Presented by: Bill Possidente, MS, CEM Emergency Planning Preparedness Department National Security Technologies, LLC

1. Presented by: Bill Possidente, MS, CEM Emergency Planning & Preparedness Department National Security Technologies, LLC Greetings, my name is Bill Possidente and I serve as the Emergency Management (EM) Coordinator for the Elevated Risk Facilities (ERFs) at the Nevada Test Site (NTS). I am employed by National Security Technologies (NSTec) and have worked on the NTS underground test programs. I have over 18 years experience the areas of operations, training, emergency management, procedures, assessments, and safety basis reviews and implementation. I hold an MS in Emergency Management, am a Certified Emergency Manager, and am a member of the International Association of Emergency Managers. I will be discussing the Elevated Risk Program that the NTS has developed to address hazards in those faculties that fall in the “grey zone” between general and high hazard facilities.Greetings, my name is Bill Possidente and I serve as the Emergency Management (EM) Coordinator for the Elevated Risk Facilities (ERFs) at the Nevada Test Site (NTS). I am employed by National Security Technologies (NSTec) and have worked on the NTS underground test programs. I have over 18 years experience the areas of operations, training, emergency management, procedures, assessments, and safety basis reviews and implementation. I hold an MS in Emergency Management, am a Certified Emergency Manager, and am a member of the International Association of Emergency Managers. I will be discussing the Elevated Risk Program that the NTS has developed to address hazards in those faculties that fall in the “grey zone” between general and high hazard facilities.

2. Introduction ERFs pose a higher risk than General Facilities but routinely fall below the risk thresholds associated with High Hazard Facilities (EPHA facilities). That is, we identified that ERFs have a higher degree of risk than the cafeteria for example, but less than those risks identified in High Hazard Facilities. The Elevated Risk Facilities (ERFs) Operational Base Program provides the technical basis for planning and response measures for hazards at ERFs. The program is tailored to be specific (i.e., technically appropriate) to the hazard and commensurate with (in size, scope, or scale) the magnitude of the hazard and its potential impacts. ERFs pose a higher risk than General Facilities but routinely fall below the risk thresholds associated with High Hazard Facilities (EPHA facilities). That is, we identified that ERFs have a higher degree of risk than the cafeteria for example, but less than those risks identified in High Hazard Facilities. The Elevated Risk Facilities (ERFs) Operational Base Program provides the technical basis for planning and response measures for hazards at ERFs. The program is tailored to be specific (i.e., technically appropriate) to the hazard and commensurate with (in size, scope, or scale) the magnitude of the hazard and its potential impacts.

3. Purpose The purpose of the ERF Program is to achieve effective integration of emergency planning and preparedness into existing emergency management programs to provide capabilities for all-hazards emergency response, through communication, coordination, and the efficient and effective use of resources. ERFs may present chemical, radiological, and/or explosive hazards based on their quantity and characteristics. Hazardous materials at ERFs are qualitatively analyzed and estimates of consequences are based on judgment rather than calculated exposures. The intent is to conduct due diligence of potential hazards at ERFs.The purpose of the ERF Program is to achieve effective integration of emergency planning and preparedness into existing emergency management programs to provide capabilities for all-hazards emergency response, through communication, coordination, and the efficient and effective use of resources. ERFs may present chemical, radiological, and/or explosive hazards based on their quantity and characteristics. Hazardous materials at ERFs are qualitatively analyzed and estimates of consequences are based on judgment rather than calculated exposures. The intent is to conduct due diligence of potential hazards at ERFs.

