ESH100.3.3

Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.3.3

Procedure Title

Implement Conduct of Operations

Procedure Manager

COFFING, STEPHEN A.

Status

Active

Subject Matter Expert

Timothy Scott Stirrup (Tim)

Applicability, Exceptions, and Consequences

This Conduct of Operations Procedure applies to all Members of the Workforce who are associated with the line organizations operating nuclear facilities, accelerator facilities, and moderate/high hazard industrial facilities, or line organizations operating other facilities required by Sandia management to comply with ConOps.

Per DOE O 422.1, all Hazard Category 1, 2, and 3 nuclear facilities (as determined by DOE STD 1027) are subject to the ConOps requirements. Each Hazard Category 1, 2, and 3 nuclear facility must develop and implement a conduct of operations program addressing the ConOps specific requirements and detailed attributes of the Detailed Conduct of Operations Matrix in DOE O 422.1 Appendix A.

In addition, NNSA/SSO requires that moderate hazard industrial facilities, high hazard industrial facilities, and accelerator facilities comply with DOE O 422.1. Each high/moderate hazard industrial facility, including accelerator facilities subject to the requirements of DOE O 420.2B Accelerator Safety, must develop and implement a conduct of operations program addressing the ConOps specific requirements of the Detailed Conduct of Operations Matrix in DOE O 422.1 Appendix A.

ConOps for Sandia low hazard and below (e.g., Standard Industrial Hazard, and facilities classified as Office activity) are addressed through the Integrated Safety Management and Work Planning & Control processes and are not addressed herein.

Exceptions to, or deviations from, this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policies, Processes, and Procedures. See CG100.1.7, Request an Exception to a Policy, Process, or Procedure for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This Conduct of Operations procedure establishes the Sandia Conduct of Operations Program, which details how line managers of applicable operational facilities establish, maintain, and document compliance with the requirements of the DOE Order 422.1, Conduct of Operations. The purpose of the ConOps Order is to ensure that management systems are designed to anticipate and mitigate the consequences of human fallibility or potential latent conditions and to provide a vital barrier to prevent injury, environmental insult or asset damage, and to promote mission success.

A ConOps program consists of formal documentation, practices, and actions implementing disciplined and structured operations that support mission success and promote worker, public, and environmental protection. The goal of a conduct of operations program is to minimize the likelihood and consequences of human fallibility or technical and organizational system failures. A ConOps program may be implemented by facilities through facility policies, directives, plans, and safety management systems and need not be a stand-alone program. The term “operations” encompasses the work activities of any facility or organization, from building infrastructure, to print shops and computer centers, to scientific research, and to nuclear facilities.

Implementation of a ConOps program is demonstrated by an approved Sandia Conduct of Operations Matrix which is based on the Detailed Conduct of Operations Matrix in DOE O 422.1, Appendix A. The Sandia ConOps Matrix has entries for each ConOps specific requirement and, in addition for nuclear facilities each detailed attribute. The ConOps matrix must be completed with either a citation of the specific documentation (e.g., procedure, manual) that implements the item, or a justification for each item that is not implemented. Facilities should use the DOE Guides to Good Practices as a reference in the development of the ConOps program.

The Sandia Site Office is the approval authority for the nuclear facility ConOps matrices. The ConOps Corporate Procedure Manager is the approval authority for the non-nuclear facility ConOps matrices.

The ConOps matrices are reviewed on an annual basis to determine whether an update to the approved ConOps matrix is necessary. The purpose of the annual review of the ConOps matrix is to ensure that the referenced documents listed in the matrix remain valid and active. The annual review is documented by submittal of a memo/email to the ConOps SME identifying if an update to the ConOps matrix is or is not necessary. The line organization may also review the ConOps matrix when any substantial changes take place in facility, operations or hazards. In addition, if there are changes to the facility SB documents the ConOps matrix shall be reviewed.

