ENVIRONMENTAL MANAGEMENT INSTALLATION PLAN ISO 14001:2015 SOC NEVADA LLC

Transcription

1 PAGE 1 OF 17 REVISION HISTORY REV CHANGE DESCRIPTION AUTHOR DATE Annual Review, Updated signatry authrity t reflect current required signatures. Annual Review, Updated signatry authrity t reflect current required signatures. Updated signatry authrity t reflect current required signatures. Tk ut clumn fr Hawthrne Site Supervisr as Rb Mathias will be reviewing and signing. Christina Hllway 04/2018 Christina Hllway 05/2017 Cdy Burke/Karli Wilbur 04/2016 DOCUMENT NUMBER REFERENCE DOCUMENTS DOCUMENT DOCUMENTS REFERENCED IN THIS PROCEDURE ARE APPLICABLE TO THE EXTENT SPECIFIED HEREIN.

2 PAGE 2 OF PURPOSE AND SCOPE 1.1 The purpse f the Hawthrne Army Dept (HWAD) Management f Change (MOC) Standard Prcedure (SP) is t establish a systematic apprach fr evaluating prpsed prcess changes and dcumenting that evaluatin befre changes are implemented in rder t cmply with Nevada Administrative Cde (NAC) Thrugh review and dcumentatin f such changes assures that safety and health cnsideratins are incrprated int the perating prcedures and the prcess. The regulated prcess at HWAD is the Mercury Strage and Transfer Prgram, including the carbn dixide (CO 2 ) fire suppressin system. This prcedure supprts the HWAD Envirnmental Plicy and serves t minimize the risk f unintentinally releasing mercury and CO MOC must be prmpted by: (1) changes in chemicals, technlgy, equipment (ther than a replacement in kind), and prcedures used in the Mercury Strage and Transfer Prgram, (2) changes t buildings, structures, and equipment that affect the Mercury Strage and Transfer Prgram, r (3) changes in HWAD staffing fr the Chemical Accident Preventin Prgram (CAPP) implementatin and fr emergency respnse. This prcedure perates in cncert with the Standard Operating Prcedure (SOP) Prgram and the existing Cntrl f Standard Prcedures and Dcuments implemented under the Internatinal Organizatin fr Standardizatin (ISO) Envirnmental Management System. 2. LEGAL REQUIREMENTS 2.1 The Management f Change Standard Prcedure fr the Mercury Strage and Transfer Prgram is designed t meet the criteria f Nevada Divisin f Envirnmental Prtectin (NDEP) CAPP. Specifically, HWAD must cmply with: NAC Prcedures fr management f certain changes. (Nevada Revised Statutes (NRS) , ). The wner r peratr f a facility with a prcess that is subject t CAPP shall: Establish and implement written prcedures t manage changes, ther than a replacement in kind, t: (a) Chemicals, technlgy, equipment and prcedures that are used in a prcess; and (b) Buildings, structures and equipment that affect a prcess; Evaluate the impact f changes t rganizatinal structure r staffing levels n the implementatin f the preventin prgram and the emergency respnse prgram;

3 PAGE 3 OF LEGAL REQUIREMENTS (CONTINUED) Ensure that the prcedures established pursuant t subsectin 1 require that the fllwing cnsideratins are addressed befre ne f the changes described in subsectin 1 ccur and that the prcedures specify the criteria fr review and apprval f each f the fllwing cnsideratins: a) The technical basis fr the prpsed change; b) The impact f change n safety and health; c) Whether any mdificatins t perating prcedures will be necessary; d) The time necessary t make the prpsed change; and e) The requirements fr authrizatin fr the elements f the prpsed change; Infrm and train fr the change any emplyee wh is invlved in the peratin f the prcess that is affected by the change and any maintenance r cntract emplyee whse jb tasks will be affected by the change befre the start-up f the prcess r f the affected part f the prcess; and Update: (a) The prcess safety infrmatin required pursuant t NAC ; and (b) The perating prcedures r practices required pursuant t NAC DEFINITIONS AND ACRONYMS 3.1 CAPP - Chemical Accident Preventin Prgram CO 2 - Carbn dixide FES Fire & Emergency Services Hg Mercury HWAD Hawthrne Army Dept ISO - Internatinal Organizatin fr Standardizatin JSA - Jb Safety Analysis MOC - Management f Change NAC - Nevada Administrative Cde NDEP - Nevada Divisin f Envirnmental Prtectin NRS - Nevada Revised Statutes P&ID - Piping and Instrumentatin Diagram PHA - Prcess Hazard Analysis PSI - Prcess Safety Infrmatin PSI - Prcess Safety Infrmatin SOC SOC Nevada LLC SP - Standard Prcedure SWP - Safe Wrk Practices

