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DOE-STD , Integration of Safety into the Design Process

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1 DOE-STD-1189-2008, Integration of Safety into the Design Process
Dr. Richard Englehart, Epsilon Systems Solutions Pranab Guha, HS-21 John Rice, Epsilon Systems Solutions

2 Expectations I expect safety to be fully integrated into design early in the project. Specifically, by the start of the preliminary design, I expect a hazard analysis of alternatives to be complete and the safety requirements for the design to be established. I expect both project management and safety directives to lead projects on the right path so that safety issues are identified and addressed adequately early in the project design. – Deputy Secretary of Energy, December 5, 2005 Set the stage – What brought us to this point? Reference 12/7/05 DNFSB public meeting on integrating safety into design and the statements made by DOE officials. DNFSB: Less prescriptive design requirements have led to confusion and misuse of safety analysis techniques. Reference was made to issues associated with on active confinement ventilation systems. Timeline – 1189 Development Team Established, Team Composition, Team established Feb. 2006 About 25 persons to begin with; about 15 all the way thru EFCOG SAWG and EPWOG, Feds DOE and EFCOG PM near end Team Meetings, About 10 weeklong meetings from Mar 06 through Mar 08 1189 in Revcom (March 2007), Approved March 31, 2008

3 Purpose DOE Standard 1189 has been developed to show how project management, engineering design, and safety analyses can interact to successfully implement the Deputy Secretary’s expectations This course provides the central ideas and themes of 1189 and conveys lessons learned from project implementation of the Standard The STD-1189 process approach for integrating safety into design is an alternative to a prescriptive approach of requiring specific safety design features. The 1189 approach includes the philosophy of letting safety analyses define what safety functions are required for adequate protection of public and workers.

4 Overview of Course Safety-in-Design Concepts Applicability
Project Integration and Planning Design Process Hazard and Accident Analyses and Inputs to the Design Process Appendices A – C Facility Modifications Lessons Learned Q & A Case Study Remainder of appendices are covered as they pertain to the topics addressed in this slide. D: Additional Functional Classification Considerations E: Safety Design Strategy F: Safety-In-Design Relationship with the Risk Management Plan G: Hazards Analysis Table Development H: Conceptual Safety Design Report I: Preliminary and Final Design Stage Safety Documentation J: Major Modification Determination Examples

5 Instructional Goal Upon successful completion of this lesson, students will be able to demonstrate a familiarity level knowledge of the background, philosophy, and contents of DOE-STD-1189, Integration of Safety into the Design Process Emphasize familiarity level. More study and familiarity with the Standard’s features is necessary in order to successfully implement it.

6 Lesson Objectives (Slide 1 of 5)
Explain why DOE-STD-1189 was developed. Identify the “drivers” that require the use of DOE- STD-1189 for integrating safety into design. Identify and explain the key concepts introduced by DOE-STD-1189. Identify and explain the guiding principles for integrating safety into design. Participants should be able to discuss these items, for example, in a test.

7 Lesson Objectives (Slide 2 of 5)
Explain the purpose of the DOE Integrated Project Team. Explain the purpose of the Contractor Integrated Project Team. Explain the purpose of the Safety Design Integration Team. Explain how the Safety Design Strategy is developed. Describe its scope, preparation, format, and approval process.

8 Lesson Objectives (Slide 3 of 5)
Describe how the requirements and deliverables identified in DOE-STD-1189 relate to the Project Lifecycle as described in DOE Order 413.3A. Explain how the Critical Decision Process can be tailored based on project type, risk, size, duration, complexity and selected acquisition strategy.

9 Lesson Objectives (Slide 4 of 5)
Identify and explain the key safety-related activities in each of the phases of a project: Discuss the purpose and content of the following documents: Conceptual Safety Design Report. Conceptual Safety Validation Report. Preliminary Safety Design Report Preliminary Documented Safety Analysis DOE Safety Evaluation Report

10 Lesson Objectives (Slide 5 of 5)
Identify common lessons learned from implementing DOE-STD-1189. State the purpose of the following appendices in DOE-STD-1189 and explain how each is used in the design process: Appendix A, Safety System Design Criteria Appendix B, Chemical Hazard Evaluation Appendix C, Facility Worker Hazard Evaluation Describe the facility modification process using DOE-STD-1189

11 STD-1189 Roadmap (Slide 1 of 6)
For all audiences: Preface, with the key concepts and guiding principles upon which the Standard was developed, Chapter 1, Introduction (background, applicability, must and should) ; Chapter 2, Project Integration and Planning; and Chapter 3, Safety Considerations for the Design Process, which provides an overall perspective of the Safety-in-Design process through the Critical Decision stages. See section 1.2 of the Standard. The roadmap was developed to direct specific audiences to sections of the Standard most relevant to their interests.

12 STD-1189 Roadmap (Slide 2 of 6)
Project safety personnel and DOE safety reviewers Chapter 4, Hazard and Accident Analyses Chapter 5, Nuclear Safety Design Criteria Chapter 6, Safety Reports Appendices A through D, Appendix F, Safety-in Design Relationship with the Risk Management Plan Appendix G, Hazards Analysis Table Development guides this basic safety-in-design input

13 STD-1189 Roadmap (Slide 3 of 6)
Project management, both federal and contractor Chapter 7, Safety Program and Other Important Project Interfaces Appendix E, Safety Design Strategy Appendix F, Safety-in-Design Relationship with the Risk Management Plan

14 STD-1189 Roadmap (Slide 4 of 6)
Project design personnel Chapter 5, Nuclear Safety Design Criteria Chapter 7, Safety Program and Other Important Project Interfaces Appendices A through D, which address safety design classifications for Safety Structures, Systems, and Components (Safety SSCs)

15 STD-1189 Roadmap (Slide 5 of 6)
Safety Document Preparers and Reviewers Appendices H and I provide format and content guidance for the preparation of the Conceptual Safety Design Report (CDSA), Preliminary Safety Design Report (PDSA), and Preliminary Documented Safety Analysis (PDSA)

16 STD-1189 Roadmap (Slide 6 of 6)
Project teams for potential major modifications of existing facilities: Chapter 8, Additional Safety Integration Considerations for Projects Appendix J, Major Modification Determination Examples

17 Safety-in-Design Basic Precepts
Appropriate and reasonably conservative safety structures, systems, and components are selected early in project designs Project cost estimates include these structures, systems, and components Project risks associated with safety structures, systems, and component selections are specified for informed risk decision-making by the Project Approval Authorities Precept: A precept is a rule or principle imposing a particular standard of action or conduct By following these precepts, it is intended that DOE projects develop the reputation of reliable and conservative project cost and schedule estimates, especially for Congressional confidence in the funding of them. Cost range at CD-1 Project Baseline (total project cost) at CD-2

18 Development of STD-1189 (Slide 1 of 2)
Designed to be guided by and consistent with the principles of ISM and the requirements and guidance of DOE O 413.3A Correlates with the DOE O 413.3A Critical Decision stages and safety design requirements of DOE O B and associated guidance documents Mission Need Statement Guide DOE G See section 3.c of the Guide for pre-conceptual level engineering/technical analysis expectations. Integrated Project Teams Guide DOE G See section 2.4 of the Guide, IPT Roles and Responsibilities and section 2.6 Membership and Structure (including Contractor participation). Project Execution Plans Guide DOE G See section 2.3 of the Guide, Tailoring Strategy (relates to 1189 and the SDS). See section of the Guide, Risk Management (relates to 1189 and Risk and Opportunities Assessments). Risk Management Guide DOE G The Guide describes the risk management process. The 1189 Risk and Opportunity Assessment is the safety in design related input to the Risk Management Plan process.