Procedure Requirements

Conduct of Operations Program Management

Step	Responsible Individual	Required Action
1	Conduct of Operations (ConOps) Corporate Procedure Manager	Develop, maintain, and ensure ConOps procedure adequately covers applicable internal/external directives, laws, regulations, contractual obligations, and risk management objectives for internal compliance.
2	ConOps Corporate Procedure Manager	Obtain and address line input into the development of ConOps procedure through effective communication.
3	ConOps Corporate Procedure Manager	Provide qualification requirements for and assign the Corporate ConOps Subject Matter Expert(s).
4	Corporate ConOps SME	Assist the Department Managers, or their delegates, in understanding, implementing, training and developing facility/activity ConOps matrices (at a minimum) that document how the facility/activity meets the requirements of the ConOps order and, for more complex facilities/activities, ConOps programs or manuals, based on a graded approach.
5	Department Manager or Delegate	Review, implement, and train operations Members of the Workforce and maintain the ConOps requirements and attributes applicable to their operations based on the approved facility-specific ConOps matrix.
6	Department Manager or Delegate	For nuclear, high hazard, moderate hazard, or accelerator facilities, document facility/activity operations using facility-level ConOps matrices (at a minimum).
7	Department Manager or delegate	May develop ConOps programs, manuals, plans, and/or procedures commensurate with the complexity of facility/activity operations.
8	Corporate ConOps SME	Conduct ConOps training programs for Members of the Workforce
9	Department Managers	Provide management assurance information to your Division VP related to ConOps using procedures within the CG100.6, Assure, Assess and Improve process.
10	Corporate ConOps SME	Provide Policy/Topic Area management assurance information related to ConOps using procedures within the CG100.6, Assure, Assess and Improve process.
12	Department Manager	Continually improve the ConOps within your assigned facilities / activities using the CG100.6.6, Perform Corrective Action or CG100.6.10, Take Preventive Action procedures.
13	Corporate ConOps SME	Continually improve the ConOps Procedure, supporting manuals, and standard ConOps matrices using the CG100.6.6, Perform Corrective Action or CG100.6.10, Take Preventive Action procedures.
14	Corporate ConOps SME	Consolidate and maintain Policy/Topic Area objective evidence, guidance, tools, and ensure ConOps objectives are maintained.

Develop Initial DOE O 422.1 Conduct of Operations Matrix—Nuclear Facilities

Step	Responsible Individual	Required Action
1	Department Manager or Delegate	Department Managers of DOE STD 1027 Hazard Category 1, 2, or 3 Nuclear Facilities must complete a facility-specific Draft ConOps Matrix using the Sandia ConOps Matrix template following the instructions for nuclear facilities. The ConOps matrix must address both specific requirements and attributes to document: Whether a specific requirement or attribute applies. Deviations and exceptions identified and justified. The implementing facility policy, procedure or practice.
2	Department Manager or Delegate	Submit the facility-specific Draft ConOps Matrix to the Corporate ConOPs SME.
3	Corporate ConOps SME	Review and comment on the submitted facility-specific Draft ConOps Matrix to provide feedback on consistency and completeness to the line organization.
4	Department Manager or Delegate	Resolve review comments.
5	Department Manager or Delegate	Submit facility-specific Draft ConOps Matrix to the SSO Conduct of Operations Program Lead for review and comment; expect 1 to 2 week review period.
6	Department Manager or Delegate	Resolve, facility-specific Draft ConOps Matrix comments from SSO Conduct of Operations Lead.
7	Department Manager or Delegate	Approve by signature the facility-specific Final ConOps Matrix.
8	Senior Manager	Approve by signature the facility-specific Final ConOps Matrix.
9	Senior Manager	Submit Sandia approved, facility-specific Final ConOps Matrix to SSO ConOps Program Lead using organization’s submittal/transmittal process.
10	Department Manager or Delegate	Review, implement, and train Members of the Workforce and maintain the ConOps elements applicable to their operations based on the approved, facility-specific ConOps matrix.

