Conduct of Operations

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

Effective implementation and control of operating activities are primarily achieved by establishing written standards in operations

• Have implementation plans been developed, approved, and implemented for DOE 5480.19?
• Does the implementation plan and schedule support safe operation until full compliance is achieved?
• Are deviations from requirements identified by the laboratory and evaluated and approved by the responsible DOE office? Do deviations represent undue risk to worker or public health and safety?
• Have procedures and guidance documents been developed, issued and
  implemented in accordance with plan and schedule requirements
• Do workers demonstrate an awareness of applicable procedure and guidance document requirements?
• Does the guidance explain the role of safety analysis reviews, job safety analyses, and the handling of safety matters?
• Do all personnel understand the safety planning requirements?

Performance Objective 2: Contractor Program Implementation

2.1 Shift Routines and Operating Practices:

• Are operations personnel qualified for their assigned duties?
• Do supervisors consider qualification status when assigning personnel to duties?
• Do operators follow procedures? Are they aware of facility policy regarding procedure use?
• Do operators know the current status of the facility and systems? Do operators understand the requirements for changing system and facility status?
• Are operators attentive to their duties and do they carry out those duties in a professional manner?
• Do operators meticulously observe safe work practices?
• Do supervisors monitor operator proficiency and performance, giving instruction where necessary?
• Are personnel involved in significant or frequent violations of operating practices counseled, retrained, and disciplined, as appropriate?
• Do supervisor performance appraisals and promotions include an assessment of safety performance?
• Is proper hearing, eye, head, foot, and respiratory protection being worn in designated areas to reduce the potential for injury?
• Are ladders or other approved means used to access equipment located in the overhead when permanent steps or catwalks are not available, thus minimizing the potential for accidents?
• Do operators avoid routinely climbing or walking on facility components and insulation?
• Do operators exercise appropriate precautions when entering or working in or around energized panels or equipment? For example, do operators ensure that electrical panel closures are securely fastened prior to making the breakers operable to energize equipment?
• Do tours include inspection of equipment to ensure that it is operating properly or, in the case of standby equipment, that it is fully operable? .
• Are the following activities conducted in conjunction with the tour:
  • The status of equipment (i.e., operating, standby, work in progress, or out-of-service).
  • Components, such as electrical panels, alarm panels, auto-start standby equipment, and breakers are inspected for abnormal or unusual conditions?
  • Unexpected conditions (e.g., equipment vibrations, unusual noises or smells, or excessive temperatures) are reported to the control room?
• Do operators inspect all areas for which they are responsible and note any deficiencies that may be present, including steam, oil, or water leaks; fire and safety hazards or radiological problems; seismic concerns such as open electrical panels and mobile objects; clogged floor drains; housekeeping or cleanliness problems; and building deficiencies such as inoperative lighting, roof leaks, or doors that do not close properly?
• Do operators take appropriate action to correct or report deficiencies noted during tours?
• Are key equipment parameters recorded during tours to provide a record of equipment performance and to reconstruct events leading up to unusual occurrences or system malfunctions?
• Is short-term trending done so that undesirable trends and equipment safety problems can be identified and corrected?
• What process exists to ensure that written materials and entertainment devices not related to job duties are prohibited from use by on-duty personnel?
• Is safety and emergency information promptly recorded in the logs?
• Is written guidance provided to define thoroughly the type and scope of entries for each log and the format for making entries?
• Are log entries made in a manner such that they can be easily read and understood, and readily reproducible with standard photocopy machines?
• Is a standardized method for correcting any erroneous entries established?
• Does management provide written guidance on the disposition of completed logs?
• Do oncoming operators and supervisors review documents specified on their checklists and ask pertinent questions prior to assuming responsibility for their shift position?
• Do off-going supervisors or operators explain all items noted on the turnover checklist to oncoming operators?
• Is a crew briefing conducted by the operations supervisor as required after he/she has accepted responsibility for the shift, including a review of the status, problems with equipment, and evolutions in progress or planned during the shift?
• Do reliefs occurring during the shift (e.g., exchange of control supervisory function) have a turnover to ensure that the oncoming person is at least as knowledgeable of the conditions as he would have been had a complete shift turnover process been conducted?
• Is a method in place to designate which documents need to be read by the individuals filling each position, and are documents readily available to those individuals?
• Is a list maintained of operations, training, and industrial safety documents to be included in the required reading file?
• Are required completion dates designated for reading each document?
• Is completion of the reading documented and the documentation retained?