4. Drivers The ERF program has the same drivers of general and high hazard facilities. The diagram indicate that ERFs fill the gap between the two endpoints. ERFs require a more robust degree of personnel qualification and training than general facilities. The ERF Operational Base Program is built upon three guiding emergency management concepts: 1) Effective response is the “last line of defense” against adverse consequences. 2) Planning, preparedness, response, recovery, and mitigation must be specific to and “commensurate with the hazards.” 3) “Early recognition” is vital to timely, effective, and commensurate response.   The goal is to achieve effective integration of emergency planning and preparedness requirements into an emergency management program that provides capabilities for all-hazards emergency response, through communication, coordination, and an efficient and effective use of resources. Through the conduct of EPHSs, NSTec has identified three tiers of facilities/activities that require an emergency management base program implementation policy. These tiers are listed from lowest to highest potential hazard: General Facilities (administrative, engineering) Elevated Risk Facilities (hazardous materials < threshold criteria) High Hazard Facilities (hazardous materials > threshold criteria) The ERF program has the same drivers of general and high hazard facilities. The diagram indicate that ERFs fill the gap between the two endpoints. ERFs require a more robust degree of personnel qualification and training than general facilities. The ERF Operational Base Program is built upon three guiding emergency management concepts: 1) Effective response is the “last line of defense” against adverse consequences. 2) Planning, preparedness, response, recovery, and mitigation must be specific to and “commensurate with the hazards.” 3) “Early recognition” is vital to timely, effective, and commensurate response.   The goal is to achieve effective integration of emergency planning and preparedness requirements into an emergency management program that provides capabilities for all-hazards emergency response, through communication, coordination, and an efficient and effective use of resources. Through the conduct of EPHSs, NSTec has identified three tiers of facilities/activities that require an emergency management base program implementation policy. These tiers are listed from lowest to highest potential hazard: General Facilities (administrative, engineering) Elevated Risk Facilities (hazardous materials < threshold criteria) High Hazard Facilities (hazardous materials > threshold criteria)

5. Process Graded Approach The ERF evaluation process will be based on the level of analysis, documentation, and actions necessary to comply with programmatic requirements that are commensurate with the relative importance to safety, safeguards, and security the magnitude of any hazard involved the life cycle stage of a facility the programmatic mission of a facility the particular characteristics of a facility any other relevant factor A graded approach is used to make the ERF identification cost effective. Only those facilities that do not screen out of the ERF identification process will be looked at in greater detail.A graded approach is used to make the ERF identification cost effective. Only those facilities that do not screen out of the ERF identification process will be looked at in greater detail.

6. Currently Identified ERFs BEEF Baker Site RNCTEC Potential Future ERFs U12g Tunnel Warehouse 160 Los Alamos Technical Facility (TaDD [Tactical Demilitarization Development]) Process By reassessing facilities such as U12g and Warehouse 160, it may be possible to “downgrade” them to ERF from their current High Hazard Facility status. By addressing current operational conditions and hazardous material inventory, it may be possible, by using the graded approach, to turn the mentioned facilities from high hazard to an ERF. This would result in significant cost savings needed from current programmatic upkeep.By reassessing facilities such as U12g and Warehouse 160, it may be possible to “downgrade” them to ERF from their current High Hazard Facility status. By addressing current operational conditions and hazardous material inventory, it may be possible, by using the graded approach, to turn the mentioned facilities from high hazard to an ERF. This would result in significant cost savings needed from current programmatic upkeep.

7. Process Requirements Walk-Through Hazard Assessment Checklist Hazard Analysis Scenarios (consequences as a function of risk vs. probability) Emergency Plan Implementing Procedure (EPIP) vs. Emergency Response Procedure (ERP) Formal LED Qualification Program Formal Drills with AAR ERFs require a higher degree of due diligence. As such, ERFs have the mentioned additional formal processes that general facilities do not. ERF facility personnel are required to understand how the Emergency Response Organization operates and their interface with response assets. ERFs are required to conduct one evacuation drill and one shelter-in-place drill annually. The drills can be conducted on the same day or on separate days at the discretion of the Facility Manger with concurrence from the assigned EM Coordinator.   Formal drills will be conducted for ERFs. Formal drills require the development of a Drill Plan and also require a Drill Planning Team with appropriate stakeholder involvement. The facility’s Emergency Management Coordinator will facilitate scheduling, drill conduct, and obtain a drill number. Formal Drills will be conducted and documented as defined in the NSTec Drill and Exercise Manual.   An actual event can substitute for a drill if the facility implemented protective actions (shelter or evacuate). To receive credit, the facility’s EM Coordinator will complete and submit an After Action Review (AAR). An AAR identifies the status of each drill objective and identifies strengths, weaknesses, and opportunities for improvement. Corrective actions are tracked to resolution. ERFs require a higher degree of due diligence. As such, ERFs have the mentioned additional formal processes that general facilities do not. ERF facility personnel are required to understand how the Emergency Response Organization operates and their interface with response assets. ERFs are required to conduct one evacuation drill and one shelter-in-place drill annually. The drills can be conducted on the same day or on separate days at the discretion of the Facility Manger with concurrence from the assigned EM Coordinator.   Formal drills will be conducted for ERFs. Formal drills require the development of a Drill Plan and also require a Drill Planning Team with appropriate stakeholder involvement. The facility’s Emergency Management Coordinator will facilitate scheduling, drill conduct, and obtain a drill number. Formal Drills will be conducted and documented as defined in the NSTec Drill and Exercise Manual.   An actual event can substitute for a drill if the facility implemented protective actions (shelter or evacuate). To receive credit, the facility’s EM Coordinator will complete and submit an After Action Review (AAR). An AAR identifies the status of each drill objective and identifies strengths, weaknesses, and opportunities for improvement. Corrective actions are tracked to resolution.