Develop Initial DOE O 422.1 Conduct of Operations Matrix—Nonnuclear Facilities

Step	Responsible Individual	Required Action
1	Department Manager or Delegate	Department Managers of High-Hazard, Moderate-Hazard, or DOE O 420.2B Accelerator Facilities as well as line organizations operating other facilities required by Sandia management to comply with ConOps must complete a facility-specific Draft ConOps Matrix using the Sandia ConOps Matrix template following the instructions for non-nuclear facilities on pg xx of the Sandia ConOps Matrix template. The ConOps matrix must address specific requirements to document: Whether a specific requirement applies. Deviations and exceptions identified and justified. The implementing facility policy, procedure or practice.
2	Department Manager or Delegate	Submit the facility-specific Draft ConOps Matrix to the Corporate ConOPs SME.
3	Corporate ConOps SME	Review and comment on the submitted facility-specific Draft ConOps Matrix to provide feedback on consistency and completeness to the line organization.
4	Department Manager or Delegate	Resolve review comments.
5	Department Manager or Delegate	Submit facility-specific Draft ConOps Matrix to the Corporate ConOps SME.
6	Corporate ConOps SME	Submit facility-specific Draft ConOps Matrix to the SSO Conduct of Operations Program for review and comment; expect 1 to 2 week review period.
7	Department Manager or Delegate	Resolve facility-specific Draft ConOps Matrix comments from SSO Conduct of Operations Lead.
8	Department Manager or Delegate	Approve by signature the facility-specific Final ConOps Matrix.
9	Department Manager or Delegate	Submit approved, facility-specific Final ConOps Matrix to ConOps Corporate Procedure Manager.
10	ConOps Corporate Procedure Manager	Approve by signature the facility-specific Final ConOps Matrix.
12	ConOps Corporate Procedure Manager	Submit facility-specific Final ConOps Matrix to SSO Conduct of Operations Lead, SSO FR, and Department Manager.
13	Department Manager or Delegate	Review, implement, and train operations Members of the Workforce and maintain the ConOps elements applicable to their operations based on the approved, facility-specific ConOps matrix.

Maintain Conduct of Operations Matrix

Step	Responsible Individual	Required Action
1	Department Manager or Delegate	Maintain the facility-specific ConOps matrix and corresponding documentation identified in the approved, facility-specific ConOps matrix.
2	Department Manager or Delegate	Perform an annual review of the approved, facility-specific ConOps matrix to ensure that referenced documentation is valid and active.
3	Department Manager or Delegate	After the annual review, submit a memorandum (e.g., memo, email) to the ConOps SME that states whether changes are required to the approved, facility-specific ConOps matrix. If no changes are required, the memorandum should state that no changes are required and no further steps actions are necessary. If changes are required, the memorandum should delineate a brief scope of the changes and a corresponding schedule for re-submittal and approval of the facility-specific ConOps Matrix.
4	Department Manager or Delegate	Update the facility-specific ConOps matrix based on the outcome of the annual review. Changes in Facility Operations that require notification of SSO are as follows: Minor change—Change that can be managed by the organization management system with notification to the ConOps SME and SSO to primarily to inform them of the change. Medium change—Change that can be managed by the organization management system with review by the ConOps and SSO because the change the oversight of the implementation. Major change—Change so significant that the matrix will need to be reapproved.
5a	Department Manager or Delegate	For Nuclear Facilities, follow the submittal, review, and approval process as provided in Develop Initial DOE O 422.1, Conduct of Operations Matrix—Nuclear Facilities.
5b	Department Manager or Delegate	For High-Hazard, Moderate-Hazard, or DOE O 420.2B Accelerator Facilities as well as line organizations operating other facilities required by Sandia management to comply with ConOps, follow the submittal, review, and approval process as provided in Develop Initial DOE O 422.1, Conduct of Operations Matrix – NonNuclear Facilities.
6	Department Manager or Delegate	A 3-year review of the approved ConOps matrices is required by DOE O 422.1. If after the review, no changes are required to the documentation demonstrating conformance to the requirements, a memorandum to that effect must be submitted to the ConOps SME. If a review of the updated matrix is warranted, a memorandum to that effect must submitted to the ConOps SME as well as update of the matrix following the submittal, review, and approval process.
7	Corporate ConOps SME	Coordinate submittal of 3-year review memorandum with ConOps Corporate Procedure Manager.
8	ConOps Corporate Procedure Manager	Submit 3-year review memorandum to SSO.