4 PAGE 4 OF DEFINITIONS AND ACRONYMS (CONTINUED) Change: Includes (1) temprary r permanent (lng-term) mdificatins t technlgy, prcess equipment, prcedures, chemicals r prcessing cnditins that are nt a replacement in kind; (2) changes t buildings, structures, r equipment that affect the regulated prcess (Mercury Strage and Transfer Prgram r CO 2 fire suppressin system) and that are nt a replacement in kind; r (3) mdificatins t rganizatinal structure r staffing levels that impact the preventin prgram and the emergency r espnse prgram. Equipment: Includes changes in materials f cnstructin, equipment specificatins, piping arrangements, cmputer prgrams, alarms r interlcks. Replacement in kind: Replacing smething with the exact same thing (based n review f design specificatins) r a replacement that is equivalent t r that satisfies the design specificatin f the item t be replaced r perfrms the same rle f that part r prcedure. Changes that are replacements in kind are dcumented per the MOC prcess fr equipment changes and prcedure changes. Prcedural replacements in kind include editrial, administrative r nntechnical changes that d nt materially affect the way staff perfrm their wrk, which include change f cntacts, clarificatin and crrectin f spelling, grammar and punctuatin. Editrial and administrative changes t prcedures and plans within the Mercury Strage and Transfer Prgram will be dcumented accrding t the HWAD ISO Standard Prcedures and Dcument Cntrl Prgram. 4. RESPONSIBILITIES 4.1 SOC and DLA Strategic Materials Persnnel Initiating Prpsed Change - are respnsible fr ntifying their supervisr and DLA Strategic Materials Facility Manager f the need fr any prpsed changes t the Mercury Strage and Transfer Prgram befre implementing such a change. If the prpsed change triggers the MOC SP, then the staff member r their supervisr may cmplete the initiating sectin f the MOC Checklist. Prir t any changes, the SOC Envirnmental Services Manager, and DLA Manager will be ntified. Ensuring the dcument being used is the latest revisin available, when apprpriate. Each Tier 1 and all Tier 2 dcuments frmatted in accrdance with the SOC Quality Plan cntain the fllwing statement: It is the user s respnsibility t ensure, prir t use, the revisin f this dcument is the latest available. Check the master list, if unsure f dcument status, prir t use. Dwnladed, printed r cpied dcument, unless supplied and s indicated by a DCA as being a cntrlled dcument are uncntrlled. Each MMTS Operating Prcedure cntains the fllwing statement: NOTE: Hard cpies f this dcument may nt be the current versin. Refer t the IAmTheKey t verify the current versin.