2.2 Investigation of Abnormal Events:  Abnormal events are investigated to ensure that facility events are thoroughly investigated to assess the impact of the event on facility operations, worker safety and health, the environment, and public welfare

• Do supervisors and managers frequently make direct observations of operations activities that include monitoring of OSH performance of operations personnel?
• Are OSH issues, requirements, and program information incorporated into training programs for managers and supervisors?
• Are safety goals used as a management tool for involving cognizant groups or individuals in improving operating performance and for measuring operating effectiveness?
• Are safety goals auditable, measurable, realistic, and challenging?
• Is a definite set of actions or an action plan developed to meet these goals?
• Was the action plan developed with input from personnel involved in conducting operations, reviewed by the operations supervisor at DOE facilities, and approved by management?
• Is progress toward completing the action plan and achieving goals monitored periodically?
• If results show a significant variance from the desired progress in achieving goals, does management review the action plan to ensure that it is adequate and is being executed?
• Are audits of performance relative to safety goals provided to facility management and DOE?
• Do these summaries include an explanation of performance and actions planned to improve future performance?
• Are meaningful operating and safety goals set and used as motivators for improvement, not as ends in themselves?
• Are OSH inspections, audits, reviews, investigations, and self-assessments a part of the checks and balances in the operating program?
• Do line managers and supervisors perform routine observations of personnel performing operating activities, from the perspective of industrial safety?
• Are deficiencies identified, documented, trended, and corrected?
• Do other groups, such as quality assurance personnel, periodically review and assess OSH?
  Are criteria for when to perform an event investigation clearly established?
• Are specific events requiring investigation listed for supervisory use, along with criteria for use in deciding what "near miss" situations should receive review?
• Do "near miss" situations receive a formal review at the discretion of the responsible supervisor?
• Does the operations supervisor or another manager have responsibility for event investigations?
• Do knowledgeable and experienced individuals perform the investigation?
• Are these individuals technically knowledgeable, well respected by the facility staff, unbiased, trained in major disciplines appropriate for the event under investigation, and trained in techniques for conducting an investigation?
• Are sufficient data collected to allow the event investigators to perform a reconstruction and analysis of the event?
• Upon completion of the data collection, is a structured review of the abnormal event conducted?
• Does each event investigation include the following steps?
  • Event Reconstruction
  • Event Analysis and Evaluation
  • Root-Cause Determination
  • Corrective Action Determination.
• Are investigative reports prepared in a timeframe determined by the responsible authority?
• Do reports include a description of the event (including pertinent conditions), a discussion of the impact of the event, root cause, the lessons learned, and the proposed corrective action(s)?
• Do reports include positive aspects of the event (such as particularly effective personnel responses)?
• Are investigative reports approved by the facility manager and reviewed by appropriate supervisors, managers, and the safety review committee?
• Are the lessons learned from an event investigation shared with all appropriate personnel who could benefit from the lessons learned?
• Are in-house events evaluated by the appropriate supervisor to determine if the event should be included in the training program for their personnel?
• In the case of events of severe or safety consequences, does a mechanism exist so that appropriate personnel could be immediately trained on that event?
• Are patterns of deficiencies such as operator errors or inadequate procedures trended?
• Is a periodic summary report of events, causes, and trends submitted to department heads, the facility manager, and appropriate managers?
• Do department heads ensure training programs include appropriate material from the summary report?
  Are procedures developed to address appropriate notifications and do they include the following elements:
  • specific responsibilities for notifications
  • identification of events and conditions requiring notifications
  • identification of primary and alternate personnel to be notified
  • establishment of time requirements for notifications that are consistent with the facility emergency plan
  • definition of recordkeeping requirements that document the reason for notifications, the time of notifications, and the person notified?
• Are names of primary and alternate contacts and current phone numbers and page codes readily available to the person assigned to make the notifications?
• Are all notifications documented and a formal record of notifications maintained?
• Is adequate communication equipment maintained in the main control area to meet the notifications objectives?
• Are operators familiar with the purpose and hazards associated with facility storage and use of such chemicals as boron, acids, caustics, chromates, hydrazine, ammonia, solvents containing chlorinated hydrocarbons, and chemicals containing organic solvents?
• Do operators understand chemical and radiochemical parameters, including calculations associated with technical specifications/operational safety requirements?
• Do operators monitor properties and hazards of such gases as hydrogen, nitrogen, carbon dioxide, chlorine, and halon?
• Are personnel knowledgeable of corrosion problems, including stress corrosion, intergranular cracking, and ammonia attack of copper alloys?
• Do operators understand chemical constraints, process equipment, and controls associated with the radioactive or toxic waste systems?
• Do operators understand operation of such water pretreatment equipment as clarifiers or charcoal filters (if such equipment is operated or monitored by operations personnel)?
• Are personnel knowledgeable of appropriate response and recovery from off-normal or hazardous conditions?
• Are the topics discussed above appropriately addressed in training programs?

