Primary Hazard Screening (PHS) for ISMS Implementation and Safety Basis Classification

1. Primary Hazard Screening (PHS) for ISMS Implementation andSafety Basis Classification EFCOG SAWG May 8, 2012 Mark Wong, Sandia National Labs

2. Presentation Outline What is PHS? How is it implemented? How does it support Safety Basis and Hazard Classification? What are the limitations?

3. What is PHS? Structured screening process that identifies: • Scope of work • High-level hazard identification • Requirements for identified hazards and controls • Training • Requirements documents • Action/Warning messages for key requirements • Hazard Analysis (HA) for select hazards • Safety Basis Hazard Classification • ES&H Subject Matter Expert (SME) involvement

4. How is PHS Used at SNL? • Initial step & foundation of SNL’s Integrated Safety Management System (ISMS) • PHS flows into Work Planning & Controls (WP&C) process: • Provides task-level detail, e.g., specific hazard and control information • Implements safe work practices & requirements • Foundation of Safety Basis Program

5. Software Implements PHS • Collects information about the work process • Asks questions to identify hazards and associated requirements • Provides process reviews by appropriate persons • Notifies authors and ES&H SMEs when hazard thresholds are exceeded or evaluations are missing • Assures uniform Safety Basis Hazard Classification

6. General Information Screen

7. Question Set Screen Shot

8. PHS Also Collects • References to documents (operating procedures, permits, NEPA) • Lists of individual hazards, in tables • Notes • General for PHS • For individual questions • To address individual requirements identified by PHS

9. PHS Support of Safety Basis Defines Scope & Safety Basis of all operations Determines Hazard Classification Supports Hazard Analysis for “Low” hazards Flags major hazard interaction situations that could cause Safety Basis classification to exceed “Low” Aggregates hazards for building or facility for hazard classification through the Hazard Aggregation Roll-up Process (HARP)

10. Hazard Classification: Industrial Facility • Office, SIH, & Low • Classification imbedded in question logic • Questions developed to identify thresholds between SIH and Low • Moderate & High • Questions identify conservative thresholds for hazards and situations that could exceed “Low” • Thresholds trigger evaluation by Safety Basis to manually determine hazard classification; classification is then entered into the software, so PHS remains definitive source for classification

11. Hazard Classification: Industrial Facility • Accelerator • Radiation Generating Devices (RGDs) that create Radiation Areas are identified in a table. • Information about the process and RGD is entered into the table, including information identifying exemptions. • Classification made based on information in the table. • Possible classifications: • Not accelerator • C(1) exempt accelerator • C(2) exempt accelerator • Accelerator • For more information, see “Implementation of DOE Order 420.2C, Safety of Accelerator Facilities” tomorrow at 9:30.

12. Hazard Classification: Nuclear • Radionuclides entered in hazard table, which automatically calculates Sum-of-Ratios (SOR). • Surrogate values (e.g., U-235 equivalent) can be used, but requires review by Nuclear Safety Basis personnel. • Automated SOR can be overridden in cases where it is inaccurate, but requires review by Nuclear Safety Basis personnel. • Segregation • Controlled, dynamic inventory • Radioactive Waste facility • Weapon storage

13. Hazard Analysis Required for hazards classified as “Low”. Uses modified Failure Modes & Effects Analysis (FMEA). Documents causes, consequences, controls, and sufficiency of controls for each analyzed hazard. Can substitute separate analysis, as long as it contains the equivalent or better information.

14. Limitations • Need good questions, which are difficult to write: • Clear & understandable; • Complete, no loopholes; and • Properly designed and scoped to identify the desired hazards and requirements. • Can’t ask enough questions to cover every situation. • Human intervention needed for complex situations. • Can’t list all requirements, so at some point need to refer user back to requirements documents to determine requirements. • Questions require periodic review and updating.

15. Summary PHS software implements a process that identifies activity scope, hazards, requirements, and Safety Basis classification. PHS is the foundation for ISMS implementation and Safety Basis classification. Effectiveness is dependent on quality and design of questions. Human intervention/judgment is needed at some point.

16. Questions?