5 PAGE 5 OF RESPONSIBILITIES (CONTINUED) 4.2 Supervisr(s) and DLA Strategic Materials Facility Manager - is respnsible fr ensuring the MOC prcess is initiated fr changes t the Mercury Strage and Transfer Prgram that are prpsed by their staff. The Supervisr r Manager cntacts the SOC Envirnmental Services Manager t btain an assigned MOC number fr a prpsed change. The Supervisr dcuments the prpsed change n the MOC checklist. Nte: Other SOC Managers will review and/r apprve the MOC dcumentatin per this prcedure. 4.3 SOC Envirnmental Services Manager and DLA Strategic Materials Facility Manager - have verall respnsibility fr the technical administratin and requirements f the MOC SP. The SOC Envirnmental Services Manager implements a system t assign tracking numbers t MOCs 4.4 SOC Fire & Emergency Services (FES) Chief - has respnsibility fr management f the mercury (Hg) mnitring and respnse prgram elements that include ensuring that MOC is perfrmed in accrdance with this prcedure fr mnitring and respnse elements. Als has respnsibility fr the testing, inspectin, and maintenance f the lw pressure CO 2 fire suppressin systems in the Hg strage warehuses, Hg mnitring and testing, and safe wrk practices (SWP) fr FES persnnel. 4.5 SOC Equipment Management Supervisr - has respnsibility fr the refrigeratin cmpnents f the CO 2 systems, ensuring that a maintenance prgram and prcedures are in place, and that MOC is perfrmed in accrdance with this prcedure fr equipment under their cntrl. 4.6 SOC Engineering Services Divisin Manager - has respnsibility fr prviding engineering technical supprt t the FES Chief and Equipment Manager. 4.7 SOC Safety Office Manager and DLA Strategic Materials Safety Manager - have respnsibility fr ensuring that MOC is perfrmed in accrdance with this prcedure fr prcess safety aspects f the Hg strage peratins. 4.8 SOC Quality Assurance Manager - has respnsibility fr ensuring that MOC is perfrmed in accrdance with this prcedure fr quality assurance/quality cntrl aspects f the Hg strage peratins, including visual inspectins f mercury strage buildings and cntainers and calibratin/peratin f mnitring equipment. 4.9 SOC General Manager and HWAD Cmmander - have administrative respnsibility fr this MOC Standard Prcedure.

6 PAGE 6 OF PROCEDURE 1 (FOR MANAGING PROCESS CHANGES) 5.1 This MOC Standard Prcedure shall be used fr all prpsed changes t the Mercury Strage and Transfer Prgram, including the CO 2 fire suppressin system, as detailed in the MOC Checklist. Prpsed changes must be evaluated fr impacts t health, safety and/r the envirnment, and a signed dcument shall be available befre the change (whether temprary r permanent) can be implemented. The dcument shall be signed a secnd time befre the change becmes peratinal as verificatin that the MOC prcess was cmpleted. Criteria and prmpts fr cnducting this evaluatin and designating respnsible individuals by psitin are included in the MOC Checklist. 5.2 This dcument is written specifically t meet the NDEP requirements under the CAPP that requires dcumentatin fr changes (including replacements in kind) in chemicals, technlgy, equipment, and prcedures used in the Mercury Strage and Transfer Prgram prcess. Changes t mercury strage warehuses, structures, equipment, and replacements in kind that affect the Mercury Strage and Transfer Prgram are als subject t CAPP dcumentatin requirements. 6. PROCEDURE 2 (FOR EVALUATING ORGANIZATIONAL OR STAFFING LEVEL CHANGES ON PROCESS SAFETY) 6.1 This prcedure requires evaluatin and dcumentatin f the impact f rganizatinal r staffing level changes n the implementatin f preventin and emergency respnse prgrams. Criteria and prmpts fr cnducting this evaluatin and designating respnsible individuals by psitin are included in the MOC Checklist. 7. CRITERIA FOR REVIEW AND APPROVAL OF PROPOSED CHANGES 7.1 The technical basis fr a prpsed change will be reviewed and apprved. The persns(s) respnsible fr the apprval are the Assistant Manager Envirnmental Services and the Defense Lgistics Agency Mercury Prgram Manager. The basis must include the reasn the change is being prpsed. An MOC tracking number will be assigned and dcumented n the MOC Checklist. Fr temprary changes, the time limit fr the change and hw it will be implemented shall be dcumented. Please refer t the MOC Checklist fr evaluatin criteria and prmpts. At the end f the apprved time perid fr the temprary r emergency change, the prcess r prcedures will either be returned t the riginal cnfiguratin r will be re-evaluated t determine whether the change will becme a permanent change using the MOC prcedure.

