listed were company procedures. Those company documents that reference more than one highertier document were listed more than once. All other source documents are listed once. Here's an example:
1 Management Systems
DOE 1322.2C, (10/22/91) “Forms Management”
NV Order 1322.2C, (05/18/92) “Forms Management
REECo Company Procedure 3.2.18, “Forms Management”
REQUIREMENTS: (DC:ORD) (AC:COM) (RC:REE)
Once each document identified as applicable on the source document list was assigned to a functional area and was assigned appropriate codes, several reviews were conducted concurrently. Facility staff were given the list to review. Comments were received and addressed or incorporated as appropriate.
Identification of Requirements. Each source document identified as being applicable to the Area 5 RWMS will be reviewed. Source documents contain several responsibilities and requirements that need to be individually addressed. Each responsibility and requirement needs to have an associated justification regarding its applicability to the Area 5 RWMS. Source documents that seem to apply to the Area 5 RWMS often contain responsibilities and requirements that are not applicable at the contractor level. Only those requirements that are determined to be necessary and sufficient for the operation of the Area 5 RWMS will be input into the database. The necessary and sufficient process allows the contractor to determine which standards are the most appropriate based on an analysis of facility hazards and the work to be performed.
Responsibilities and requirements from the source documents were entered into a prototype database until a final database can be completed. Information input to the database includes source document, issue date, responsibilities and requirements by source document section, and justification of applicability.
Once all requirements are entered into the completed database, a paperless system will enable the tracking of requirements and their implementation. Reports can be printed from this system for line management and oversight organization review. The reports are an essential component for ensuring that changes to source documents are addressed and compliance continues. The reports enable line managers to identify those areas of potential concern as they relate to the Area 5 RWMS.
Even though only requirements related to the Area 5 RWMS will be entered into the database, the information will constitute 90 percent of the information required to generate site-wide S/RIDs. The information has already been used to respond to several requests for information from DOE.
THE KEY TO THE SUCCESS of this project was defining the project objectives required to meet DOE/NV goals. Procedure revision and process modeling were essential components of conceptual analysis. Involvement of field personnel facilitates the development of an accurate model and is necessary to achieve total quality management. Identification of source documents that contain standards and requirements applicable to the Area 5 RWMS using a graded approach reduced the time spent on compiling unnecessary information. Involvement of appropriate subject matter experts for the review of the source document ensures that the source document list is complete and does not contain unnecessary documents. Identification of individual requirements and entry of information into the database will enable management to maintain compliance to identified requirements. This project will continue as each requirement is revised and changes to the database reflect new requirements. Effective scope management can assist project managers in identifying all requirements applicable to their facility. As budget cuts continue, bottom-up information processing using effective scope management will become accepted practice. ■
Dawn M. Starrett, Ph.D., PMP, is a certified environmental manager and faculty member at the University of Phoenix in Las Vegas, Nevada, where she teaches environmental science. She is currently a reengineering specialist with Bechtel Nevada, and has been involved in waste management for the last eight years.
David L. Schlick has 19 years of experience in environmental compliance and engineering and is a certified chemical hazardous material manager. He is presently involved with hazardous and radioactive waste at the Nevada Test Site.
Dennis L. Armstrong has 14 years experience in technical areas with an emphasis in health physics and radiological operations. He is presently assigned to the Waste Management Division of DOE Nevada Operations Office as a senior health physicist.
PM Network • May 1997