19 Development of STD-1189 (Slide 2 of 2)
Specifically references 413.3A guidance on Mission Need Statements Integrated Project Teams Project Execution Plans Risk Management Plans

20 Correlation to ISM Core Functions
Define the work: Mission Need; Alternatives Definition Analyze the hazards: Conceptual Design and follow on stages, hazards analysis, and design basis accidents Identify safety controls: Follows from HA and safety classification Perform the work: Integrate safety in the design process Feedback and Improvement: Iterative process between design and safety Reference: DOE P 450.4, Safety Management System Policy and DOE G B, ISM Guide

21 Summary of Key Safety-in-Design Concepts (Slide 1 of 4)
Establishment and early involvement of Integrated Project Teams (IPT) and their coordination Federal and Contractor IPTs; Contractor Safety Design Integration Team (SDIT) Defining the overall strategy for the project, including how safety integration is to be accomplished, and obtaining DOE approval of the strategy Safety Design Strategy, derived from DOE safety expectations defined in the pre-conceptual phase, is formalized and approved during conceptual design phase

22 Summary of Key Safety-in-Design Concepts (Slide 2 of 4)
Identifying CD-1 as the key point in a project when major safety systems and design parameters should be defined Focus on high potential cost safety implications: Hazard Category; building and major components seismic design categories; building confinement strategy; fire protection and power supply system classification Establishing objective criteria for the designation and design of safety structures, systems, and components STD-1189 Appendices A, B, and C (seismic design basis; collocated worker SSC safety classifications; in-facility worker safety classifications) Define collocated worker

23 Summary of Key Safety-in-Design Concepts (Slide 3 of 4)
A conservative front-end approach to safety-in-design that is reflected by a “risk and opportunities” assessment Conservative approach early-on based on assumptions and incomplete information: input to project risk management plan (Risk and Opportunities Assessment) and information for cost estimates Identifying key project interfaces (physical and programmatic) that affect design decisions Project Interfaces: e.g., site infrastructure, security, waste management, emergency preparedness, DNFSB

24 Summary of Key Safety-in-Design Concepts (Slide 4 of 4)
Ongoing involvement of DOE in safety-in-design decisions Safety Design Strategy (SDS) Conceptual and Preliminary Safety Design Reports (CSDR, PSDR) Preliminary Documented Safety Design Analysis (PDSA) Related DOE reviews and approvals

25 Guiding Principles (Slide 1 of 3)
Derived from DOE O 420.1B, DOE O 413.3A, and their associated Guides Use of O 420.1B and clearly articulated strategies to satisfy requirements Control selection strategy order of preference Following the design codes and standards in O 420’s associated Guides Use of risk and opportunities assessments See pp vii and viii of the Standard Compliance with the Key Concepts and Guiding Principles is necessary in order to comply with the Standard

26 Guiding Principles (Slide 2 of 3)
Conservative early project safety decisions input to cost/schedule CD packages describe safety decisions Project team includes appropriate expertise Safety personnel involved from onset of project planning

27 Guiding Principles (Slide 3 of 3)
Important safety functions addressed during conceptual design SDIT invokes the safety-in-design process All stakeholder issues identified early and addressed Bases for safety related decisions are documented

28 Applicability The Standard applies to the design and construction of:
New DOE hazard category (HC) 1, 2, and 3 nuclear facilities Major modifications to DOE HC 1, 2, and 3 nuclear facilities (as defined by 10 CFR 830) Other modifications to DOE HC 1, 2, and 3 nuclear facilities managed under the requirements of DOE O 413.3A O 413.3A: Projects with Total Project Cost > $20 million O 420.1B modification for STD-1189 will include projects < $20 million The “other modifications” refers to modifications to HC 1, 2, and 3 nuclear facilities that are not “major modifications” under 10 CFR 830, but come under O 413.3A because of cost.

29 Safety and Design Integration
Project Integration and Planning This series of slides covers the material in Ch 2 of DOE-STD-1189

30 Key Components of Project Integration and Planning
Safety Design Project Management Interfaces Safety-in-Design Federal Integrated Project Team Contractor Integrated Project Team Safety Design Integration Team Safety Design Strategy Risk and Opportunities Assessments DOE and Contractor Roles and Responsibilities Each of these bulleted items will be covered in the following set of slides.

31 Relationships of Major Project Entities
Acquisition Executive DOE SBAA/SBRT Contractor IPT Engineering Design Safety Analysis SDIT Contractor Project Manager DOE Program Federal IPT Federal Project Director O 413.3A roles and responsibilities of the FPD, as further described in DOE G (IPT) , are extensive. See paragraph 6.g of the Order. OECM asserts that it is the responsibility of the FPD to get all of the items in table 2 of the Order completed. The FPD makes use of the resources available to him. These primarily include the IPT, the CIPT, and the SDIT. Preferably, the federal IPT is well staffed by feds, including some full time committed personnel, especially in the project management and safety areas. Often the CIPT works in support of the federal IPT, However it can not be put in the position of reviewing and approving its own products. If feds are not available to perform IPT functions, the IPT may be supported by independent contractors. It can be beneficial if the safety person on the IPT is also affiliated with the SBRT, not as the lead (potential conflicts), but optimally as an advisor to the lead. The benefit is that that person will have much background information on the project , which will help the SBRT have a running start for their review responsibilities. 31

32 Federal Integrated Project Team (Slide 1 of 3)
FPD leads an IPT with representation necessary for project success FPD and IPTs must aggressively lead the project (not passively monitor and review) IPT formally established at CD-1 (really needs to be established at the beginning of Conceptual design) Roles, responsibilities, and functions of the Federal IPT are provided in DOE G , Integrated Project Teams Guide for Use with DOE O 413.3A From G section 2.4: The series of 413.3A guides assigns nearly 100 roles and responsibilities to IPTs. Some of the more significant are: Support the FPD in developing a PMP and RMP Ensure project interfaces are identified, defined, and managed to completion Plan and participate in project reviews Review and comment/recommend approval on key project deliverables including CD packages Section 2.6 of Guide 18 includes the CIPT and SDIT as subgroups to the federal IPT

33 Federal Integrated Project Team (Slide 2 of 3)
From DOE G : The IPT is the primary tool for breaking down the walls that can exist between different organizations, different professions, and different levels within the different organizations’ command structures. A successful IPT brings these diverse elements together to form a unit that willingly shares information, balances conflicting priorities and ideologies, and jointly plans and executes the project mission. (¶ 2.2) All IPT members and CIPT members, as well as any independent contractors supporting the IPT need to understand these paragraphs. They are important enough that they should be read out loud when this slide is shown.

34 Federal Integrated Project Team (Slide 3 of 3)
From DOE G (Continued): The initial requirement imposed upon the IPT by DOE O 413.3A is to support the FPD by providing individual expertise to fill the voids in his or her knowledge base in the areas of planning and implementing the project… (¶ 2.4.1)

35 What is the Contractor Integrated Project Team?
Standard 1189 encourages the formation of the Contractor IPT; similar makeup to Federal IPT Comprised of personnel who ensure integration of mission need, safety analysis, and design Diversity of expertise is essential Project process understanding very helpful Strong upper management support to IPT members Need consistency and longevity of team members Team formed after approval of CD-0

36 Typical Contractor IPT Representation
Facility Owner/Operator Funding Organization Project Management Health, Safety, and Radiation Protection Nuclear Safety Engineering Waste Management Procurement Safeguards and Security (as needed) Quality Assurance Computing, Communications and Networking DOE Representative

37 Contractor IPT Key Points (Slide 1 of 2)
Parallel management functions as the Federal IPT, but from the contractor’s perspective Safety Design Integration Team (SDIT) directly supports the CIPT, and through it, the Federal IPT While it is preferred that the federal IPT is well staffed and that a core team be assigned full time in support of the FPD, experience has shown that this is not always the case. In such cases, members of the CIPT can help. However, they should never be put in the position of reviewing and recommending approval of contractor products/documentation. NNSA is exploring the idea of providing funds for independent contractor support to the IPT when federal employees are not available to provide the needed support to the FPD.