7 PAGE 7 OF CRITERIA FOR REVIEW AND APPROVAL OF PROPOSED CHANGES (CONTINUED) 7.2 A detailed descriptin f the prpsed change will be prvided by the respnsible Supervisr r Manager, including as applicable: design cncept, engineering studies, assciated prcess safety infrmatin (PSI), including plt plans, marked up piping and instrumentatin diagrams (P&IDs), specificatins, and/r calculatins. 7.3 This technical basis must be detailed, as it supprts the cmprehensive review f the impact f the change n safety, envirnment, and/r health (including persnnel impacts resulting frm expsure t the change). This review may identify additinal infrmatin needed fr decisin making. 7.4 The technical basis is used t evaluate which Managers are affected and which Managers shuld review and apprve the prpsed change, and then begin the prcess t review and update any affected CAPP dcuments. 7.5 If SOPs require changes, the affected Managers must cnduct and dcument safety impact reviews f the prpsed changes. The SOC Safety Manager and the DLA Strategic Materials Mercury Prgram Manager must review and apprve any changes t SOPs fr safety and health impacts. 7.6 Review f the safe wrk practices (SWP); jb safety analyses (JSAs), PSI, prcess hazard analysis (PHA) and emergency respnse training must be cmpleted by affected Managers t determine if revisins are necessary as a result f the prpsed change. If SWPs and JSAs require changes, the affected Managers must cnduct and dcument safety impact reviews f the prpsed change. The SOC Safety Manager and DLA Strategic Materials Safety Manager must review and apprve any changes t SWPs, PSI and PHA fr safety r health impacts. 8. METRICS 8.1 Nne required 9. RECORDS 9.1 The fllwing Quality Recrds shall be generated and managed in accrdance with SOC.QP.QMS.0002 QUALITY RECORDS RECORD REQUIRED CUSTODIAN RETENTION DISPOSITION

8 PAGE 8 OF FORMS 10.1 The fllwing frms are applicable t this dcument FORM NUMBER APPLICABLE FORMS 11. IMPLEMENTATION OF MOC CHANGES 11.1 Affected Managers will make the necessary changes t SOPs, SWPs, jb hazard analysis (JHAs), training, PSI and PSSR and dcument that thse changes were made n the MOC Checklist The respnsible Manager r Supervisr will fllw-up n the changes and when all are cmplete, that Manager r Supervisr will ntify the SOC Envirnmental Assistant Manager, wh will verify that all necessary changes have been made. If cnflicts are encuntered, the SOC Directr f BOP s will be cnsulted After the SOC Envirnmental Assistant Manager verifies the MOC prcess has been fllwed, then the change is released fr use. In additin, the SOC Envirnmental Assistant Manager will reprt t the DCA that changes have been made t a Site Specific prcess. The DCA will crdinate training t ensure all prcess peratrs, maintenance r cntract emplyees whse jb tasks will be affected. 12. TRAINING FOR EMPLOYEES AFFECTED BY PROPOSED CHANGES 12.1 The Supervisr f the Site Specific prcess must review and train all prcess peratrs, maintenance r cntract emplyees whse jb tasks that will be affected by the prpsed change prir t the implementatin f the change. The DCA receives mnthly Emplyee Baseline updates t ensure Site Specific emplyees are nt left ut The training prgram affected by changes t the Mercury Strage and Transfer Prgram is SOC.QP.EMP.HG All Mercury Strage and Transfer Prgram staff will be trained t cmply with this MOC prcedure.

