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Facilities:
Y-12
National Security Complex (B&W Y-12) and
Lawrence Livermore National Laboratory
(LLNL)
Point of Contact:
Phil
Montgomery, Y-12 USQ SME, (865)
574-2322,
montgomerypb@y12.doe.gov,
or Mark Mitchell, LLNL USQ SME, EFCOG
SAWG USQ Subgroup Chair, (925) 422-8600,
mitchell36@llnl.gov
Brief Description of Best Practice:
The Unreviewed Safety Question (USQ)
process can be improved, becoming more
efficient and effective.
This best practice implements one
of the recommended actions to improve
efficiency of the USQ process,
consistent with the USQ white paper. The
Expert USQD Process is based on the
seven questions that derive from 10 CFR
830.203. It has been determined by DOE
to be Rule Compliant and capable of
producing results equivalent to the DOE
USQ Guide (Memorandum from Thomas P.
D’Agostino to Theodore D. Sherry,
Expert Based Unreviewed Safety Question
Determination Procedure, June 2,
2010).
The Expert USQD is essentially a
tailored USQD for certain simple
proposed changes that do not meet
today’s limited screening criteria.
It is unnecessary to spend
resources to perform a detailed standard
USQD for these type changes.
Proposed changes considered for
this process are limited to those
straightforward in nature and clearly
have no adverse impact on credited
elements in Safety Basis documents.
The Expert USQD Process limits
preparation of these USQDs to a limited
set of highly trained and experienced
“experts” who have actual nuclear
related experience in the facility.
A Y-12 National Security Complex USQ
Procedure containing the Expert USQD
option was reviewed and approved by the
NNSA Administrator’s office (NA-1) on
June 2, 2010.
Within the approval included the
following expectations:
“Based on the positive outcomes
at Y-12 and the expert nature of this
approach, other sites may explore this
approach under the following conditions:
(1) the site has a USQ process that is
consistent with the guidance in DOE
Guide 424.1-1A and has been implemented
for at least four years;
(2) results of assessments of the USQ
program have indicated acceptable
performance for at least two years; and,
(3) a successful pilot is completed at
the site prior to full implementation.
In addition, National Nuclear Security
Administration sites (including Y-12)
are expected to conduct an effectiveness
review of the expert-based USQ process
within twelve months of implementation
to ensure the integrity and quality of
the USQ process and the resulting
documentation is being preserved.”
Expert USQD have
been integrated into the USQ Process and
implemented at the Y-12 National
Security Complex and the Lawrence
Livermore National Laboratory (LLNL).
Why the best practice was used:
The USQ process as described in DOE G
424.1-1B and implemented at most of the
DOE sites is overly burdensome.
As described in the EFCOG SAWG
USQ white paper, the interpretations of
the Guide are interpreted differently by
the local DOE Site Offices and as
enforced from audits at most sites, has
resulted in a process that requires
significant amount of resources and
documentation regardless of the
complexity of the change.
In approving the Expert USQD Process,
DOE recognizes that some changes do not
warrant the investment of valuable time
and resources required to perform a full
USQD.
In order to perform work in
compliance with the rule, efficiently,
and focus attention appropriately on
changes requiring USQDs, the streamlined
USQ process has four levels of review:
1.
The first level consists of any
Categorical Exclusions (Section 3.2).
2.
The second level consists of a USQ
Screening (Section 3.3) of proposed
changes that were not categorically
excluded in step 1 to determine if a
USQD is required.
3.
The third level consists of the Expert
USQD (Section 3.4). This level applies
to proposed changes that were not
categorically excluded or screened out
in the first two levels of the USQ
process and determined to potentially be
applicable to an Expert USQD.
If the proposed change does not
fit the Expert USQD profile, it is
evaluated at the next level – Standard
USQD.
4.
The fourth level consists of the
Standard USQD (Section 3.5). This level
applies to PISAs and proposed changes
that did not complete the USQ Process in
the first three levels.
PISAs require a Standard USQD.
Note that these
levels of review are not required to be
sequential. If one knows a proposed
change cannot be screened and is not
applicable to an Expert USQD, then the
USQ Process may be start with a Standard
USQD.
What are the benefits of the best
practice:
At Y-12 the anticipated benefits are
approximately $1.2M in cost savings and
schedule efficiency gains of 40-50% once
fully implemented.
During the Y-12 Pilot runs of the
Expert USQ Process, approximately 60
percent of procedure changes were found
applicable to Expert USQDs while only
40% of physical changes could apply the
process.
(See Appendix 1)
Across the DOE Complex, as documented in
the Safety Analysis Working Group’s
White
Paper to Improve the Unreviewed Safety
Question (USQ) Process Across the DOE
Complex, efficiency improvements
from implementing Expert USQDs
complex-wide would range from 2 – 50%
due to varying complexities in
operations and differing screening
methods (see Appendix 2).
The USQ Subgroup believes that the
proposed recommendations will
effectively streamline the process while
maintaining the necessary rigor to
ensure the proposed activities that
required DOE approval, obtain that
approval.
What problems/issues were associated
with the best practice:
At
Y-12, process implementation was
decidedly successful.