8. Process The facility’s EPHS serves as the technical basis document for determining if a more in-depth analysis of the facility’s hazards is warranted (EPHA). Hazardous materials at ERFs do not exceed screening criteria but could produce operational emergencies not requiring classification during uncontrolled release events. Therefore, it is prudent to evaluate the hazards at ERFs in greater detail. The management objective is to identify and analyze hazards and to systematically evaluate potential impacts. Although this method is predominately qualitative, it provides a relatively thorough evaluation of the spectrum of risks to workers, the public, and the environment. Estimates of consequences are based on professional judgment rather than calculated exposures and the use of Hazards Analysis Scenarios.   The following process is used to evaluate potential adverse events at ERFs. By definition, risk is the product of consequence and frequency of occurrence. If only consequences are considered, then the risk can not be adequately determined. Probability demonstrates that postulating an accident does not make it credible or likely: rather, it shows the range between frequent events of low consequence and rare events of high consequence. As such, the intent is to identify and evaluate processes and activities that could lead to potential accidents involving hazardous materials based on conditions identified in the facility’s EPHS and through facility walk-throughs.   For each ERF, a qualitative risk analysis is conducted based on the assumptions of risk consequence, the probability of occurrence, and by addressing the following questions (Q1 through Q5). If the answer to a given question is “yes,” then no further analysis is considered.   Is the hazard considered a Standard Industrial Hazard? Does the scenario result in Facility Physical Damage Only? Does the scenario result in Negligible Consequences? Is the scenario Physically Impossible? Is the hazard addressed in other Programs or Analyses?The facility’s EPHS serves as the technical basis document for determining if a more in-depth analysis of the facility’s hazards is warranted (EPHA). Hazardous materials at ERFs do not exceed screening criteria but could produce operational emergencies not requiring classification during uncontrolled release events. Therefore, it is prudent to evaluate the hazards at ERFs in greater detail. The management objective is to identify and analyze hazards and to systematically evaluate potential impacts. Although this method is predominately qualitative, it provides a relatively thorough evaluation of the spectrum of risks to workers, the public, and the environment. Estimates of consequences are based on professional judgment rather than calculated exposures and the use of Hazards Analysis Scenarios.   The following process is used to evaluate potential adverse events at ERFs. By definition, risk is the product of consequence and frequency of occurrence. If only consequences are considered, then the risk can not be adequately determined. Probability demonstrates that postulating an accident does not make it credible or likely: rather, it shows the range between frequent events of low consequence and rare events of high consequence. As such, the intent is to identify and evaluate processes and activities that could lead to potential accidents involving hazardous materials based on conditions identified in the facility’s EPHS and through facility walk-throughs.   For each ERF, a qualitative risk analysis is conducted based on the assumptions of risk consequence, the probability of occurrence, and by addressing the following questions (Q1 through Q5). If the answer to a given question is “yes,” then no further analysis is considered.   Is the hazard considered a Standard Industrial Hazard? Does the scenario result in Facility Physical Damage Only? Does the scenario result in Negligible Consequences? Is the scenario Physically Impossible? Is the hazard addressed in other Programs or Analyses?