38 Contractor IPT Key Points (Slide 2 of 2)
Lesson Learned: Biggest challenge for the CIPT/SDIT is to assure active and effective communications between engineering design activities and safety analysis activities Especially true when they are not collocated Failure to support the iterative interactions between safety analysis and design is equivalent to failure to implement the processes of STD-1189

39 What is the Safety Design Integration Team (SDIT)?
Operations Safety Design Provides working-level integration of safety into design for the project Usually composed of subset of Contractor IPT plus other specialties as needed Core team Safety Design Operations (including maintenance) Additional composition depends on the hazards, safety, and security issues The following slides cover the objectives, functions, and the need for formality in establishing the SDIT. The core team should include the leads of the engineering disciplines involved in the design and the lead of the contractor safety team. Operations personnel (including maintenance) are especially important in the role of assuring that the designs are practical from the human factors perspective, as well as their experience in the technologies that may be involved in facility operations. Regarding the interactions between engineering design and safety, especially when different contractors are involved, it would help if project personnel were to receive some training in the type of interactions needed during the design process. One of the lessons learned in project execution is that “safety analyses often lag the design process.” It has also been stated that the needed iterations between design and safety depends on the professionals in these disciplines to “know when they need to communicate.” These lags are exacerbated when such awareness is lacking (training helps).

40 SDIT Objectives Ensure integration of safety in design by adherence to the key concepts and guiding principles of DOE-STD-1189 Document the bases for all safety in design decisions Maintain consistency of and configuration management between safety and design work Resolve initial uncertainties and assumptions for safety in design Achieve consensus and approvals for direction of safety in design progress Note: Through accomplishing SDIT Objectives and Functions (next slide), the SDIT implements the STD 1189 safety in design process. However, to fully implement STD-1189, Project Management must also make use of information developed by the SDIT (e.g., Risk and Opportunity Assessments, Safety Design Strategy, etc.) See Guiding Principle 10

41 SDIT Functions (Slide 1 of 2)
Timely communications with and support to CIPT and IPT Conduct Risk and Opportunities Assessment (input to RMP) Draft safety documents (CSDR, PSDR, PDSA)

42 SDIT Functions (Slide 2 of 2)
Ensure the iterative safety/engineering design process is effective and that the identified safety functions: Lead to selection of controls that are adequate to serve the safety functions and are consistent with operational needs Are classified appropriately Are accommodated in project cost and schedule estimates

43 SDIT Best Practices SDIT should have a charter
Define membership (core team and SMEs) Designate lead Define roles and responsibilities Specify required training for members SDIT should use formal processes Ideally the SDIT lead would have background experience in both engineering design and in safety analysis. The SDIT lead needs to be the driving force in assuring effective and frequent communications between the design and safety disciplines. An objective that was not stated in a previous slide is to minimize the time lag between the design and safety activities.

44 Safety Design Strategy (SDS) (Slide 1 of 3)
“…must be developed for all projects subject to this Standard.” (¶ 2.3) Developed from CD-0 definition of DOE expectations for execution of safety during design Prepared by SDIT; reviewed by DOE Safety Basis Review Team (SBRT); approved by Federal Project Director and Safety Basis Approval Authority (SBAA) See section 2.3 of the Standard.

45 Safety Design Strategy (SDS) (Slide 2 of 3)
Is a living document, updated throughout the project stages as needed Provides the mechanism by which all elements of the project and approval authorities can agree on basic safety in design approaches Single source for project safety policies, philosophies, major safety requirements, and safety goals to maintain alignment of safety with the design basis during project evolution

46 Safety Design Strategy (Slide 3 of 3)
Addresses: Guiding philosophies or assumptions to be used to develop the design Safety-in-design and safety goal considerations for the project Approach to developing the overall safety design basis for the project Significant discipline interfaces affecting safety

47 SDS Updates Focus is on those major safety decisions that influence project cost (e.g., seismic design criteria, confinement ventilation, safety functional classification, and strategy) Provide a means by which all parties are kept informed of and agree with important changes due to safety in design evolution between Critical Decision points

48 SDS Format (see Appendix E)
Purpose Description of the Project Safety Strategy 3.1 Safety guidance and requirements 3.2 Hazard identification 3.3 Key safety decisions Risks to Project Decisions Safety analysis approach and plans SDIT – Interfaces and integration See Appendix E of the Standard Should be as detailed as needed to communicate the strategy for successfully integrating safety and design and producing safety basis documentation that will be approved to allow either entry into the next critical decision or into operation

49 Risk Assessment DOE O 413.3A CD-1 requirement: “Prepare a preliminary Project Execution Plan, including a Risk Management Plan (RMP) and Risk Assessment… “ (Table 2) Risk management strategies must address All technical uncertainties (including schedule and cost implications) Establishment of design margins Increased technical oversight requirements The SDIT is best prepared to identify safety in design technical issues that need to be managed through a project’s Risk Management Plan

50 Risk and Opportunities Assessment (R & OA) (Slide 1 of 2)
DOE-STD-1189 Risk and Opportunities Assessment is: Required by the Order and the Standard and Provides the safety-related input to the Project Risk Management Plan Purpose is to recognize and manage risks of proceeding at early stages of design on the basis of incomplete knowledge or assumptions regarding safety issues

51 Risk and Opportunities Assessment (R & OA) (Slide 2 of 2)
SDIT prepares R & OA and updates it throughout the project phases Reviewed by IPT and DOE Safety Basis Review Team and approved by the Federal Project Director Discussed in DOE STD-1189 Appendix F Conservative safety design posture coupled with comprehensive risk and opportunities identification allows the project to define appropriate cost range estimates with a high degree of reliability. Opportunities relate to modifying early conservatisms as design evolves and avoiding later costs. Project risks are assigned to personnel to manage. It is likely that risks identified by the SDIT will be assigned to SDIT personnel to manage. Even risks that are transferred to other organizations need to be aggressively followed up on if resolution is important to the success of the project.

52 Example Risk Areas (Slide 1 of 2)
Technical Uncertain seismic requirements (seismic geotechnical investigation) SSC classifications (safety and seismic) Interfaces with site infrastructure and boundaries of safety SSCs with them Undefined, incomplete, unclear safety functions and requirements New or undecided technology See Table F-1 (pp F-3 -4) of STD-1189 for a more extensive list. Does it make a difference in how the FPD manages an issue if it is classified as a risk or as an opportunity? Answer is yes; project managers are more aggressive in pursuing opportunities.

53 Example Risk Areas (Slide 2 of 2)
Programmatic Level: Interfaces with other facilities (inputs and outputs) Coordination between design and safety organizations (if different) Implications of less than optimum dedicated IPT support for FPD Including ability to actively manage risks, including programmatic

54 Roles and Responsibilities (Slide 1 of 2)
Product/ Document Responsibility Interface with Other Documents/ Products Prepare Review Approve SDS SDIT IPT and SBRT FPD and SBAA DOE expectations in Mission Need Statement R&OA FPD Input to RMP CSDR Via CSVR CDR CSVR SBRT IPT SBAA with FPD Concurrence CSDR and CDR PSDR Via PSVR Preliminary Design This chart and the next one are abbreviated versions of Table 2-1 of STD-1189 (pp 12, 13) These tables are also consistent with Table 2 of O 413.3A (Critical Decision Requirements). Note that the Order table does not identify the FPD as the approval authority for project documents. The FPD is responsible for having all project documents prepared, so the issuance of them implies FPD approval.