The use of highly qualified
experts helped maintain a high degree of
conservatism and procedure compliance
required of this process.
However, the first few months of
data after Y-12 site-wide implementation
indicate less than optimum efficiency.
It appears that not all experts
have the time in their current
assignments to dedicate to Expert USQDs.
When approved experts are not
available, the other option to complete
a standard USQD is applied, thus
reducing efficiency gains.
To address this efficiency issue,
the site has better communicated the
benefits of Expert USQDs to managers in
an effort to free more time for expert
preparers or replace unavailable experts
with other more available qualified
experts.
As a result, the set of
authorized experts was re-shuffled.
The bottom line is that it is
important at the beginning of the expert
selection process to choose experts who
would be available for the expected work
and communicate to management the
savings from application of Expert
USQDs.
Optimal implementation of this best
practice can be further improved by
increasing the comfort level of
personnel in this new process and
expediting the learning curve.
Y-12 and LLNL applied lessons
learned during development of training
material to cover a wide range of topics
that experts may encounter.
Example training material from
one site (LLNL) can be found in Appendix
5.
Related to optimal implementation of
this best practice, a new tool was
presented at the EFCOG SAWG workshop
(appendix 3). The Office of
Science developed this tool to evaluate
sites and facilities that would
potentially be eligible for
implementation of the expert USQD
process.
Some NNSA sites have also found
this tool useful in determining and
documenting that the site and specific
facilities were ready to implement this
best practice.
How the success of the Best Practice was
measured:
Success was gauged by two measures at
Y-12.
First, by looking at Expert USQD
compliance to requirements (assessments)
when implemented, and second, by the
degree of implementation at the site.
Periodic assessments of Expert USQDs
were performed by both B&W Y-12 and the
NNSA Y-12 Site Office (YSO).
To date five Expert USQD
assessments were completed (three by B&W
Y-12 and two by NNSA) with no
significant issues.
One of the YSO assessments
addressed the requirement in the NA-1
approval letter to “conduct an
effectiveness review of the expert-based
USQ process within twelve months of
implementation to ensure the integrity
and quality of the USQ Process and
resulting documentation is being
preserved.”
At Y-12, the percentage of Expert USQDs
completed is tracked both at the
facility level and overall site-wide.
The estimated utilization for
Y-12, as determined from previous pilot
run information is anticipated to be
between 40 and 50% Expert USQDs.
Utilization percentage was
tracked at six months and 12 months
after implementation.
As indicated in Appendix 1, the
percentage of Expert USQDs to overall
USQDs (Expert + Standard) ran about 17%
for the first six months indicating room
for additional efficiency gains.
Follow-on actions to improve
efficiency were taken, as described
above, and efficiency was measured again
after the second six month period.
Utilization measured this time indicated
significant improvement, showing
approximately 28% utilization.
Description of
process experience using the Best
Practice:
A
short form, expert-based USQD, tailored
to evaluate simpler proposed changes,
may significantly increase the
efficiency of the USQ Process.
The purpose of an Expert USQD to
quickly and correctly determine, with
minimal documentation, if a proposed
change is not a USQ.
Depending on the site specific
process, the Expert USQD may also
determine that the change requires
further evaluation in a Standard USQD or
that the change is a USQ.
The Expert USQD Worksheet may be applied
to certain simpler and more
straightforward proposed changes where
it is readily apparent to safety basis
professionals that the change cannot
create a USQ.
The Expert USQD incorporates a
review checklist, modeled after the USQD
questions.
However, checklist questions may
be adjusted at the discretion of the
local DOE Site Office.
The outcomes of the Expert USQD
are either the proposed change does not
represent a USQ, or the change requires
additional review via a Standard USQD.
For those proposed changes found
not to represent a USQ, the preparer may
document any considerations deemed
relevant as to why it is readily
apparent a USQ would not exist.
Such documentation should be
brief and focused, and not be
commensurate with the level of detail
for a Standard USQD because of the more
straightforward nature of the change.
Expert USQDs still require review
and approval by Management (e.g., the
Facility Manager or the Operations
Manager).
If either the expert preparer or
reviewer has any doubt about the
applicability of the Expert USQD or a
definitive answer, then the Expert USQD
should be abandoned and the evaluation
documented in a Standard USQD.
The contractor’s USQ procedure
should also specify stricter
qualification requirements for
“experts.”
Specifically, the intent is not
to plug any preparer available into a
rotating “expert” slot.
Experts should have lengthier
career experience than the average USQD
preparer, thorough knowledge of the
facility and its operations as
demonstrated by documented, sustained
experience at the facility, and a
history of preparing USQDs for that
facility.
The contractor’s USQ procedure
should include a mechanism for a
formally defined list of experts
approved by the contractor’s
institutional safety basis organization.
Stringent qualification
requirements for “experts” are key to
implementation.
Only the most experienced and
trained personnel in the facility, its
processes, and Safety Basis should
qualify to sign as expert preparer.
Figure 1 is an
example of how an Expert USQD could be
included in the USQ Process.
Example Expert USQD Worksheets
can be found in appendix 4.
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