Performance Assessments

Step	Responsible Individual	Required Action
1	Department Manager or Delegate	Establish a schedule for performance assessments to ensure that compliance with the ConOps specific requirements are assessed at least once every three years.
2	Department Manager or Delegate	Coordinate with the applicable SSO FR for completion of performance assessments.
3	Department Manager or Delegate	Forward the results of ConOps self assessments to the Corporate ConOps SME.
4	Corporate ConOps SME	Establish a schedule for performance assessments to ensure that each facility having a ConOps matrix is reviewed at least once every three years.
5	Corporate ConOps SME	Coordinate with applicable Department Manager for completion of performance assessments.
6	Corporate ConOps SME	Coordinate with the SSO ConOps Lead for completion of performance assessments.
7	Corporate ConOps SME	Consolidate and maintain documentation of performance assessments for the ConOps Program.
8	Department Manager or Delegate	If a change to the approved, facility-specific ConOps matrix is required as a result of a performance assessment, include these changes in the annual update process in *Maintain Conduct of Operations Matrix*.

Implementing Tools

SNL Conduct of Operations Matrix

Required Records and Retention Schedule

Annual ConOps Matrix Review Memoranda
Accelerator Facility Facility-Specific ConOps Matrices
Moderate/High Hazard Facility-Specific ConOps Matrices
Nuclear Facility-Specific ConOps Matrices
Performance Assessment Documentation
3-year review memorandum

Requirement Drivers (Prime Contract Baseline Directives)

DOE O 226.1A DOE O 414.1D

Additional Drivers

P. Wagner Letter to M. Hazen dated December 23, 2001; Subject: Approval of Sandia National Laboratories’ (SNL) High-Level Plan for Implementation of Department of Energy Order (DOE O) 422.1, Conduct of Operations for Nuclear Facilities
Conduct of Operations (ConOps) Project Plan for Implementation of DOE Order 422.1, Conduct of Operations; Sandia National Laboratories, Rev. 0, January 2011
10 CFR 830, Nuclear Safety Management
DOE M 450.4-1, Integrated Safety Management System Manual
DOE-STD-1030-96, Guide to Good Practices for Lockouts and Tagouts.
DOE-STD-1031-92 (CH-1), Guide to Good Practices for Communications.
DOE-STD-1032-92 (CH-1), Guide to Good Practices for Operations Organization and Administration.
DOE-STD-1033-92 (CH-1), Guide to Good Practices for Operations and Administration Updates Through Required Reading.
DOE-STD-1034-93 (CH-1), Guide to Good Practices for Timely Orders to Operators.
DOE-STD-1035-93 (CH-1), Guide to Good Practices for Logkeeping.
DOE-STD-1036-93 (CH-1), Guide to Good Practices for Independent Verification.
DOE-STD-1037-93 (CH-1), Guide to Good Practices for Operations Aspects of Unique Processes.
DOE-STD-1038-93 (CH-1), Guide to Good Practices for Operations Turnover.
DOE-STD-1039-93 (CH-1), Guide to Good Practices for Control of Equipment and System Status.
DOE-STD-1040-93 (CH-1), Guide to Good Practices for Control of On-Shift Training.
DOE-STD-1041-93 (CH-1), Guide to Good Practices for Shift Routines and Operating Practices.
DOE-STD-1042-93 (CH-1), Guide to Good Practices for Control Area Activities.
DOE-STD-1043-93 (CH-1), Guide to Good Practices for Operator Aid Postings.
DOE-STD-1044-93 (CH-1), Guide to Good Practices for Equipment and Piping Labeling.
DOE-STD-1045-93 (CH-1), Guide to Good Practices for Notifications and Investigation of Abnormal Events.
DOE ConOps Guides to Good Practices

Authorities and Accountabilities

The authorities and accountabilities identified below are based on DOE O 422.1 specific requirements, ILMS Corporate Structure requirements for Procedure Manager (PM), and ILMS Corporate Structure requirements for Subject Matter Expert (SME).