55 Roles and Responsibilities (Slide 2 of 2)
Product/ Document Responsibility Interface with Other Documents/Products Prepare Review Approve PSVR SBRT IPT SBAA with FPD Concurrence PSDR PDSA SDIT IPT and SBRT Via SER Final Design SER DSA and TSR SDIT and Operations Team TSR is based on the DSA. SBAA

56 What Parts of the Standard are Mandatory? (Slide 1 of 2)
Originating with STD-1189 Safety Design Strategy Risk and Opportunities Assessment CSDR and PSDR (and DOE reviews) Appendix A seismic design basis and collocated worker safety significant SSC criteria Major Modification Determination (documented in SDS) Key Concepts and Guiding Principles (for full implementation of STD-1189) Ref. section 1.4 of the Standard (Must and Should) The word should is used for provisions of the Standard are not required but are recommended in order that the Standard can be effectively implemented. Where an activity is required by a DOE directive, but not directly involved with integration of safety with design, it is assumed to be carried out by the project (indicated by is or are, rather than a must. Musts are also associated with key concepts and guiding principles that are necessary for effective integration of safety with design. Failure to apply one or more of these musts implies failure to fully implement the Standard. Requirements specific to this Standard are defined only for objectively measureable parameters or conditions. Specific elements of the Standard can be tailored to fit a specific project through the SDS.

57 What Parts of the Standard are Mandatory? (Slide 2 of 2)
Derivative 10 CFR : PDSA; design criteria of O 420.1B DOE O 413.3A Chg. 1: requires implementation of STD-1189 DOE O 420.1B: nuclear safety, fire safety, criticality, NPH

58 Safety and Design Integration DOE-STD-1189-2008
Design Process by Project Phase The material in this section is based on Ch 3 of STD-1189.

59 Project Lifecycle Pre-Conceptual Conceptual Preliminary Design
Final Design Construction Turnover/Acceptance Operations CD-0 CD-1 CD-2 CD-3 CD-4 Pre-Project Planning Compare to LANL paradigm of 30, 60, 90 percent design LANL ref. is LANL Engineering Standards Manual PD342 It has also been characterized in the following ways: 30% Completion of hazards analyses (or 30% of drawings) 60% Completion of accident analyses (or 60% of drawings) 90 % Completion of PDSA (or 90% of drawings) With advent of STD-1189 and the emphasis on conceptual and preliminary design activities, this paradigm is OBE. Hazard and accident analysis all the way thru; level of detail increasing with increasing design evolution. Note: Title I is preliminary design; Title II is detailed design; Title III is engineering and construction services after CD-3

60 Pre-Conceptual Phase Objective is to identify and assess a program gap and then to propose a project to close the mission related performance gap Analysis focus: Special Safety Requirements New facility or modification Available technology Process material inputs and outputs Upper level facility functions Results in the development of Mission Need which becomes a baseline document in the project if CD-0 is granted

61 Safety-Related Activities in Pre-conceptual Phase (Slide 1 of 2)
Assign project safety lead (establishes continuity) Initial assessment of project safety issues Identify top level hazards (including process inputs and outputs) Determine preliminary hazard categorization Identify unique constraints affecting project safety approach Develop DOE expectations for safety activities

62 Develop DOE Expectations for Execution of Safety Activities (Slide 1 of 2)
Examples: Anticipated safety issues/hazards and goal (if any) for hazard category (Can affect process capacity through MAR limits; can affect issues regarding criticality hazards; could affect siting) Potential need for improvements in site infrastructure to support facility safety systems (an interface issue that might expand scope of the project)

63 Develop DOE Expectations for Execution of Safety Activities (Slide 2 of 2)
Potential need for geotechnical studies Expectations regarding confinement strategy Project tailoring (e.g., PDSA only for a major mod) Anticipated need for exceptions to O 420.1B and associated guides

64 Pre-Conceptual Phase It is important not to think of each box in these charts as individual steps that are completed along a path to completion. The iterative and interactive nature of the process within 1189 is illustrated by the grouped items and the use of double headed arrows. Note the numbers in some boxes in this and following similar figures. They correspond to section numbers of the Standard where the activities in that box are described further.

65 Identify Important Project Interfaces
Criticality Quality Assurance Fire Protection Emergency Management Human Factors Site Infrastructure Worker Safety and Health (10 CFR 851) Radiological Protection Hazardous Waste Management Safeguards and Security Transportation Environmental Protection Coordination with the DOE SBRT

66 Conceptual Design Phase
Goal for safety-in-design in this phase is to evaluate alternative design concepts, prepare the SDS, and provide a conservative design basis for the preferred concept Perform sufficient analysis to make informed safety decisions for this phase Document risks and opportunities for selections including cost and schedule range impacts Begin considerations of quality requirements, Quality Assurance Program (QAP) established (This phase is the best opportunity for safety analysis to cost-effectively influence design)

67 Conceptual Design Phase
Note that some of the boxes on these figures have numbers at the bottom. These numbers refer to STD-1189 section numbers. Talk through this diagram in detail. The similar diagrams at Preliminary Design and Final Design are primarily updates on the activities described here.

68 Key Safety-Related Activities (Slide 1 of 3)
Form Integrated Project Teams (both DOE and Contractor) and SDIT Develop Preliminary Security Vulnerability Assessment Develop Preliminary Fire Hazards Analysis Develop Safety Design Strategy Establish Configuration Management

69 Key Safety-Related Activities (Slide 2 of 3)
Evaluate alternatives and provide recommendations Assess risks and opportunities as input to the Risk Management Plan Develop preliminary hazard analysis (PHA) for recommended alternative Define safety functions Identify high-cost safety systems Initiate hazard analysis data capture (Appendix G)

70 Key Safety-Related Activities (Slide 3 of 3)
Identify facility-level design basis accidents (DBAs) Bounding consequences Safety and seismic classification Commit to nuclear safety design requirements (DOE O 420.1B) and place under design control Develop Conceptual Safety Design Report (CSDR) Maintain project interfaces focus (see Ch 7 of STD ) The safety design requirements of O 413.3A and the standards invoked in the associated guides (or alternatives to them) need to be put under design control. Expect to demonstrate implementation. See STD-1189 Appendix I (format and content of PSDR/PDSA) Appendix B of that 1189 appendix.

71 Conceptual Safety Design Report (CSDR) (Slide 1 of 2)
Document and establish a preliminary inventory of hazardous materials Establish a preliminary hazard categorization Identify and analyze facility-level DBAs Assess the need for facility-level hazard controls (safety SSCs) This listing is on p 28 of O 413.3A for a CSDR. These items are also consistent with Appendix H of STD-1189, format and content of a CSDR. See also STD-1189 definition for CSDR (p xviii)

72 Conceptual Safety Design Report (Slide 2 of 2)
Preliminary assessment of appropriate seismic design bases (facility structure and SSCs) Evaluate security hazards that can impact the safety design basis Commitment to nuclear safety design criteria Format and content of CSDR in Appendix H

73 Conceptual Safety Validation Report (CSVR)
CSVR prepared to confirm an appropriately conservative basis to proceed to preliminary design, based on: preliminary hazard categorization of the facility preliminary identification of facility DBAs assessment of the need for SC and SS facility-level hazard controls preliminary assessment of the appropriate seismic design bases position(s) taken with respect to compliance with the safety design criteria of DOE O 420.1B See STD-1104 section 5 See also STD-1189 Appendix H, section H.1.

74 Preliminary Design Phase
The activities described here build on similar activities during conceptual design stage and evolve the design to the point of final design (final design - dotting the I’s and crossing the t’s. The activities in the engineering and the safety design rows that are enclosed with dotted lines are highly interactive and iterative. They will be described in more detail in the next section of the course (Safety and Design Interactions).

75 Preliminary Design Phase
Advance conceptual design toward final design Evolve the Hazard Analysis (HA) to include process level HA Develop design-specific solutions based on safety design requirements Prepare for final design Complete NEPA documentation by end of design phase This is where the bulk of creative development design engineering is done. This assessment/opinion is based on O 413.3A understanding that final design activities focus on preparation of final drawings and specifications (based on the preliminary design) to support procurement. However the final design stage may well cost more than preliminary design just by virtue of the man-hours involved.

