MANAGING DD IN AN EPA-DOE REGULATED FACILITY

摘要

DOE-EPA guidance which establishes and integrates environmental, engineering, D&D activities, and establishes a safety basis for remediation work has not been delineated and promulgated. Unlike operating facilities where quantities of material are known, design tasks delineated, and safety boundaries established, implementation of current guidelines to D&D create problems in identifying all activities and vulnerabilities. Uncertainties complicate identifying, analyzing, and providing engineered safeguards and administrative controls. Execution of D&D activities require a continuing engineering design effort and constant awareness and investigation of hazardous conditions as they are found in the field. The problems can be mitigated by: planning for variability and uncertainties; establishing type and content of documentation that should be addressed and how documents will be revised; establishing an iterative process of characterization and safety analysis; basing the maintenance of the approved D&D safety basis on a USQ-like process rather than a standard "production oriented" Safety Analysis Report; identify teams to develop information needed for performance and authorization of work and insuring worker awareness of boundary conditions and conditions that could develop into an accident.