9. Process If however, the answer to a question is “No,” then an estimate of the Uncontrolled Frequency of Occurrence for that question is assigned a corresponding Frequency ID and point value from the table. The graded approach is used to determine the depth of analysis, the extent of analysis documentation, and the actions necessary to provide safety commensurate with the hazard(s).   This table, Uncontrolled Frequency of Occurrence, defines the frequencies for the likelihood of events. Anticipated events (IV) are unplanned events that are expected to occur at least once during the life of the facility and occur within 100 years. Unlikely events (III) are events not expected to occur during the lifetime of the facility, and occur between 100 and 10,000 years. Extremely Unlikely events (II) will probably not occur during the lifetime of the facility and occur between 10,000 and 1,000,000 years. Beyond Extremely Unlikely (I) events are not expected to occur within 1,000,000 years. If however, the answer to a question is “No,” then an estimate of the Uncontrolled Frequency of Occurrence for that question is assigned a corresponding Frequency ID and point value from the table. The graded approach is used to determine the depth of analysis, the extent of analysis documentation, and the actions necessary to provide safety commensurate with the hazard(s).   This table, Uncontrolled Frequency of Occurrence, defines the frequencies for the likelihood of events. Anticipated events (IV) are unplanned events that are expected to occur at least once during the life of the facility and occur within 100 years. Unlikely events (III) are events not expected to occur during the lifetime of the facility, and occur between 100 and 10,000 years. Extremely Unlikely events (II) will probably not occur during the lifetime of the facility and occur between 10,000 and 1,000,000 years. Beyond Extremely Unlikely (I) events are not expected to occur within 1,000,000 years.

10. Process This table, Consequence Indicators, provides indicators on which to base the level of consequence relative to the anticipated release frequency.   The mean (average) for all hazard initiator values is calculated for a given facility hazard. If the calculated mean falls in between two whole numerical point vales, then the number will be rounded up. For example: If the calculated mean is 2.2, then this figure is rounded up to “3,” which corresponds to an Moderate consequence level with a Frequency ID of “Unlikely” (III). Numbers of less than 2.0 will be rounded down to the next lowest whole number.   Note: “0” values are not included in determining the mean predicted frequency. This table, Consequence Indicators, provides indicators on which to base the level of consequence relative to the anticipated release frequency.   The mean (average) for all hazard initiator values is calculated for a given facility hazard. If the calculated mean falls in between two whole numerical point vales, then the number will be rounded up. For example: If the calculated mean is 2.2, then this figure is rounded up to “3,” which corresponds to an Moderate consequence level with a Frequency ID of “Unlikely” (III). Numbers of less than 2.0 will be rounded down to the next lowest whole number.   Note: “0” values are not included in determining the mean predicted frequency.