76 Safety Activities in Preliminary Design (Slide 1 of 2)
Update Security Vulnerability Assessment Update hazard analysis (HA) to address process level hazards based on the selected design Evaluate and apply DOE O 420.1B and associated guides Evolve system-level DBAs with appropriate added specificity based on selected design Decisions reversed after this stage, for whatever reason, can have significant impact on project costs and schedule. Because this is the most intense design stage, it also is where disconnects between design and safety iterations are a great threat. How can these disconnects be avoided?

77 Safety Activities in Preliminary Design (Slide 2 of 2)
Update Risk and Opportunity Assessment Update SDS reflecting design and safety evolution Develop the Preliminary Safety Design Report (PSDR)

78 Preliminary Safety Design Report (PSDR)
Developed to demonstrate safety adequacy of the preliminary design effort Limited to the extent that design information is also limited Format and content guide in DOE STD Appendix I DOE prepares Preliminary Safety Validation Report (PSVR) to approve PSDR, similar to (CSVR) in purpose and scope Note that the PSDR format is modeled after STD-3009 (although the content is more demanding). The intent is that the PSDR evolves through the PDSA to a DSA for operations in an orderly fashion.

79 Safety Activities in Final Design
Update and finalize preliminary safety in design analyses, information and documentation Update Risk and Opportunity Assessment (as needed) Update SDS reflecting design and safety evolution (as needed) Develop Preliminary Documented Safety Analysis DOE prepares a Safety Evaluation Report

80 Final Design Phase Pre - CD 3 , Final Design S a f e t y D s i g n B P r o j c E m d M 2 Approval Initiate Final Design Update Security Vulnerability Analysis Update Risk Management Plan Baseline Management Package Validate Design vs . Desired Control Functions & Criteria 4 Develop Design Output Documents Design Reviews ( Fed and / or Contractor as appropriate ) Update Hazards Mitigated Accident Update Safety SSC Functions and Classification PDSA Safety Evaluation Report DOE Authorizes Procurement Construction , & Final Implementation Update Safety in Design Risk Opportunities Assessment Execution Readiness Independent Review Updated SDS needed Update Project Risk Considerations Transition Closeout 7 O 413.3A understanding is that final design activities focus on preparation of final drawings and specifications to support procurement. If this paradigm is met, then the engineering and safety activities (see boxes enclosed by dotted lines) are primarily confirmatory in nature and also includes preparation of key design documents such as SDDs. To the extent this is not true (engineering design activities are still evolving the design) then the interactions in the dotted line enclosed boxes include the types of interactions described for preliminary design. As with preliminary design, other activities are primarily updates of activities begun at conceptual design, to the extent needed.

81 Final Design Phase Finalizes HA and DBAs (mitigated analysis)
Evolves the preliminary design to the point where Specifications are developed Security Vulnerability Assessment is finalized Procurement and construction can be accomplished Test, inspection, and commissioning requirements are developed and detailed System Design Descriptions (SDD) and Facility Design Description (FDD) are completed

82 Preliminary Documented Safety Analysis (PDSA)
Evolves from the PSDR Completes the analysis of the design Format and content covered in Appendix I Based on DOE-STD-3009 format Minimizes need to rewrite for DSA Provides the basis for design adequacy with respect to safety Change control of PDSA is established

83 Construction ,Transition, and Closeout Phase Design Related Issues
Field Changes Government Furnished Equipment (GFE) and other equipment not part of primary design Revisions to PDSA Changes to comply with readiness review issues Input to Documented Safety Analysis (DSA) and Technical Safety Requirements (TSR) It is important to not wait until now to get operations involved. They should be an active part of the design team from the beginning. This will make TSR development and implementation easier.

84 Criteria for Determining PDSA Revision (Slide 1 of 2)
The change: alters a safety function for a safety SSC identified in the current PDSA results in a change in the functional classification, reliability, or rigor of the design standard for an SSC previously specified in the PDSA configuration baseline See section 6.4 of the Standard.

85 Criteria for Determining PDSA Revision (Slide 2 of 2)
requires implementation of new or changed safety SSC or proposed TSR controls significantly alters the process design or its bases, such as increased material at risk, changes to seismic spectra, major changes to process control software logic, new tanks, new piping, new pumps, or different process chemistry

86 Safety and Design Interactions
Hazard and Accident Analyses and Inputs to the Design Process

87 Hazard and Accident Analysis: Initial Information Needed (Slide 1 of 2)
Facility site/location General arrangement drawings MAR estimates or assumptions and material flow balances Sizing of major process system containers, tanks, piping

88 Hazard and Accident Analysis: Initial Information Needed (Slide 2 of 2)
Process block flow diagrams for: Ventilation Electrical power Special mechanical handling equipment (e.g., gloveboxes) Instrumentation and control (I&C) system architecture Summary process design description and sequence Confinement strategy

89 Hazard and Accident Analysis (Slide 1 of 2)
At conceptual design stage (facility level analyses) Building structure Building and process confinement Power systems, including Safety Class single failure criteria Fire protection provisions Special mechanical equipment (e.g., gloveboxes) Initial focus on high-cost safety functions and design requirements The items listed are intended to be assessed through facility level DBAs. For example, the seismic design category of the building structure should be a product of the analyses. The approach to building and process confinement can be informed by the analyses. If SC functions are needed, that could affect the need for SC power supply and the application of single failure criterion. ETC.

90 Hazard and Accident Analysis (Slide 2 of 2)
At preliminary and final design stages Update and refine conceptual design analyses Extend to process and activity level and safety functions and SSCs

91 Hazard and Accident Analysis: Accident Types to Consider
Fires Explosions Loss of confinement/containment Process upsets (starting in preliminary design) Natural Phenomena Hazards Design basis accidents (for the accident types) Beyond design basis accidents (starting in preliminary design)

92 Hazard and Accident Analysis: Outputs to Engineering Design
For Structures, Systems, and Components (SSCs), based on DOE O 420.1B safety design requirements Performance Categories (wind, flood, etc.) Seismic Design Basis Safety Class functions Safety Significant functions Defense in depth /Important to Safety (ITS) safety functions Design codes and standards from Guides associated with DOE O 420.1B

93 Hazard Analysis and Design Basis Accidents (DBAs) at Conceptual Design
Simple DBAs are postulated based on facility level upsets involving limiting quantities of MAR and facility layout Unmitigated consequences are assessed to help establish both needed safety function and safety classification of that function These accidents are analyzed for both collocated workers and public impact; they are to help define safety functional and design requirements DBAs are refined and expanded upon in later stages of project At conceptual design stage, it is expected that at least a facility layout and locations and quantities of MAR would be available to support DBAs. These DBAs would assume accidents involving the MAR occur and the accident consequence levels (public and collocated worker) are used to classify preventative and mitigative SSCs as SC or SS. They would also be used for seismic design basis categorizations.