Corporate Procedure Manager

The Sandia Safety Basis Department (SBD) Manager serves as the Sandia Conduct of Operations Procedure Manager (ConOps Corporate Procedure Manager) and shall:

Develop, maintain, and ensure ConOps procedure adequately covers applicable internal/external directives, laws, regulations, contractual obligations, and risk management objectives for internal compliance.
Obtain and address line input into the development of ConOps procedure through effective communication.
Provide qualification requirements for and assign the Corporate ConOps Subject Matter Expert(s).
Support the development, review, approval/concurrence, and maintenance of the line organizations’ ConOps matrices through the review and approval of the industrial facilities ConOps matrices
Support the development, review, approval/concurrence, and maintenance of the line organizations’ ConOps matrices through the review of the nuclear facility ConOps matrices.
Review and approve line organization requests for deviation from the Sandia ConOps matrix template.

Line Organization Managers

Sandia Line Organization Managers required to develop a Sandia Conduct of Operations Matrix shall:

Develop and maintain a ConOps program compliant with DOE O 422.1, Conduct of Operations based up on the applicability of the ConOps requirements and attributes to their facility and/or operations.
Complete, review/approve, and maintain the Sandia ConOps matrix to document the applicability of the ConOps requirements and attributes to their applicable facility and/or operations including submittal of the ConOps matrix to the Safety Basis Department for review..
Review the ConOps matrix for their organization on an annual basis to determine whether an update to the approved ConOps matrix is necessary including submittal of a memo at least annually to the ConOps SME identifying if an update to the ConOps matrix is necessary.

Line Organization Senior Manager

Sandia Line Organization Senior Managers of nuclear facility operations required to develop a Sandia Conduct of Operations Matrix shall:

Review and approve their operations’ Sandia ConOps matrix.
Submit their operations’ approved ConOps matrix to SSO approval authority follow the organizations transmittal requirements.

Corporate ConOps Subject Matter Expert

The Corporate ConOps SME assists the ConOps Corporate Procedure Manager in administering the ConOps Program. The Corporate ConOps SME:

Assist the line with understanding, implementing, training, and developing facility/activity ConOps matrices that document how the facility/activity meets the requirements of the ConOps order and, for more complex facilities/activities, ConOps programs or manuals, based on a graded approach.
Coordinate submission of the ConOps matrices to the ConOps Corporate Procedure Manager for review and approval/concurrence and coordinate submission to the NNSA/SSO for review and approval/concurrence.
Provide direct support to the ConOps Corporate Procedure Manager in developing and maintaining ConOps-related policies, processes, and procedures.

Corporate ConOps Program Analysts

Corporate ConOps Program Analysts are required to:

Assist the line organizations with the development, review, and approval/concurrence of the ConOps matrix as an integral team member, including providing guidance to line organizations to ensure consistent application and implementation of the ConOps elements.

Line Organization ConOps Personnel

Line Organization ConOps Personnel are required to:

Develop and maintain ConOps matrix in coordination with the Corporate ConOps SME and Corporate ConOps Program Analysts.

Training Requirements

Minimum training for the Corporate ConOps SME is SAF-261, Conduct of Operations provided by the DOE NTC.
Minimum training for Members of the Workforce developing a ConOps matrix is a facility-specific ConOps 1 hour training provided by the Corporate ConOps SME and/or ConOps Corporate Procedure Manager.
Recommended training for Members of the Workforce performing ConOps program requirements including the development of a ConOps matrix is the Sandia Conduct of Operations training (currently under development) and/or facility-specific ConOps training.
Recommended reading for a Members of the Workforce performing ConOps program requirements, including the development of a ConOps matrix, is DOE O 422.1, Conduct of Operations and the ConOps guides.

