Example 14: Lessons Learned from a Readiness Evaluation Process

DOE-STD-1120-2005/Vol. 2

Justification: No equipment is identified as important to safety in the safety basis (SB). The

proposed changes do not require any equipment to be designated as important to safety. However,

administrative controls and safety management program (SMP) commitments take the place of

equipment important to safety (EITS) hardware in most remediation activities. The SB (chapter 5,

section 5.2) and the work instruction commit to the SMPs. There are no "increases in the probability

of malfunctions" to controls important to safety created by the proposed change to the work

instruction in the form of deviations to the company approved safety management programs.

Therefore, the answer to this question is "No."

The "controls" in this case are not limited to TSR level controls but include defense in depth similar to the

discussion in the DOE G 424.1-1 on equipment important to safety not being limited to safety significant

or safety class equipment. The controls are those administrative practices that would weaken or

circumvent a safety function implicitly or explicitly identified in the Safety Basis.

Example 14:

Lessons Learned from a Readiness Evaluation Process

A Hazard Category 2 nuclear facility was shutdown in 1992 and is currently planned for deactivation.

The facility still contains significant quantities of uranium hexaflouride in process lines and various

degraded containers. Adjoining the facility is a metal recovery operation, which is to be retained to

support recycling of weapons parts. Both facilities share a common ventilation system that is

contaminated with various uranium isotopes, including U-233.

After consultation with the DOE field office, it was determined that the appropriate level of readiness

evaluation appropriate for the facility deactivation was an ORR. This level of readiness evaluation was

selected for the following reasons:

The facility contained significant quantities of dispersible hazardous substances, including

radioactive materials, contained in aged, degraded, and non-criticality-safe containers.

The process of removing materials from the facility was complex, since much of the material was

contained in numerous process lines and in a ventilation system.

The facility undergoing deactivation, as well as the adjoining metal recovery operation, contained

classified quantities and configurations of materials.

The deactivation project represented the first major disposition project at the site.

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