94 Hazard Analysis (HA) at the Process Level
HA and design iteration HA activities support identification of safety functions and selection of DBAs Includes consideration of in-facility workers DBAs and safety functions support design selection and associated design criteria Design selection / criteria support development of a refined HA for the PSDR Several iterations may be necessary as preliminary design progresses Hazard Analysis table updated as necessary

95 Design Basis Accidents in Preliminary Design
The Design Basis Accidents (DBAs): Refined from Conceptual Design based on system design Provide input for new or revised design criteria Establish system-level safety classification DBAs are selected based on safety function and magnitude of hazard Consider public and collocated worker consequences

96 Safety Interface with Design (Slide 1 of 2)
Assist designers in understanding and addressing Safety requirements from hazards and accident analyses Safety implications associated with design alternatives and trade studies Safety interpretation of DOE O 420.1B and DOE G requirements and recommendations

97 Safety Interface with Design (Slide 2 of 2)
Safety input into System Design Descriptions (SDD) System boundaries Safety functions and requirements Supporting analyses (safety SSCs can provide safety function when called upon) Project design reviews Include safety design basis information and information included in design products (e.g., SDDs)

98 When to Communicate Between Design and Safety
Factor Engineering Design Safety Potential Accident Scenarios Changes in facility or process layout Barriers to accident propagation established, changed, or removed (e.g., fire barriers, separation of hazardous materials) Introduction of new sources of energy or hazard (e.g., chemical, mechanical, kinetic, potential, flammable, explosive) Effect of any design factor where change: Introduces a new accident scenario alters a safety function for an SSC results in a change in safety functional classification, reliability, or design standards requires a new safety SSC or implies a new TSR control significantly alters process design or its basis Material at Risk (MAR) Tank Size Process details (e.g., inventory in gloveboxes) Total facility inventory, including all hazardous materials Damage Ratio (DR) Facility and/or process layout, including fire barriers Airborne Release Fraction MAR material type and form (gaseous, powder, solid) Leakpath Factor (LPF) Physical barriers to release of hazardous materials Building seismic design basis (SDB: Seismic Design Category/Limit State (SDC/LS)) Chi over Q (X/Q) Location change Definition of site boundary The safety in design process includes significant iterations between the design and safety disciplines. It has been said that, absent a defined process, these iterations require both disciplines knowing when they need to interact. This slide is based on two factors. One is that any change introduces a new accident scenario or that i tmplies a change in the 5 factor formula for accident consequences. Those factors are in the first column. Examples of the types of design changes that might result in changes in these items are listed in the second column. The second factor is the impact of the design changes on factors that might change safety classifications or categorizations that in turn can change the design requirements (codes and standards; single failure criteria; power supply, etc.). These impacts are shown in the third column and are common to each of the factors in the first column. See STD-1189 section 6.4, where these items are listed as those requiring DOE approval if made after an approved PDSA. The design team and the safety analyst need to be sensitive to accident analysis processes broadly  and to the things that can impact it to ensure alignment.  Stress to the importance of alignment before CD package release.  Each group is accountable to communicate to ensure alignment.  Basically anything that can drive changes across the columns needs to be communicated between the safety and design teams in real time (whoever generates the potential non-alignment) to ensure alignment.  This slide gives good examples of some things that can cause misalignments.

99 Quality Assurance Program Activities for Design Process
Establish formal work processes (document control, verification processes, configuration management) Training on standards, requirements, work processes Periodic assessments of documentation Independent design verifications, validations, assessments Controlling documents and drawings and changes to them to approved processes Identifying and controlling design interfaces O 413.3A requires that a QAP is developed and is applied to the project from its inception (during the Conceptual Design Phase). The bullets in this slide are selected from STD-1189 Chapter 7, section 7.1 as being QA activities essential for management of change in the design activities. Configuration management/management of change is essential in keeping track of the flowdown of functional requirements to design documentation and keeping this information consistent with safety documentation. Software tools are available to support this. The safety design requirements of O 413.3A and the standards invoked in the associated guides (or alternatives to them) need to be put under design control. Expect to demonstrate implementation. See STD-1189 Appendix I (format and content of PSDR/PDSA) Appendix B of that 1189 appendix.

100 Safety and Design Integration DOE-STD-1189-2008
Appendix A – Safety System Design Criteria At one of the first 1189 writing team meetings members from contractor organizations said that one of the most valuable things to do in saving time and money for projects would be to set definitive and objective criteria for seismic design requirements and for Safety Significant SSC designation. This Appendix does that related to radiological hazards.

101 Purpose of Appendix A Provides objective criteria requirements for specification of the seismic design basis and for safety classifications of safety SSCs Seismic design basis includes specification of seismic design category (SDC) and limit state (LS) for a safety SSC based on radiological hazards Adds collocated worker Safety Significant radiological classification criterion along with Safety Class criterion for the public Objective criteria in Appendix A replace subjective criteria (e.g., significant exposure) previously associated with Safety Significant classification and NPH seismic criteria. Subjective criteria often generated conflicts between designers and reviewers (eye of the beholder problem).

102 Seismic Design Basis Applies recently published national standards for seismic design of non-reactor nuclear facilities ANSI/ANS , Categorization of Nuclear Facility Structures, Systems and Components for Seismic Design; and ASCE/SEI 43-05, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities.

103 Seismic Design Standards
ANSI/ANS 2.26 provides seismic design bases (SDC and LS) for safety SSCs based on unmitigated radiological dose (as modified by DOE) to collocated workers and to the public and on the safety function of the safety SSC. ASCE/SEI provides the design criteria to use with the seismic design basis (SDB) DOE modification for implementation of ANS 2.26 is related to: use of conservative instead of mean values for unmitigated accident analyses limited to radioactive releases vs. rad and chemical for ANS 2.26 rad dose criteria for SDCs differ from Appendix A of ANS 2.26 (a non mandatory part of the Standard) worker is defined as the collocated worker at 100 m (ANS 2.26 does not differentiate between facility and collocated worker) ASCE uses input from ANS 2.26 (SDC and LS) to provide requirements for determining design basis seismic loading (from ANS 2.27 and 2.29) and prescribes design criteria that are tied to Limit States.

104 Seismic Design Criteria
Unmitigated Consequence of SSC Failure from a Seismic Event Category Collocated Worker* Public* SDC-1 Dose < 5 rem Not applicable – Defaults to SDC-1 SDC-2 5 rem < dose < 100 rem 5 rem < Dose < 25 rem SDC-3 100 rem < dose 25 rem < dose** These criteria (and other criteria in this Appendix and in Appendices B and C) are not “health based.” That is, they do not represent acceptable levels of accident consequences. These criteria are for safety classification purposes only. The safety classifications lead to design requirements and codes and standards to be applied in design. * Using the safety classification methodology for public and collocated workers ** If the public dose for SDC-3 is exceeded significantly for any project (between one and two orders of magnitude), then the possibility that SDC-4 should be invoked must be considered on a case-by-case basis.

105 Limit States (examples From ANS 2.26)
SSC Type Limit State A Limit State B Limit State C Limit State D Building structural components Substantial loss of SSC stiffness; some margin against collapse Some loss of SSC stiffness; substantial margin against collapse SSC retains nearly full stiffness and strength; passive components will perform normal and safety functions SSC damage is negligible Structures or vessels for containing hazardous material Low hazardous material; vessel not likely to be repairable Moderate hazardous liquids; cleanup and repair expeditious Low pressure vessels with worker hazard if contents released; damage minor Leak tightness must be assured; moderate to high hazard gases/liquids Stiffness is defined as resistance of an elastic body to deformation by an applied force. K = force/displacement It is an extensive (vs. intensive) property of a solid body. Note that the elastic modulus is a material property (intensive property). Strength : when a material has reached the limit of its strength, it has the option of either deformation or fracture. Source: Wikipedia Other SSCs covered include: confinement barriers (glove boxes, ducts), equipment support structures, filter assemblies and housings, etc.

106 Comparison of SDB to Performance Category
Ruggedness is related to the extent a structure is deformed with increasing design loads. Components have a range of ruggedness because of design factors used for various types of structural elements and applications. Components in SDC 5D can take the most severe seismic load without permanent deformation. Those in SDC 1A deform under minimum load but retain their structural stability. Seismic Ruggedness Factor was introduced to conceptually compare ANS 2.26/ASCE 43 seismic design provisions with those of STD 1020. Ref.: Seismic Design Implications Working Group Report to DOE HS-21, dated February 2, 2007

107 Supplemental Guidance for ANS 2
Supplemental Guidance for ANS 2.26 When Selecting SDCs and Limit States (SDB) Safety analyst, seismic design engineer and the equipment design engineer evaluate the functional requirements for the safety SSC and its subcomponents to determine the appropriate Seismic Design Basis (SDB). If the safety functions of a safety SSC include confinement and leak tightness, a Limit State C or D must be selected. Guidance is provided for an SDC-1 or SDC-2 SSC having safety functions requiring Limit States A, B, C or D.

