EFCOG Best Practice #43

(11/14/06)

PDF Version

Title: Avoiding Procedure and Database References in Regulator Approved/Enforced Documents Simplifies Work Transition Between Contractors and Saves Money

Facility:  Hanford Site, Fluor Hanford

Point of Contact: 

• Richard Gurske, (509) 372‑0761, Richard_H_Gurske@rl.gov

• Ron Brunke, (509) 376-2663, Ronald_C_Brunke@rl.gov

Brief Description of Best Practice: 

There are some clear advantages to not including contractor procedure and database references in regulator approved/enforced documents.  It has been a common practice to rely on contractor or Department of Energy (DOE) procedure references as a convenient way to represent to the regulatory agency how work will be performed.  Including procedure references can give the regulator confidence that work will be performed in compliance with regulatory requirements.  However, this practice also presents a potential for regulatory agency approval and enforcement of contractor procedures in the performance of work described in the approved document.  Procedures typically contain much more information than is necessary for meeting the regulatory requirements.  Including specific contractor procedures in a regulatory agency approved document also presents a challenge to DOE if there is a need to assign work governed by the approved document to another contractor.  While a revision to include the other contractor's procedures, a procedure 'crosswalk', or other fixes are possible, they take time and resources as well as approvals, to complete.

FH initially believed that replacing procedure references with brief descriptions of how the contractor would perform the work would be problematic.  The challenge was to balance the detail of the procedure/process description, not unduly increase the size of the document, and still obtain regulatory agency approval.

Three categories of solutions were used. 

1. Follow procedure drivers back to and reference a document, procedure or requirement that is already regulatory agency approved (e.g., EPA publication SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods).

2. Substitute, for example, "internal work requirements and processes", for administrative procedure references that would not be concern to regulator.

3. Substitute a brief description.  Replace text that reads:

 "Routine radiological surveys will be conducted prior to any major equipment removal activities. The routine radiological surveys will consist of routine surveys of accessible surfaces of the waste media and will be conducted by project radiological control technicians (RCTs) in accordance with HNF-5173, PHMC Radiological Control Manual."

 with text reading:

 "A substantial amount of survey information currently exists from pre-entry surveys conducted prior to the start of the project.  This information will be reviewed by the Characterization Team and used when deemed to meet the sampling and analysis plan (SAP) requirements.  Additional surveys may be required at specific locations to fill voids in the existing data identified by the Characterization Teams’ review or to address areas of concern identified during visual inspections.  Surveys will consist of direct (static) radiation measurements at regular intervals on flat surfaces.  The spacing for the measurement intervals will be 1 meter by 1 meter for areas likely to be contaminated and 2 meters by 2 meters for areas with a low contamination potential.  Suspect areas such as floor drains, process lines, sumps, or visibly stained areas will also be surveyed.  Removable contamination measurements will be performed at locations where direct measurements indicate radiological contamination.  Survey results will be recorded on radiological survey report forms and provided to the Characterization Team for evaluation."

Why the Best Practice was used: 

FH recommended and the DOE field office concurred that contractor procedure and database references should no longer be included in regulatory agency approved/enforced documents.

As work scope and facilities (buildings) were transferred to Fluor Hanford (FH) from other contractors, FH had to both rewrite contractor procedures that were cited in and obtain regulator approval of revised regulatory documents, e.g., removal action work plans (RAWPs).  Much time and effort went into this effort.

What are the benefits of the Best Practice?

Avoiding procedure and database references in regulator approved/enforced documents reduces or eliminates potential for regulatory agency approval and enforcement of contractor procedures in the performance of work described in the document.  It also avoids including procedure text that contains more information than is necessary to meet regulatory requirements of the document.  This practice enhances transfer of work supporting a regulated action from one contractor to another contractor without expending resources to revise regulatory agency approved documents.

This approach addresses the requirements for regulator approved documents while maintaining flexibility for work execution.  An action-specific implementation plan, e.g., Project Execution Plan, can then be used to directly link the regulatory approved document to implementing procedures and work instructions.

What problems/issues were associated with the Best Practice?

This approach required a paradigm shift by the regulatory agency.  Furthermore, revisions to procedures must be monitored to be consistent with the regulator‑approved document descriptions.

How the success of the Best Practice was measured:

DOE acceptance of the documents and U.S. Environmental Protection Agency (EPA) approval of the documents are evidence that this approach can be successful.  It is expected that document revision is less frequent and requirements management is maintained.

Description of process experience using the Best Practice:

At Hanford, workscope has been reassigned between contractors.  Prime contract changes are in process and for some multiple building removal actions, DOE wants more than one contractor to perform work.  The 'no procedure reference' approach in regulatory documents significantly supports these changes. 

The process used to achieve regulator approval included:

• FH informed the regulating agency that they were directed to remove procedure references

• The regulatory agency requested sufficient information in the documents to assure them that work would be conducted in accordance with applicable or relevant and appropriate requirements (ARARs).

• FH provided a presentation to the regulatory agency showing what document changes would be.

• The regulatory agency requested additional description to be included in a few instances

•  The regulatory agency stated that though they preferred procedure references, the document was acceptable.

Please check the applicable boxes below for the Topical Area(s) to which the Best Practice relates:

X   Environmental

X   Standards and Requirements

Relationship to Integrated Safety Management Core Function and Guiding Principles