11. Process As a point of origin, all hazard initiators identified in the Hazards Analysis Scenarios table will be initially assigned the mid-value of “2,” corresponding to an “Extremely Unlikely” (Improbable events that should not occur during the facility’s lifetime) event. This value may be increased or decreased based on a review of the facility’s technical basis documents, hazardous materials inventory, facility walk-through, and interviews with facility personnel. If the evaluation concludes that engineering and programmatic elements necessary to minimize the probability of an uncontrolled release are present, then the mid value of “2” may be adjusted downward (decreased). The opposite set of conditions is equally true to adjust frequency values upwards. That is, The mid-point value of “2” from the Frequency Categories is initially assigned to each Hazard Initiator; e.g., Structural Fire and Explosion, Natural Phenomena, Environmental Releases, Hazardous Material Releases. Subsequently, the point value for a given initiator is then tempered with identified or the lack of preventative/mitigative/programmatic controls for the facility. In this example, a release due to a malevolent act is determined to be extremely unlikely based on existing programmatic controls. Next, factors used to adjust the “Extremely Unlikely” (II) frequency category are considered. These factors include 1) existing fire mitigation equipment, 2) facility location and boundary conditions, 3) security posture, 4) inventory limitations, 5) results from the facility walk-through inspection. As such, existing engineering and programmatic controls suffice to minimize the probability of an uncontrolled release due to a malevolent act to a overall frequency category “1,” Beyond Extremely Unlikely. An in-depth review of facility documentation is required to systematically adjust frequency ratings. Conversely, a facility may demonstrate the necessary engineering and programmatic constraints to minimize the probability of an unplanned release. However, if the worst case scenario release of hazardous materials from a facility would cause activation of the emergency response organization assets, then it may be prudent to assign a higher probability category to this initiating event. In this example, the hazardous material release initiator from a structural fire/explosion was assigned a “3” frequency category (events that are not anticipated to occur during the facility’s lifetime) which is a higher probability of occurrence than the baseline “2” category. Doing so allows a higher degree of confidence that these types of events are captured and addressed in the overall perspective of potential consequences from facility hazards.As a point of origin, all hazard initiators identified in the Hazards Analysis Scenarios table will be initially assigned the mid-value of “2,” corresponding to an “Extremely Unlikely” (Improbable events that should not occur during the facility’s lifetime) event. This value may be increased or decreased based on a review of the facility’s technical basis documents, hazardous materials inventory, facility walk-through, and interviews with facility personnel. If the evaluation concludes that engineering and programmatic elements necessary to minimize the probability of an uncontrolled release are present, then the mid value of “2” may be adjusted downward (decreased). The opposite set of conditions is equally true to adjust frequency values upwards. That is, The mid-point value of “2” from the Frequency Categories is initially assigned to each Hazard Initiator; e.g., Structural Fire and Explosion, Natural Phenomena, Environmental Releases, Hazardous Material Releases. Subsequently, the point value for a given initiator is then tempered with identified or the lack of preventative/mitigative/programmatic controls for the facility. In this example, a release due to a malevolent act is determined to be extremely unlikely based on existing programmatic controls. Next, factors used to adjust the “Extremely Unlikely” (II) frequency category are considered. These factors include 1) existing fire mitigation equipment, 2) facility location and boundary conditions, 3) security posture, 4) inventory limitations, 5) results from the facility walk-through inspection. As such, existing engineering and programmatic controls suffice to minimize the probability of an uncontrolled release due to a malevolent act to a overall frequency category “1,” Beyond Extremely Unlikely. An in-depth review of facility documentation is required to systematically adjust frequency ratings. Conversely, a facility may demonstrate the necessary engineering and programmatic constraints to minimize the probability of an unplanned release. However, if the worst case scenario release of hazardous materials from a facility would cause activation of the emergency response organization assets, then it may be prudent to assign a higher probability category to this initiating event. In this example, the hazardous material release initiator from a structural fire/explosion was assigned a “3” frequency category (events that are not anticipated to occur during the facility’s lifetime) which is a higher probability of occurrence than the baseline “2” category. Doing so allows a higher degree of confidence that these types of events are captured and addressed in the overall perspective of potential consequences from facility hazards.