108 Safety Classification Methodology: Public Protection
The guidance of DOE G and DOE-STD-3009, Appendix A, should be used in classifying SSCs as Safety Class (SC) for radiological protection The words “challenging” or “in the rem range” in those documents should be interpreted as radiological doses equal to or greater than 5 rem, but less than 25 rem In this range (5 to 25 rem), SC designation should be considered, and the rationale for the decision to classify an SSC as SC or not should be explained and justified 3009 guidance (public): Unmitigated release calculation: Take no credit for active safety features Take credit for passive safety features where they can be shown to survive accident conditions Leakpath factor (LPF) = 1 Source Term = MAR * DR * ARF (includes respirable fraction) * LPF Dose = ST * X/Q * DCF NUREG for determining 95th percentile value of X/Q X/Q is concentration divided by source term. Correlations are based on experimental observations under varying atmospheric conditions.

109 Safety Classification Methodology: Collocated Worker Protection
Use unmitigated accident analysis source term guidance in DOE-STD-3009, Appendix A, Section A.3.2 and DOE G Use dose of 100 REM TEDE at 100 m Use ICRP 68 dose conversion factors Apply X/Q value at 100 m of 3.5E-3 sec/m3 for the dispersion calculation Collocated Worker Objective criteria. Only MAR and ARF are variables; X/Q is specified in order to move discussions from atmospheric dispersion modeling to safety. 3009 guidance: Unmitigated release calculation: Take no credit for active safety features Take credit for passive safety features where they can be shown to survive accident conditions Leakpath factor = 1 Source Term = MAR * DR * ARF (includes respirable fraction) * LPF Dose = ST * X/Q * DCF

110 Backfit for Major Modifications
For major modifications of existing facilities, Appendix A criteria are applicable Backfit analyses should examine: The need to upgrade interfacing structures, systems, and components in accordance with these criteria, and Whether there should be relief for the modification from the design requirements that application of these criteria in design would imply

111 Additional Notes ANS 2.27, Criteria for Investigations of Nuclear Facility Sites for Seismic Hazard Assessments, and ANS 2.29, Probabilistic Seismic Hazards Analysis, have been completed and approved DOE plans to adopt them and to update DOE G (Natural Phenomena Hazard guide)

Appendix B, Chemical Hazard Evaluation

113 Purpose of Appendix B DOE is not invoking mandatory classification of safety SSCs or specifying nuclear design requirements based on chemical hazards alone, but the Standard does provide advisory chemical safety criteria. The guidance provides a sense of scale as to what is meant by a “significant exposure” in the criterion for classifying SSCs as safety significant. Note: DNFSB has advised DOE to consider the need to effectively implement controls for chemical hazards, including guidance on the design of hazard controls (ref. letter dated 2/22/08, Dr. Eggenberger to Mr. Sell). Note: NNSA and EM conditions for concurrence with App A of 1189 were that App A not include chemical hazards and that chem hazard criteria now in App B be non mandatory.

114 Content of Appendix B Guidance for consideration of Safety Significant designation of SSCs for significant chemical exposures is based on a process of: Screening chemicals (hazardous materials) to determine those that may have the potential to immediately threaten or endanger collocated workers or the public and Evaluating the severity of potential exposures against advisory classification criteria for collocated workers and the public Note: Chemical exposure for facility workers is addressed in Appendix C. Screening guidance is given in Section B.1 (p B-1) of STD-1189.

115 Appendix B Methodology
Methods for estimating chemical exposures are detailed in Appendix B Unmitigated chemical consequence analysis should use reasonably conservative values for the parameters related to material release, dispersal in the environment and health consequences It is desirable to reduce any tendency toward over- conservatism to achieve the risk-informed balance in the design of the SSCs Note guidance to use mean (instead of reasonably conservative) values of analysis parameters.

116 Advisory Criteria for Safety Significant Classification
Public Exposure > AEGL-2/ERPG-2/TEEL-2 (Potential for irreversible or serious long-lasting health effects) Collocated Worker Exposure > AEGL-3/ERPG-3/TEEL-3 (Potential for life threatening health effects or death) Hierarchy AEGL, ERPG, TEEL Acute Exposure Guideline Levels (AEGL, EPA) Emergency Response Planning Guidelines (ERPG, AIHA) Temporary Emergency Exposure Limits (TEEL, DOE)

117 Additional Notes DNFSB issue on design guidance for Safety Significant SSCs is being addressed: in a new draft DOE standard implementing ANSI/ISA (ISA-84), Functional Safety: Safety Instrumented Systems for the Process Industry Sector, by a revision to DOE G NNSA and EM each have issued guidance for Natural Phenomena Hazard (NPH) classification based on chemical hazard levels to the public and to workers NNSA: SS SSC onsite or offsite; SDC 3 for chemical hazards or PC-3 for non seismic NPH Facility worker remaining: SDC 3 for chemical hazards Facility worker prompt life threatening: consider SDC 3 SS SSC for facility worker protection (otherwise) SDC 2 EM: Equivalent level of safety for seismic and non seismic NPH events (rad) Atmospheric dispersion for non seismic NPH event same as App A, except for tornado/high wind events, including chemical releases SS SSC onsite or offsite; SDC 3 for chemical hazards or PC-3 for non seismic NPH, but with C/B exceptions leading to PC-2

118 EM Chemical Hazard NPH Guidance
Reference: 4/15/09 memo from Owendoff on Implementation of DOE-STD-1189, Integration of Safety into the Design Process for Environmental Management Activities Note: also addresses non-seismic NPH For chemical hazards, use Appendix A X/Q unless heavy gases or high wind/tornados are involved Criteria of Appendix B will be applied for safety significant designation and PC-3 designation, subject to cost/benefit analysis and consultation with EM HQ Consult the referenced document for details

Reference: 7/9/2009 memo from D’Agostino to the Deputy Administrator for Defense Programs (and others), Guidance and Expectations for DOE-STD , Integration of Safety into the Design Process, Natural Phenomena Hazard Design Basis Criteria for Chemical Hazard Safety Structures and Components Note: also addresses non seismic NPH Guidance mandatory for projects not yet in preliminary design (July, 2009)

Appendix B criteria suggested for use for safety significant classification and initial categorization of SDC-3 or PC-3 (rad and non-rad) SDC-2 or PC-2 may be justified based on technical or cost/benefit considerations with approval of Acquisition Executive Similar guidance for in-facility worker protection (SDC-3 or PC-3) when it is necessary for them to remain in the facility after an accident for safety related purposes Appendix C criteria suggested to be used for safety significant classification for in-facility workers Consult the referenced document for details

121 Safety and Design Integration DOE-STD-1189-2008
Appendix C – Facility Worker Hazard Evaluation For worker safety, Safety Significant SSCs are those whose failure is estimated to result in a prompt worker fatality or serious injuries or significant radiological or chemical exposures to workers. Appendix C provides guidance on related hazards analyses and what might be considered “significant” in the context of facility worker exposures.

122 Hazard Analysis A qualitative evaluation of unmitigated consequence to the facility worker (FW) considering: energetic releases of radiological or toxic chemical materials where the FW would be unable to take self-protective actions; deflagrations or explosions where serious injury or death to a FW may result; chemical or thermal burns to a FW that could reasonably cover a significant portion of the FW’s body; and leaks from process systems where asphyxiation of a FW normally present may result.