9 PAGE 9 OF DOCUMENTATION UPDATES 13.1 Mercury Strage and Transfer Prgram dcuments fllw the SOC.QP.QMS.01, R16 Cntrl f Dcuments standard perating prcedure Fr any changes, including new equipment, instruments, and cntrls are checked t ensure suitability with the prcess by fllwing the MOC, PSI, PHA, and PSSR prcedures This includes equipment, instruments, and cntrls being checked t ensure installatin is per design specificatins and manufacturers instructin. The MOC prcess als ensures that maintenance materials, spare parts, and equipment are suitable fr the prcess fr which they will be used. 14. MANAGEMENT PLAN AND DOCUMENT CONTROL 14.1 SOC Envirnmental Services Manager is respnsible fr the develpment, implementatin and technical integratin f this prcedure. The fllwing rganizatins will participate in the develpment, implementatin and integratin f this prcedure and its cntents: SOC Fire and Emergency Services Hg Strage Buildings, CO 2 System, and Mnitring Equipment SOC Engineering, Facilities, & Planning CO 2 System Testing SOC Equipment Maintenance CO 2 System Refrigeratin Equipment Maintenance SOC Maintenance and Utilities Electrnics Shp Facilities Maintenance SOC Grunds Building Pest Cntrl and Brush Clearing arund CO 2 Tanks SOC MAXIMO System fr Managing and Tracking Preventive Maintenance SOC Cntract Administratin and Purchasing SOC Security SOC Guard Operatins SOC Envirnmental Services SOC Quality Assurance SOC Human Resurces Training Recrds DLA Strategic Materials Mercury Mbile Transfer System This prcedure and its cntents will be reviewed at least annually r at any time it is determined that a change t the MOC prcess (steps defined herein) is required. 15. MANAGEMENT OF CHANGE IMPLEMENTATION 15.1 The MOC Standard Prcedure is available t Mercury Strage and Transfer Prgram persnnel (DLA Strategic Materials, FES, Maintenance, Lgistics, Quality, Envirnmental, Engineering persnnel, etc.) Signatures n this prcedure indicate training f persnnel is dcumented and being prvided. The Training Plan fr the Mercury Strage Prgram addresses required training fr staff with regards t this MOC SP. In additin, randm audits are cnducted under ISO Internal Audit Standard Prcedure.

10 PAGE 10 OF MANAGEMENT OF CHANGE IMPLEMENTATION (CONTINUED) 15.3 The Cmpliance Audit Prgram will be fllwed while cnducting CAPP audits Internal Audits are cnducted at least every three years under the CAPP Cmpliance Audit Prgram t assure cmpliance with the MOC prcedure Scheduled MOC activities can be verified by cntacting the SOC Envirnmental Services Manager This prcedure is cntrlled under the ISO Dcument Cntrl Standard Prcedure and the Standard Operating Prcedure Prgram. Recrds - (including the checklist, training recrds, and changes made t prcedures, plans and dcumentatin) supprting this MOC are retained fr a minimum f five years. The respnsible manager maintains recrds during the time that a MOC is being evaluated and apprved fr implementatin. The cmpleted MOC dcumentatin checklist is kept n file by the SOC Envirnmental Services Manager. 16. REFERENCES 16.1 NDEP Prvided MOC / PSSR Flwchart NDEP/CAPP Management f Change Element Audit Checklist MOC Checklist Prcess Safety Infrmatin (PSI) Prcedure and supprting dcumentatin Prcess Hazard Analysis (PHA) Prcedure and supprting dcumentatin Pre-Start Up Safety Review (PSSR) Prcedure and supprting dcumentatin Standard Operating Prcedure Prgram Cmpliance Audit Prgram Training Plan fr the Mercury Strage and Transfer Prgram

11 PAGE 11 OF 17 Management f Change (MOC) Checklist t cmply with the NDEP CAPP PART 1: Prpsed Change including Replacements in Kind MOC #: Initiatin Apprval Date Implemented: Name f Initiatr: Phne #: Name f Prcess: Name f Respnsible persn(s) that have the authrity t apprve this MOC. By the signature(s) belw, the Respnsible persn(s) acknwledge that the submitted technical basis has been reviewed and apprved: Assistant Manager Envirnmental Services: Defense Lgistics Agency Safety and Health (CSP) Manager: Technical Basis: Reasn fr the change: Please prvide a detailed descriptin that supprts the review f health, safety r envirnmental impacts. Befre prceeding t Part 2: Evaluatin Criteria submit the technical basis t the Assistant Manager Envirnmental Services and the Defense Lgistics Agency Mercury Prgram Manager fr review and apprval.

