Integrated Safety Management

DOE-HDBK-1129-99

3.3.2 Integrated Safety Management

All tritium-related operations and activities, including design, construction, system acceptance and

turnover, operations, shutdown, deactivation, and decommission for Category 2 and 3 Nuclear

Facilities (and Category 1, if ever applicable), should follow commitments identified in DOE

Integrated Safety Management (ISM) directives of the 450.4 series, which were an outgrowth from

the Defense Nuclear Facilities Safety Board (DNFSB) 95-2 Implementation Plan. The

commitments for ISM follow the seven Guiding Principles:

Line Management Responsibility for Safety

Clearly defined Roles and Responsibilities

Personnel Competence Commensurate with Responsibilities

Balance of Priorities

Identification of Safety Standards and Requirements

Hazard Controls Tailored to the Work Being Performed

Operations Authorization.

The process for planning and conducting pre-work hazardous analysis for all work operations at

tritium facilities should be consistent with the Guiding Principles listed and should follow a

structured approach commensurate with the risks and hazards involved. Several methods of

enhanced work planning and related work planning strategies used throughout the DOE complex

follow five steps: 1) Define Scope of Work, 2) Determine and Analyze Hazards, 3) Develop and

Implement Controls, 4) Perform Work, and 5) Monitor Work Performed and Provide

Feedback/Improvements. This sequence is one of many ways to ensure a structured approach in

work planning with a focus on worker safety and reduced environmental risks.

3.3.3 Facility Segmentation

Facility segmentation is discussed in DOE-STD-1027-92. Activities conducted in the same facility

may be separated into different areas for analysis purposes, but only if independence (in accident

space) can be shown. Potential areas for segmentation include:

Receiving area,

Receiving storage area,

Shipping area,

Shipping storage area,

Tritium unpackaging, handling, and packaging operations,

Low-level waste accumulation area,

Low-level waste packaging area, and

Packaged low-level waste storage area.

The independence of the segments, however, is not easily demonstrated. Common piping and

heating, ventilation, and air conditioning (HVAC) cannot exist to use this segmentation process.

Additionally, common cause initiating events (e.g., fire, seismic) affect multiple segments, thereby

placing an additional burden of proof on the analyst to demonstrate independence. A successful

segmentation analysis, however, would not affect the applicability of Price-Anderson enforcement

of the Nuclear Safety Rules to the facility.