Changes to TSR control set due to changes in mission and lessons learned

Previous Technical Safety Requirements (TSRs) established to support plutonium production activities at the Rocky Flats Environmental Technology Site (RFETS) were heavily focused on engineered safety features that would mitigate potential accidents. With the change in mission in 1992 to Site closure, and considering antiquated equipment nearing the end of their useful life, a change in philosophy was adopted to emphasize preventive controls that are mostly administrative. The new Administrative Controls (ACs) developed in the last few years include discrete attributes of safety management programs (SMPs) that are specifically credited to prevent or mitigate an accident, and include requirements on handling individual deviations, programmatic deficiencies, and TSR AC violations. The primary benefit of these changes is fewer requirements on equipment that allow the contractor more flexibility to maintain the defense-in-depth safety systems in a more cost-effective manner. A disadvantage of these new ACs is that implementation has become cumbersome and difficult to manage, e.g., resulted in an increased burden of demonstrating compliance and required an additional infrastructure to track deviations and deficiencies. In order to improve the efficiency of the authorization basis (AB) process to support accelerated Site closure according to the 2006 Plan, the Site has recently modified the ABs to better focus on the programmatic elements that were credited in the accident analyses, and to rely on the Integrated Safety Management System to implement SMPs via one general TSR AC requirement. At the request of DOE/RFFO, a self-assessment of the Rocky Flats AB program was performed in November 1998 by Victor Stello, DOE Headquarters, along with representatives from other DOE sites and Defense Programs. Results of this self-assessment confirmed that the proposed AC changes would be beneficial and provided specific recommendations