Changes to MIRP Operations

1. Changes to MIRP Operations Lee Hammons DCOO, C-AD, NPP October 2019

2. Changes to Operations • Many features of MIRP documentation, procedures, and processes have been changed to improve and update operations. • Many changes address concerns that arose during Accelerator Safety Assessment of November 2018 as well as the SC Management Review of July 2019.

3. Completion of IRR and ARR • Issue: • ASA: BLIP and RRPL/TPL have been operated and managed under a C-AD SAD and ASE since 2011; however, an ARR was never conducted for either facility. • SC: Complete IRR and ARR for BLIP and RRPL. • Action: • Convene IRR for BLIP and RRPL Facilities. • Status: • Site-Assist Visit to prepare for ARR • ARR scheduled for either December or January

4. Creation of New MIRP SAD • Issue: • ASA: C-AD SAD is an aggregated document for multiple accelerators and support facilities. • Does not provide adequate information and analytical results to understand all hazards, risks, and derived controls of each individual facility. • SC: BNL would benefit from completion of standalone SAD for BLIP and RRPL. • Extent: • C-AD SAD is 500+ page document that describes all of the 19 accelerator facilities within C-AD complex. • MIRP facility safety analysis embedded within document in manner that makes ascertaining hazards, risks, and controls of MIRP facilities difficult. • Action: • Create new SAD for MIRP facilities. • Status: • New SAD for MIRP has been developed • Focus on just BLIP and RRPL facilities • New document is ~130 pages. • MIRP SAD focuses exclusively on the descriptions, hazards, safety analysis, and controls that are relevant to MIRP operations at BLIP and TPL. • MIRP SAD requires review and approval by BNL committees.

5. Improved Hazard Analysis • Issue: • ASA: C-AD hazards analysis incomplete and does not adequately identify and analyze all potential hazards for RRPL. • SC: Enhance clarity and documentation of hazard analysis and underlying assumptions. • SC: Leverage the improved authorization basis to analyze and implement future operational changes. • Action: • Create new SAD for MIRP facilities. • Status: • MIRP SAD focuses exclusively on the descriptions, hazards, safety analysis, and controls that are relevant to MIRP operations at BLIP and TPL. • Safety analysis streamlined and clarified to make understanding hazards and risks easier. • New formatting of safety analysis makes maximum credible incidents and controls easy to understand. • MIRP SAD requires review and approval by BNL committees.

6. Improved ASEs • Issue: • ASA: Inconsistencies between C-AD SAD and BLIP/RRPL ASE credited controls. • Extent: • The complexity of the C-AD SAD may have contributed to this problem. • Action: • Create new MIRP SAD. • Create new MIRP ASEs. • Status: • New SAD for MIRP developed. • New ASEs for BLIP and RRPL developed that are derived directly from MIRP SAD. • MIRP SAD and ASEs require review and approval by BNL committees. • ASEs require review and approval by BHSO.

7. Improved USI Process • Issue: • ASA: The C-AD USI procedure unclear and does not fully implement BSA SBMS requirements. • SC: Benchmark the USI process against other SC sites. • Action: • Revise USI procedure and screening tool to be more clear and conform to benchmarked standards across DOE complex. • Status: • The various USI processes were benchmarked and compared across DOE Complex. • Using this consensus information, C-AD developed new USI program. • C-AD USI process is 2-tier approach: • 1 - A simple USI Checklist completed by trained line personnel. • The checklist is then reviewed by knowledgeable personnel to determine if potential for USI exists. • 2 - If determination is made that USI may exist, typical six questions used across the DOE complex used to perform the USI evaluation. • A USI log will be generated to document USI process.

8. Improved Conduct of Operations Matrix • Issue: • ASA: Conduct of Operations deficiencies identified. • SC: Develop a MIRP Conduct of Operations Matrix. • Extent: • C-AD ConOps matrix is broad document that covers all 19 accelerator facilities within C-AD. • Action: • Create a new ConOps matrix for MIRP. • Status: • New document has been created focused on MIRP procedures and activities. • Document requires review and approval by BNL ConOps Review Board and BHSO.

9. Developed Radioactive Inventory Management Process • Issue: • ASA: BLIP and RRPL should have active radioactive material inventory control process with maximum inventory limits and technical basis. • SC: Expand postulated accident scenario set to address offsite unmitigated release potential using maximum material via all credible paths. • Extent: • Neither BLIP nor RRPL facilities had a documented radioactive inventory management plan with maximum limits and a technical basis. • Action: • Develop radioactive material inventory control process for BLIP and TPL. • Status: • Radioactive material inventory management plan has been developed for both the BLIP and TPL facilities. • Three components: • Regular accounting and reporting procedure for both the BLIP and the TPL • Inventory limit for the TPL main hot cell • Inventory limit for the BLIP hot cell • Technical basis for these limits was developed by considering worst-case scenarios for TPL and BLIP inventories. • Postulated worst-case scenarios analyzed risks to workers and off-site individuals.

10. Improved Flowdown of Credited Controls • Issue: • SC: Improve flowdown of credited controls of SAD, ASE, and transportation safety documents in operating procedures. • Extent: • Procedures do not explicitly identify credited controls or institutional transportation safety requirements. • Action: • Identify and revised procedures that are associated with credited controls. • Transportation controls are covered by institutional requirements. • Status: • These procedures have been identified and are in the process of being revised.

11. Continue Assurance Process • Issue: • SC: Periodically repeat assurance process as continuous improvement opportunity. • Extent: • Assurance process for continuing operations developed as immediate response to feedback received from Accelerator Safety Assessment. • Assurance process included: • Review and observation of activities • Weekly reporting • Action implementation • Action: • Continue assurance activities on periodic basis. • Status: • Appropriate procedure and assessment schedule has been revised. • Assurance activities are built into procedure.

12. Improved Procedure Review and Revision • Issue: • SC: Engage operators and technical writers in review and revision of documentation and procedures. • Extent: • Procedure creation and review process did not involve trained technical writers or editors. • Action: • Engage technical writers in review and revision of documentation and procedures. • Status: • Technical writers and operators are engaged in the review and revision of MIRP procedures as well as the SAD.

13. Clarified Roles and Responsibilities • Issue: • Procedures do not consistently identify roles and responsibilities. • Action: • Clarify roles, training requirements, responsibilities, and personnel assignments. • Status: • MIRP developed 2 documents: • MIRP Organization Chart - personnel and reporting structure • Roles Table – roles performed and training associated -Organization chart captures personnel -Personnel are assigned roles -Roles perform certain tasks -Tasks are performed to procedures • Technical writer is being resourced and provides guidance on procedure writing and consistency including referencing identified roles in procedures as well as formatting practices.

14. Understanding the Regulatory Spaces DOE O 420.2 – Safety of Accelerator Facilities 10 CFR 835 – Occupational Radiation Protection Program 10 CFR 851 – Worker Safety and Health Program BLIP/TPL RRPL MIRP