2.3 Control of Equipment and System Status: Operating practices ensure that the facility configuration is consistent with design requirements and that the on-duty personnel know the status of equipment and systems.

Lines of Inquiry

• What process exists to ensure that only trained and authorized personnel operate equipment regulated by safety standards (i.e., cranes, forklifts, construction vehicles, etc.)? [
  Are methods that identify deficient equipment to operating personnel established?
• Does the operations supervisor or his/her designee authorize in writing all shift activities (including maintenance) on equipment that is important to safety, that affects operations, or that changes control indications or alarms?
• Is equipment tested, and testing documented, following maintenance to demonstrate that it is capable of performing its intended function?
  Are the following components labeled?
• Is information on labels consistent with the information found in facility procedures, valve lineup sheets, piping and instrument diagrams, and hazardous materials containers?
• Are label abbreviations and nomenclature used standardized and understood by facility personnel?
• Are labels permanent, securely attached, and do they have distinguishable, easy-to-read information?
• Where color coding is used, are the colors applied consistently, with only one meaning per color or combination?
• Is piping labeled to indicate the fluid contained and the normal flow direction?
• Are pipes containing potentially radioactive fluids, toxic fluids, or explosive gases uniquely marked?
• Are labels made from materials that are compatible with their particular application? For example, chloride-free labels should be used on stainless steel piping, and temperature-tolerant labels should be used on hot components. Are adhesives used for label attachment verified for compatibility?
• Are labels oriented in a manner that is easy to read so that the correct component or material is easy to identify?
• Are labels place so as not to interfere with equipment operation or obscure indicators?
• Are procedures established to ensure that misplaced or damaged labels are replaced?
• Does a method exist to help ensure the prompt identification and correction of labeling deficiencies?

2.4 Lockout and Tagout & Independent Verification

• Are devices for energy or toxic material isolation locked out?
• Are isolating devices that cannot be locked out tagged out?
• Do new equipment and major modifications provide for lockout?
• Is administrative guidance established to outline acceptable controls over locked components?
• Are locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware provided for isolating, securing, or blocking machines or equipment from energy sources?
• Are Lockout/Tagout devices singularly identified and do they meet OSH requirements?
• Is a Lockout/Tagout program established consisting of procedures to control potentially hazardous energy and materials and personnel training?
• Are clear and specific Lockout/Tagout procedures developed, documented, validated, and utilized for control of potentially hazardous energy or material?
• Is a clear and specific sequence of operations provided and used for temporary removal of Lockout/Tagout devices?
• Are periodic inspections conducted by authorized personnel, supervisor, or appropriate manager, to determine whether procedures are being followed and to correct any Lockout/Tagout deviations or inadequacies observed?
• Is use of caution tags for personnel protection administratively controlled and restricted?
• Is training provided and documented to ensure that the purpose and function of the Lockout/Tagout program are understood by all personnel and that they have the knowledge and skills required for safe application, use, and removal of Lockouts and Tagouts?
• Is Lockout or Tagout only accomplished by authorized, qualified personnel?
• Does a supervisor or appropriate manager notify affected personnel of the application and removal of Lockout/Tagout devices before the devices are applied and after they are removed?
• Do facility and outside contractors inform each other of their respective Lockout/Tagout procedures and ensure that their personnel are aware of the changes?
• Are specific procedures utilized during shift or personnel changes to ensure the continuity of Lockout or Tagout protection, including provision for the orderly transfer of Lockout or Tagout devices between personnel or shifts?