Affiliated Metrics

Annual review of each facility ConOps matrix
Three-year assessment cycle of each of the 18 ConOps requirements

Related Processes and Procedures

Numerous corporate process and procedures encompass Sandia’s Conduct of Operation Program based on the type and complexity of work being conducted.

Processes

- ESH100.1, Plan Work
- ESH100.2, Analyze and Control Hazards
- ESH100.3, Perform Work
- ESH100.4, Feedback and Improve

Required Reviews

Review Completion Dates
In Process

Change Summary

Date	Summary
03/12/2012	*Administrative* Modified Changed DOE O 414.1C reference to DOE O 414.1D. (Requirement Drivers) Replaced SAPLE link for subject matter expert with direct link to e-mail for improved usability.
07/13/2011	*Administrative* *Deleted* Removed dates in Requirements & Instructions (June 14, 2011 and August 4, 2011).
07/07/2011	*Administrative* Added The Requirements & Instructions table "Performance Assessments" that was part of the substantive change made on 07/05/2011. Modified Changed the style of a table heading for display purposes.
07/06/2011	*Administrative* Added Added a missing paragraph in the Applicability, Exceptions & Consequences.
07/05/2011	Substantive Added Requirements and Instructions for the ConOps Corporate Procedure Manager. Requirements and Instructions for Nuclear Facilities (i.e., develop initial 422.1 Conduct of Operations Matrix). Requirements and Instructions for Non-Nuclear Facilities (i.e., develop initial 422.1 Conduct of Operations Matrix). Requirements and Instructions for maintaining Conduct of Operations matrices. Requirements and Instructions for Performance Assessments. Training requirements for the Corporate ConOps SME and Members of the Workforce who develop ConOps matrices. Deleted Deleted the following Requirements & Instructions: Coordinate submission of individual facility/activity ConOps matrices to the Sandia Site Office (ConOps SME). Implement Work Controls per CPR001.3.14 in satisfaction of ConOps requirements (Department Manager, or delegate, of Low Hazard Operations). Compliance with the Work Planning and Control procedure meets the expectation of ConOps for Low Hazard operations (Department Manager, or delegate, of Low Hazard Operations). Review, implement, and train operations Members of the Workforce to the Sandia Standard Matrix, which is applicable to their operation: Standard Business Occupancy or Standard Industrial Hazard (Department manager, or delegate, of work in Office Environments or Standard Industrial Hazard operations). Coordinate submission of standard ConOps matrices to the Manger of the Management System Improvement Department for review and approval (ConOps SME). Once ConOps matrices, program or manuals are approved, train Members of the Workforce about the provisions of the matrix (Department Manager or delegate). Maintain objective evidence of matrix approval using WFS and ILMS on your Division ILMS page(Department Manager or delegate). Once standard ConOps matrices, program or manuals are approved; the ConOps SME shall maintain objective evidence using WFS and ILMS – under the Corporate Governance Policy Area (ConOps SME). *Administrative* Added Recommended training and reading for Members of the Workforce who perform ConOps program requirements. Annual ConOps Matrix review memoranda; Accelerator Facility-Specific ConOps matrices; Nuclear Facility-Specific ConOps matrices; Performance Assessment documentation; and the 3-Year Review Memorandum to Records Retention & Disposition Schedule. Modified Modified Overview to include the implementation of a ConOps Program information (i.e., how implementation is demonstrated and that SSO is the approval authority). Replaced references to CPRs in Related Corporate Processes & Procedures with current Corporate Policy System references.
02/24/2011	*Substantive* NEW This new ES&H procedure was relocated from Corporate Governance, CG100.5.4, Implement Conduct of Operations.