Post-Restart Recommendations - Added comments in color
1. The
work authorization policies and procedures for the ITF should be documented to
clarify the roles and responsibilities of the Area Manager and the other persons
involved in the control of work activities. Specific attention should be
paid to clarifying the joint-authorization issues for persons from other
departments. The use of these policies and procedures should be added to
the training requirements for all ITF staff. Reference:
2. The
committee was concerned about the practice whereby individuals sometimes work
alone in the GTL or LDL with the outer door locked (to enable hazards).
While we did not reach a consensus on whether this practice is inherently
unsafe, we felt a reevaluation of this practice by persons with first-hand
knowledge of the activities and hazards would be prudent, including an
assessment of possible engineered or administrative measures to mitigate the
risk. Other locked spaces with people sometimes working
alone include the various other laser rooms on site. There is no policy at SLAC for a 2-man rule. (As of
4/19/2006, LLNL also does not have a 2-man rule for its laser labs per Ken
Barat, LSO.)
3. The GTL PPS system should be evaluated from the perspective of compliance with laboratory standards. Specific questions to address are whether a locking mechanism is appropriate for the GTL sliding door and if so, whether an interlocking mechanism is needed to ensure that the gun is off before the door can be opened from the outside. This appears to be something Radiation Physics should do.
Ö4. The sign-off documents used to record the training qualifications of persons who work in the ITF should include a provision for recording the written approval from each person’s supervisor (or SLAC contact person for non-SLAC employees). The AD Gun Operator Safety Training checklist and the AD Laser Operator Certification Workbook have both been updated to include a sign-off by the supervisor/contact person.
Ö5. The training documents include
an obsolete description of the administrative steps and responsibilities for
completing and archiving these documents. This information should be
updated, perhaps just to state that control and archiving of the documents is
the responsibility of the section head, who would then
have the authority to handle these matters in whatever way he sees fit. The AD Gun Operator
Safety Training checklist and the AD
Laser Operator Certification Workbook now contain the following statement:
"Completed Safety Training checklists are archived by the AD Documentation
Office."
6. The
formal documentation governing activities in the GTL should be expanded to
describe the need for and use of Radiation Safety Work Control Forms. The
procedures should be designed to ensure that appropriate authorization approvals
are obtained before covered work is performed, and that the forms are controlled
in such a way that the specified close-out requirements have been met before
operations resume. The requirement and
procedures for using the RSWC Forms at the ITF are specified in the SLAC Guidelines for
Operations (9-5.2.3.2). Implementation of these Guidelines will be integrated into
the response to Post-Restart Recommendation 1 above. The Guidelines for
Operations explicitly applies to the ITF.
Ö7. Posted signs should be updated as needed. Specifically, the sign that lists the names of trained GTL operators should be corrected or removed. The sign listing the “responsible persons” should also be updated. The list of names of trained GTL operators has been removed. The sign listing “responsible persons” has been updated.
Ö8. A sign should be posted to describe the function of the plastic barrier that enforces the allowable working height near the radiation enclosure in the GTL. A standard AD safety label is posted on the bottom of the barrier. It state: “Radiation Safety Item. Do not remove, modify or repair without authorization.”
Ö9. The cable trays should be grounded in accordance with the requirements of the National Electrical Code. The cable trays in the LDL have been grounded. For the GTL, where the trays have not been grounded, the suggestions in the ESG-XXX on "Managing the Hazards of Existing Electrical Systems," SLAC-I-730-0A11S-004-R000 (August 24, 2005), online at http://www-group.slac.stanford.edu/essg/pdf/guidance003.pdf , apply.
10. The need for a high-voltage grounding hook should be reevaluated. Based on a cursory examination and discussion, it appears that the installed grounding hook is unnecessary. Installed safety devices that give a false impression of the severity of a hazard or are inappropriate for the intended purpose can cause staff members to lose respect for the seriousness of other hazards. In this case, a designation of the device as a “discharge tool” rather than a “grounding hook” may help to avoid misplaced concerns about compliance with inappropriate standards. Perry Anthony (ESO) prefers we use the term "Ground Hook". The requirements for Ground Hooks are spelled out in Section 10.10.1.2.3 of the DOE Electrical Safety Handbook, available off the ESSG Standards page at http://www-group.slac.stanford.edu/essg/standards.htm . The hooks will be labeled: "GROUND HOOK: to be applied or removed only by approved operators."
11.
Several electrical safety warning labels list telephone extension 2097 as a
number to call for information. This number happens to correspond to the
current Area Manager; however, under SLAC’s telephone number assignment
policies, this number would not necessarily be reserved for the person
responsible for Building 6 cable trays if there were organizational or personnel
changes. Instead, such labels should refer to the title of the person who
has this responsibility. The widespread installation of these and similar labels
throughout SLAC in recent months, while providing an immediate remedy to a
long-standing problem, has been done in such a way as to plant the seeds for
long-term labeling problems which will grow in severity as time goes on. This is
a lab-wide issue, outside the control of this department. What are we suppose to do about a “lab-wide issue” like this?
Where the function of the person on a label is
important, the function will be listed in addition to the current name; i.e.,
“Building Manager, Tom Galetto,
2097.”
Annotated last on 24 April 2006