2.5 Operations Procedures

• Do these policies specify goals and the means to achieve those goals?
• Do these documents provide for the types of controls necessary to implement policies as discussed in the Conduct of Operations guidelines?
• Do operations procedures support facility and DOE OSH guidance?
• Do administrative procedures or writers' guides direct the development and review process for procedures?
• Are procedures developed for abnormal and emergency situations?
• Do preparation, verification, and validation of safety-related procedures receive high-level attention?
• Are procedure writers qualified by the job, training, and experience?
• Are procedures formalized by verification and validation? Who performs the verification and validation? Are the persons performing the verification and validation qualified to do so?
  Are procedure scope and applicability readily apparent?
• Are emergency procedures distinguishable from other procedures?
• Do procedures incorporate appropriate information from applicable source documents?
• Are prerequisites and initial conditions detailed?
• Are definitions used in procedures explained?
• Are procedures correct, easily understood, and actions clearly stated, with sufficient, but not excessive detail?
• Do procedures contain only one action per step?
• Are warnings, notes, and cautions easily identifiable and in appropriate position?
• Are limits and/or tolerances for operating parameters specified and consistent with the readable accuracy of instrumentation?
• Is acceptance criteria for surveillance or test procedures easily discerned, including tolerances and units?
• Are calculations clearly explained?
• Are procedures developed with consideration for the human-factor aspects of their intended use?
• Do emergency procedures provide guidance in responding to single and multiple casualties?
• Are portions or steps of other procedures that are used or referred to when performing a procedure specifically identified within the procedure so that personnel will not be confused when transferring between procedures.
  Is the review and approval process for each procedure change or revision properly documented and initiated?
• Are procedure revisions implemented concurrently with modifications?
• Is important information regarding changed or revised procedures communicated to appropriate personnel via the required reading system?
• Does the review process involve verification and validation of procedures using walkthroughs or similar methods?
• Are emergency procedures reviewed by the facility safety review committee or by another appropriate review mechanism?
• Are new and revised procedures reviewed prior to issuance and at periodic intervals to ensure that the information and instructions are technically accurate and that appropriate human-factor considerations have been included?
• Are applicable procedures reviewed following an unusual incident (i.e., emergency)?
• Is a controlled copy of all safety-related procedures maintained in the control area and at other appropriate locations for reference?
• Is the procedure the most current approved revision of the procedure? DOE 5480.19, Attachment 1, Chapter 16, C. 2. j.
• Have procedure changes outstanding for longer than 6 months been incorporated as revisions? DOE 5480.19, Attachment 1, Chapter 16, C. 3. c.
• Do procedures identify and have signature spaces for activities requiring independent verification? DOE 5480.19, Attachment 1, Chapter 16, C. 2. c.
• Do equipment, instrument, or component designators in procedures match control panel, switch, instrument, breaker, or component nameplates or labels? DOE 5480.19, Attachment 1, Chapter 16, C. 2. o.
• Are technical performance data in procedures such as instrument set points, relief valve set points, design pressures or temperatures, and points for operator action consistent with the authorization basis assumptions and safety analysis results? DOE 5480.19, Attachment 1, Chapter 16, C. 2. b.
• Is the procedure in use the most current approved revision of the procedure? DOE 5480.19, Attachment 1, Chapter 16, C. 6.
• If the procedure in use is a working copy, is it the most current approved revision of the procedure? DOE 5480.19, Attachment 1, Chapter 16, C. 6.
• Is the procedure user aware of the facility process for obtaining working copies of procedures? Did the procedure user follow that process? DOE 5480.19, Attachment 1, Chapter 16, C. 6.
• Has the facility implemented a policy for use of procedures? DOE 5480.19, Attachment 1, Chapter 16, C. 7.
• Does the procedure user understand the facility process on use of procedures? DOE 5480.19, Attachment 1, Chapter 16, C. 7.
• Did the procedure user verify completion or complete the required prerequisites and initial conditions? DOE 5480.19, Attachment 1, Chapter 16, C. 2. c.
• Did the procedure user complete all the applicable steps of the procedure in the required order of completion? DOE 5480.19, Attachment 1, Chapter 16, C. 7.
• Does the procedure user understand the action to be taken when procedures are found to be inadequate for the intended tasks or when unexpected results occur? DOE 5480.19, Attachment 1, Chapter 16, C. 7.
• Does the procedure user understand actions to be taken if procedures conflict or do not contain adequate guidance? DOE 5480.19, Attachment 1, Chapter 16, C. 7.
• Does the procedure user understand the facility policy on deviating from written procedures if necessary to protect personnel and equipment, or to maintain a safe condition? DOE 5480.19, Attachment 1, Chapter 16, C.

2.6 Communications:  Methods are in place and implemented to ensure that all facility personnel are promptly alerted to facility emergencies.

• Are alternate alerting methods utilized in areas where personnel cannot hear the public address system or emergency signals?
• Are emergency communications systems periodically tested to ensure that they are functional?
• Do control areas have the capability of overriding other users of the public address system for emergency announcements?
• Is excessive use of the public address system for paging of personnel and unnecessary announcements avoided?
• Are facility telephones and other point-to-point communications channels used in lieu of the public address system whenever practical?
• Identify all the existing methods available for operators in control areas to quickly contact on-shift operators or supervisors.
• Are the existing methods for contacting the on-shift operators and supervisors adequate?
• Is distinction made between a routine and emergency notifications?
• Are areas where radio use is prohibited delineated?
• Are instructions regarding frequencies (channels) and postings provided?
• Is consideration given to dedicating certain radio channels to specific groups or functions (e.g., a dedicated channel for security or a dedicated channel for emergency use)?Are only abbreviations and acronyms obtained from an approved list used in facility communications?
• Are both written and spoken terms prescribed in the list?
• Are oral instructions clear and concise? In all communications, are the sender and intended receiver readily identifiable?