Departmental Initiative to Enhance Activity-level Work Planning and Control

1. Departmental Initiative to Enhance Activity-level Work Planning and Control DOE and DOE Contractors Industrial Hygiene Meeting in Conjunction with the 2014 American Industrial Hygiene Conference and Exposition June 2, 2014 David J Weitzman Industrial Hygienist Department of Energy Office of Health and Safety, HS-10

2. Integrated Safety Management (ISM) Thanks to CH2MWG, Idaho, LLC

3. ISM

4. ISM Activity Level Activity Level Work Planning Work Planning Activity-Level Work Planningand Control (ALWPC) • Where the ISM rubber meets the road • Applicable to all types of work activities including operations, maintenance, research, decommissioning, construction, etc. • Protects both the worker from the plant and the plant from the worker You

5. Defense Nuclear Facilities Safety Board (DNFSB) • Expressed concern about work control processes in Recommendation 2004-1 • Several DNFSB letter with WP&C concerns • Reviewed WP&C at DOE sites with defense nuclear facilities from 2008-2012 • Issued DNFSB/TECH-37 ISM at the Activity Level: Work Planning and Control in 2012

6. The Deputy Secretary outlined the following major actions in his November 2012 letter: Develop a DOE Handbook on ALWPC for contractor implementation Develop DOE CRADs and other guidance for oversight of ALWPC Conduct a workshop and evaluate operating experience • DOE’s Response

7. Special ISM Champions Workshop DOE Forrestal HQ Building and Video and Web Conferencing Washington, DC May 15-16, 2013

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9. New Handbook-1211-2014 Activity-level Work Planning and Control Implementation • Approved, soon to be published • Objectives: • Improve implementation of Activity-level Work Planning and Control (ALWPC) and activity-level work; • Assist contractors in more effectively meeting requirements of ISM at the activity level; • Provide a resource to clarify DOE requirements that govern activity-level work; • Provide good practices for implementing activity-level work; and • Show the linkage between safety culture and effective ALWPC practices.

10. New Handbook-1211-2014 Activity-level Work Planning and Control Implementation • Addresses: • Implementation of work planning and control • Skill of the worker • Work planning and control metrics, analysis, and trending • Collaborative team approaches • Activity-level work control document writer’s guide • Activity-level work control document verification and validation guidelines • Multi-week scheduling management • Fostering an environment to promote a positive safety culture and a safety-conscious work environment • DOE requirements citations as performance expectations

11. New Handbook-1211-2014 Activity-level Work Planning and Control Implementation • Implementation Sections: • Work planning and control and ISM • Defining the scope of work • Planning the Work – Identify and Analyze Hazards • Planning the Work – Develop and Implement Hazard Controls • Planning the Work – Scheduling • Performing Work within Controls • Providing Feedback on Adequacy of Controls and Continuing to Improve Safety Management

12. HDBK-1211-2014 Example ALWPC Process

13. DOE G 226.1-2A Federal Line Management Oversightof DOE Nuclear Facilities • Published April 14, 2014 • Objectives: • Revise DOE-G 226.1-2 to enhance guidance for ALWPC oversight • Measure effectiveness of ALWPC systems and identify situations in which the desired outcome is not achieved • Provide a clear set of expectations and evaluationcriteria • Share best practices rather than promoting a single acceptable approach

14. DOE G 226.1-2A Federal Line Management Oversightof DOE Nuclear Facilities • Published April 14, 2014 • Revised DOE-G 226.1-2 to enhance guidance for Activity-level Work Planning and Control (ALWPC) oversight • Can use for measuring effectiveness of ALWPC systems and identify situations in which the desired outcome is not achieved • Provides a clear set of expectations and evaluationcriteria • Shares best practices rather than promoting a single acceptable approach

15. DOE G 226.1-2A Federal Line Management of DOE Nuclear Facilities • Based on: • The DOE requirements and guidance documents for ISM • URS Inc. procedures and an EFCOG guidance document, where appropriate • DOE analysis of ALWPC lessons learned, best practices, and DOE’s Operating Experience Program data • Lessons learned from implementation of ongoing DOE improvement actions • Ongoing efforts to improve safety culture across the DOE complex

16. DOE G 226.1-2A Federal Line Management of DOE Nuclear Facilities • WP&C sections: • Field Element WP&C Assessments • Program Definition • Program Implementation • Operational Awareness • Oversight Schedule • Oversight Roles and Functions

17. DOE G 226.1-2A Federal Line Management of DOE Nuclear Facilities • WP&C sections: • Analysis, Tracking, and Trending • Headquarters WP&C Oversight • CRAD Usage • Preparation for Oversight of Work Activities • Conducting Oversight of Work Activity Execution • Graded Approach for Conducting Oversight of Work Activities

18. DOE G 226.1-2A Federal Line Management of DOE Nuclear Facilities • Includes Criteria Review and Approach Documents (CRADs): • Programmatic CRADs • Implementation CRADs • CRADs include: • References to requirements • Lines of Inquiry (LOIs) • Are tailored to the level of hazard: • From high hazard and complexity to activities appropriate for Skill of the Worker • Are useful for: • Planned reviews as well as routine operational awareness

19. Sustained Federal and Contractor Oversight of ALWPC • Sample NNSA Work Planning and Control improvements during FY2013 and FY2014(courtesy Jim Winter, NA-00-10): • NNSA biannual reviews of Field Offices emphasize WPC oversight in the Maintenance and Conduct of Operations CRADs • A growing number of Field Offices are collaboratively targeting ALWPC oversight more holistically with Facility Representatives and SMEs such as IHs. • Several M&O Contractors are applying elements of the EFCOG WPC CRADs to Contractor Assurance activities • WPC performance improvement plans are actively managed by M&O Contractors and Field Offices

20. Sustained Federal and Contractor Oversight of ALWPC • Sample EM Work Planning and Control improvements during FY2013 and FY2014(courtesy Don Rack, EM-42): • All EM contractors include ALWPC oversight as part of their contractor assurance systems and have incorporated ALWPC oversight into their annual assessment schedules • Each EM field element has Identified a ALWPC SME to conduct programmatic oversight • EM HQ ALWPC oversight is performed by the Office of Operational Safety (EM-42) • EM's FY 2014 ALWPC oversight will continue to focus on ALWPC program implementation 20

21. Work Planning and Control Training • National Training Center Course SAF-269: Fundamentals of Work Planning and Control • Provides foundational level knowledge of work planning and control concepts and processes • For DOE contractor and Federal oversight personnel • Pilot tested May 5-6, 2014 at Nuclear Facility Safety Programs Workshop 21

22. Contact • david.weitzman@hq.doe.gov, 301 903-5401