12. Process This process is conducted for all of the potential initiators, Structural Fire and Explosion, Natural Phenomena, Environmental Releases, etc., to derive a point value for each. Then, all the point values are summed and divided by the number of non-zero initiators to calculate the average (mean).  Sum of frequency point values for all events = ? n+n+n…  Average Predicted Frequency = (? n+n+n…) / # of non-zero entries  In this example, this equates to: 3+3+2+3+1+3+2+2+1+0= 20 then: 20/9 = 2.22, which is rounded up to “3,” or a Moderate consequence with an Unlikely frequency (III) This ranking process is carried out for all those items that had a “No” answer to the initial questions (Q1 – Q5). Q1 Is the hazard considered a Standard Industrial Hazard? Q2 Does the scenario result in Facility Physical Damage Only? Q3 Does the scenario result in Negligible Consequences? Q4 Is the scenario Physically Impossible? Q5 Is the hazard addressed in other Programs or Analyses? Finally, the numbers derived for the “Average Predicted Frequency” are subjected to the same averaging process. In this example, that is: 2.2 (for Q1) + 2.0 (for Q3) ….. = 4.2/2 This equals an average of 2.1. By program definition, any facility that exceeds the 2.0 point of origin value, will be considered an Elevated risk Facility. The results of this example indicates that the highest event probability (frequency category) for all hazardous materials of interest is Moderate, [2.2 (˜ 3.0)]. The resultant composite score of 2.1 corresponds to an unlikely event that is not anticipated to occur during the lifetime of the facility and could occur between 100 and 10,000 years. “What-if” release events are associated with a catastrophic release of the maximum inventory of hazardous materials at the facility. As such, it is determined that there are analyzed emergencies that may warrant categorization as an Operational Emergency Requiring Classification for this example. This facility would NOT require an EPHA. However, as an ERF, this facility requires the added rigor of a formalized drill program and additional LED training using a graded approach commensurate with the hazards.This process is conducted for all of the potential initiators, Structural Fire and Explosion, Natural Phenomena, Environmental Releases, etc., to derive a point value for each. Then, all the point values are summed and divided by the number of non-zero initiators to calculate the average (mean).  Sum of frequency point values for all events = ? n+n+n…  Average Predicted Frequency = (? n+n+n…) / # of non-zero entries  In this example, this equates to: 3+3+2+3+1+3+2+2+1+0= 20 then: 20/9 = 2.22, which is rounded up to “3,” or a Moderate consequence with an Unlikely frequency (III) This ranking process is carried out for all those items that had a “No” answer to the initial questions (Q1 – Q5). Q1 Is the hazard considered a Standard Industrial Hazard? Q2 Does the scenario result in Facility Physical Damage Only? Q3 Does the scenario result in Negligible Consequences? Q4 Is the scenario Physically Impossible? Q5 Is the hazard addressed in other Programs or Analyses? Finally, the numbers derived for the “Average Predicted Frequency” are subjected to the same averaging process. In this example, that is: 2.2 (for Q1) + 2.0 (for Q3) ….. = 4.2/2 This equals an average of 2.1. By program definition, any facility that exceeds the 2.0 point of origin value, will be considered an Elevated risk Facility. The results of this example indicates that the highest event probability (frequency category) for all hazardous materials of interest is Moderate, [2.2 (˜ 3.0)]. The resultant composite score of 2.1 corresponds to an unlikely event that is not anticipated to occur during the lifetime of the facility and could occur between 100 and 10,000 years. “What-if” release events are associated with a catastrophic release of the maximum inventory of hazardous materials at the facility. As such, it is determined that there are analyzed emergencies that may warrant categorization as an Operational Emergency Requiring Classification for this example. This facility would NOT require an EPHA. However, as an ERF, this facility requires the added rigor of a formalized drill program and additional LED training using a graded approach commensurate with the hazards.

13. Conclusion The application of this methodology is not intended to duplicate the determinations in the facility’s EPHS but to validate existing conclusions and examine potential consequences of unplanned releases of hazardous materials for all the ERFs. The application of this methodology determines the relative degree of potential hazards between ERF facilities. This methodology will also be applied for any future facilities that enter the ERF program The probability of occurrence and potential consequences from an unplanned release will be tempered by the quality and quantity of existing controls. That is, 1) engineered rather than administrative, 2) preventative rather than mitigative, and 3) passive rather than active.The application of this methodology is not intended to duplicate the determinations in the facility’s EPHS but to validate existing conclusions and examine potential consequences of unplanned releases of hazardous materials for all the ERFs. The application of this methodology determines the relative degree of potential hazards between ERF facilities. This methodology will also be applied for any future facilities that enter the ERF program The probability of occurrence and potential consequences from an unplanned release will be tempered by the quality and quantity of existing controls. That is, 1) engineered rather than administrative, 2) preventative rather than mitigative, and 3) passive rather than active.

14. Conclusion Elevated Risk Facilities (ERFs) Store and/or handle hazardous materials (explosives, radioactive materials) Can generate Operational Emergencies Require a more robust and formalized EM approach than General Facilities Program is unique in concept and structure across the DOE community Self explanatory. This is a summary of previous discussions of the ERF program.Self explanatory. This is a summary of previous discussions of the ERF program.

15. QUESTIONS?

16. Bill Possidente, MS, CEM Exercise and Facility Preparedness Program Section National Security Technologies, LLC (NSTec)Nevada Test SiteOffice: 702.295.0885Cell: 702.241.4224Pager: 702.794.6789possidw@nv.doe.gov