U.S. department of energy safety design strategy review and approval beyond critical decision 3 for the high-level waste facility - 15525
The Waste Treatment and Immobilization Plant (WTP) in Hanford, Washington, is the nation's largest environmental remediation construction project. In 2012, at the WTP's High-Level Waste (HLW) Facility, the U.S. Department of Energy (DOE), Office of River Protection (ORP) restricted construction work at the Hazard Category 2 nuclear facility because of unresolved technical issues associated with the facility and of misalignment of the design and nuclear safety basis. By 2013, as additional issues were discovered, ORP limited HLW design and procurement activities. Addressing the technical issues and the misalignment of the design basis with the Preliminary Documented Safety Analysis (PDSA) is a priority for ORP. A proposal was developed to use the concept of a safety design strategy (SDS), as documented in DOE-STD-1189-2008, Integration of Safety into the Design Process, as a planning mechanism to support facility design and PDSA alignment. The standard provides the processes to develop an SDS that will ensure safety is integrated into design early in the project, by the start of preliminary design. Ultimately, as design progresses, an SDS is intended to support development of the project's PDSA. However, in this unique case, the HLW Facility design and construction phase has progressed beyond Critical Decision 3 and DOE-STD-1189-2008 was issued in 2008; 6 years after ORP approved the first WTP PDSA. In July 2013, ORP and the contractor recognized that the unresolved technical issues and design - safety basis misalignment should be addressed through a renewed look at nuclear safety requirements, and agreed that developing an SDS tailored to the criteria in DOE-STD-1189-2008 provided the best path forward to better integrate design and safety. Development of the SDS for the HLW Facility was one of many goals ORP established in a plan that describes how ORP will determine whether, and under what conditions, the contractor should be authorized to proceed with production engineering, procurement, and construction activities for the HLW Facility. Over the next several months, the contractor developed the draft SDS, identifying design basis accidents and control strategies for those accidents. ORP monitored progress and, when appropriate, provided recommendations. In April 2014, the contractor provided a draft SDS to ORP for initial review by an independent DOE Review Team. The Review Team was comprised of representatives from nuclear safety, criticality safety, engineering, fire protection, the Office of Environmental Management, the Assistant Manager WTP, and the DOE Chief of Nuclear Safety. A unique draft document review and interactive review process, facilitated through work sessions and continuous communication with the contractor, culminated in the development of 147 technical comments on topics varying from SDS implementation to hydrogen deflagration in vessels. Comment resolution sought to improve project clarity, delineation of control strategies, and, holistically, facilitate integration of safety into design in the SDS, as it will guide the restart of the HLW Facility production engineering and limited procurement and construction activities. All comments were resolved in support of a contractor submission of the final SDS to ORP at the end of June 2014. Successful resolution of these comments was achieved by continuing the real-time response and incorporation interaction with the contractor to ensure that mutual objectives were satisfied. The response times were facilitated through telephone, E-mail, and a shared file server accessible to contractor and DOE reviewers across the DOE complex. As a measure of success of this process, the Safety Basis Approval Authority (ORP Manager) and the WTP Federal Project Director approved the SDS on August 1, 2014, with no conditions of approval. DOE and the contractor recognized that it would be difficult to implement the SDS without changes to the existing contractor's engineering and nuclear safety processes. Accordingly, the contractor developed or revised a significant number of engineering and nuclear safety plans and procedures to implement the SDS into the design process. Over the coming year, the contractor will conduct a gap analysis between the SDS and the presently approved PDSA to incorporate the design basis accidents and preferred control strategies developed from the SDS into the PDSA. In addition, ORP will conduct an assessment of the contractor's implementation of the SDS into the design process at the appropriate stage of implementation, within 6 to 12 months of approval. Although the SDS was developed late in the HLW project timeline, the document will facilitate alignment of design and the safety basis, and is a key step in the return to full production engineering for the HLW Facility. (authors)