123 Significant Exposure For radiological consequences, the suggested evaluation criterion is 100 rem TEDE. For chemical exposure, the evaluation criterion is AEGL-3 or equivalent (e.g., ERPG-3, TEEL-3).

124 Qualitative Results By comparing the qualitatively derived FW radiological or chemical consequence to these evaluation criteria, an assessment can then be made about the need for SS preventive or mitigative controls. Where the qualitative consequence assessment yields a result that is not clearly above or below the evaluation criteria, then the need for SS FW controls shall be more closely considered by the project.

125 Safety and Design Integration DOE-STD-1189-2008
Facility Modifications

126 Facility Modifications
The process for integration of safety into the design of facility modifications is similar to that for new facilities, but it is tailored to the scope, magnitude, and complexity of the modification.

127 Facility Modification Process
Note: Because a simple modification could come under O 413.3A (cost greater than 20 million), this figure is not completely accurate. There should be a route into the diamond asking if applies from simple modification.

As defined by 10 CFR 830.3, major modifications are those that “substantially change the existing safety basis for the facility.” A major modification requires the development of a Preliminary Documented Safety Analysis (PDSA) ( ) and approval of the PDSA by DOE ( ) prior to procurement or construction of the modification

129 Evaluating Modifications (Slide 1 of 2)
Simple modifications - existing hazard analysis is adequate for the modification; hazard controls adequately address the modification and associated activities; implementing the existing change control processes is adequate to support the proposed change.

130 Evaluating Modifications (Slide 2 of 2)
Note that a simple modification or a less-than-major modification might invoke DOE O 413.3A, and therefore STD-1189, under cost criteria. In those cases, a Safety Design Strategy (SDS) is required, wherein the bases for the modification classification must be described. The SDS also provides the mechanism for tailoring the application of STD-1189.

131 Determining a Major Modification
It is important to determine the need for a Preliminary Documented Safety Analysis (PDSA) as early as feasible in planning for a modification. In many situations, the need for a PDSA may be readily discernable with little or no detailed evaluation required. The Standard establishes criteria for evaluating the need for a PDSA. If a PDSA is warranted, the facility modification is a Major Modification.

132 Major Modification Criteria (Slide 1of 2)
Add a new building or facility with a material inventory > HC 3 limits or increase the HC of an existing facility? Change the footprint of an existing HC 1, 2 or 3 facility with the potential to adversely impact any SC or SS safety function or associated SSC? Change an existing process or add a new process resulting in the need for a safety basis change requiring DOE approval? These criteria are presented in the Standard on pages 77 and 78 along with a discussion of each. Examples of application of the criteria are contained in Appendix J of the Standard. No one criterion is controlling. It is a judgment driven process. It may be useful to work through one of the examples in Appendix J

133 Major Modification Criteria (Slide 1of 2)
Utilize new technology or Government Furnished Equipment (GFE) not currently in use or not previously formally reviewed and approved by DOE for the affected facility? Create the need for new or revised Safety SSCs? Involve a hazard not previously evaluated in the DSA?

134 Safety Design Strategy for Major Modification
Where a major modification is found to exist, an SDS should be developed that addresses: The need for a CSDR or PSDR (as well as the required PDSA) to support project phases The graded content of the PDSA necessary to support the design and modification The application of nuclear safety design criteria The interface with the existing facility, its operations, and construction activities

135 Summary of Major Modification Determination Process
Determine whether the modification is a major modification Determination involves qualitative evaluations of six criteria No one criterion is determining Process relies on judgment based on consideration of all the criteria evaluations, on balance Process and criteria are described in Ch 8 of the Standard Specific examples are in Appendix J of the Standard

136 Safety and Design Integration DOE-STD-1189-2008
Lessons Learned

137 Sources of Lessons Learned
DOE Project Reviews DNFSB Project Reviews Project Implementation Experience Implementation Questions from Field Questions During 1189 Training Sessions

138 Lessons Learned (Slide 1 of 5)
Need for detailed training on STD-1189 for FPDs, safety leads, engineering leads Surface level review of the Standard; focus on products (SDS, CSDR, PSDR, etc. instead of understanding the integrating process approach) Project management, safety, and engineering design personnel should have a level of familiarity with the requirements and guidance relevant to the other disciplines

139 Lessons Learned (Slide 2 of 5)
Issues missed in application: Level of HA as function of design stage; Nuclear criticality safety not included in HA/control identification; Risk and Opportunity Assessments not carried into Project Risk Management Plan; Security not included in SDIT

140 Lessons Learned (Slide 3 of 5)
Need for formality in establishment and activities of Safety Design Integration Team (SDIT) Project management commitment; designation of an SDIT lead (forcing function for effective communication between safety, design, and engineering) 140

141 Lessons Learned (Slide 4 of 5)
Importance of a requirements management system (e.g., Dynamic Object Oriented Requirements System) Need flowdown of functional requirements to design documentation [System Design Descriptions (SDDs)] Need management of change Don’t let development of SDDs get out of sync with safety input and documentation in CSDR, PSDR, PDSA Need to assess/validate ability of safety SSCs to provide the safety function indicated by hazards analysis

142 Lessons Learned (Slide 5 of 5)
Role of the Safety Design Strategy (SDS) document Tailoring of CD phases and safety documentation Revising conservative safety assumptions with better information as design proceeds Real time mechanism to achieve consensus on safety in design approaches (living document)

143 FAQs Does commitment to O 420.1B criteria mean commitment to the associated guides as well? Means for choosing/justifying alternative safety design criteria. Level of detail of DOE review of safety design documents (CSDR/PSDR/PDSA) in meeting O 420.1B safety design requirements. How to modify early conservative safety design assumptions/approaches. Considerations. What is Code of Record?

144 Commitment To DOE O 420.1B Guides
Does commitment to O 420.1B criteria mean commitment to the associated guides as well? Guides are not requirements (unless committed to by contract) DOE expectation is that guides will be followed Considerations? Cost Schedule implications Equivalent or better outcomes/demonstration thereof

145 Level of DOE Review of Safety Design Documents
What is the level of detail of DOE review of safety design documents (CSDR/PSDR and PDSA) in meeting O 420.1B safety design requirements? A function of the stage of design Sufficient to identify issues that need to be addressed in the next stage Sufficient to determine acceptability of safety-in-design approaches

146 How to Modify Early Conservative Safety Design Assumptions/Approaches
Potentials for this should be identified in the Safety Design Strategy (SDS, Risk & OA, and the Project RMP) Modify the SDS and get approval of the update Considerations Refined design inputs (process design, MAR, new information…) Cost and schedule impacts of redesign (e.g., redesign of building structure for lower Seismic Design Category/Limit State (SDS/LC)

147 What is the Code of Record?
Set of design codes, standards, and other requirements that are the bases for design and operation Originates at CD-2 (preliminary design approval) and is important to cost basis Documented through design documents and PSDR/PDSA Can be added to or modified throughout the life of a facility Example of where code of record became an issue is the Salt Waste Treatment Facility (SWTF) at SRS. Facility was being designed to NPH requirements that called for PC-3 only when an NPH event could cause a site boundary dose exceeding 25 rem. SRS requirements called for SS designation if collocated worker dose exceeded 100 rem (average meteorology) DNFSB asserted SS designation required PC-3 for building structure if it was relied upon for confinement. EM agreed and directed contractor to comply, thus changing the previous understood code of record

148 Summary (Take Aways) The importance of the SDS as a consensus document for planning the path forward. The importance of the SDIT and timely communications in the iterative nature of feedback and improvement between safety input and design outputs The importance of the CDSR and PSDR and their approvals as timely communication documents to provide the safety-in-design basis for proceeding to the next design stage

149 Summary (Take Aways) (Continued)
Management support and utilization of the process; utilization of the R &OA; conformance of the project to the Key Concepts and Guiding Principles of 1189 The importance of a proactive approach in identifying and addressing safety in design issues in a timely fashion

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