12 PAGE 12 OF 17 Is the prpsed change a replacement in kind? If yes, skip the rest f this frm, btain required signatures and implement the replacement. Yes / N / NA What are the prpsed design changes, and hw are they dcumented? Was the design r cncept taken int cnsideratin? Yes / N / NA Yes / N / NA Were Engineering Studies Used? If yes, then list. Yes / N / NA Were Plt Plans used? If yes, then list. Yes / N / NA Were P&IDs used? If yes, then list. Yes / N / NA Were any calculatins used? If yes, then attach a cpy. Yes / N / NA PART 2: Evaluatin Criteria

13 PAGE 13 OF 17 Wuld the prpsed change impact safety r human health (including but nt limited t increases in pressure, higher expsure t harmful chemicals, increased pssibility f a release f hazardus chemicals, interrupt r change alarms r instrumentatin, interfere with safety r emergency equipment, change perating prcess parameters, etc.)? If yes, must be apprved by SOC Assistant Manager Envirnmental Services & DLA Safety and Health (CSP) Manager and review new PHA and PSI. Yes / N Assistant Manager Envirnmental Services: Defense Lgistics Agency Safety and Health (CSP) Manager: Wuld the prpsed change impact the envirnment, including but nt limited t increased pssibility f spills t the envirnment r increased discharges (air emissins, water emissins, increased energy cnsumptin, etc.)? If yes, cnsult the SOC Envirnmental Services Manager. Yes / N Des the prpsed change ptentially impact ther HWAD rganizatins? If yes, cnsult the SOC Safety Officer. If n, cnsult SOC Envirnmental Services Manager and skip Part 3. Is the prpsed change majr, cmplex (invlving multiple systems), r significant? Cnsultatin with all affected SOC managers is required. Yes / N Yes / N Des the change affect staffing f the CAPP implementatin r Emergency Respnse? If yes, cmplete Parts 3, 4 and 5. PART 3: Organizatins Cnsulted Was the fllwing rganizatin cnsulted: DLA Strategic Materials Was the fllwing rganizatin cnsulted: SOC Human Resurces? Was the fllwing rganizatin cnsulted: SOC Cntract Administratin r Purchasing? Was the fllwing rganizatin cnsulted: SOC Fire & Emergency Services? Yes / N Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA

14 PAGE 14 OF 17 Was the fllwing rganizatin cnsulted: SOC Safety Office? Was the fllwing rganizatin cnsulted: SOC Health Office? Was the fllwing rganizatin cnsulted: SOC Envirnmental Services? Was the fllwing rganizatin cnsulted: SOC Quality Assurance? Was the fllwing rganizatin cnsulted: SOC Maintenance Planning and Husing? Was the fllwing rganizatin cnsulted: SOC Engineering, Facilities, & Planning? Was the fllwing rganizatin cnsulted: SOC Maintenance & Utilities? Was the fllwing rganizatin cnsulted: SOC Equipment Maintenance, Electric Shp? Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA PART 4: Dcumentatin f Impact Reviews and Changes Standard Operating Prcedures (SOPs) Were prcedures reviewed? If n, state basis fr decisin and skip balance f sectin. D any prcedures need t be mdified r created? If yes, a) list the prcedures and prpsed changes; b) review the prpsed changes fr safety and health impacts; c) dcument the review; and prvide date(s). Yes / N / NA Yes / N / NA Safe Wrking Practices (SWPs) / Jb Safety Analysis (JSAs) Were SWPs / JSAs reviewed? If n, state basis fr decisin and skip balance f sectin. Were there any changes t r were SWPs/JSAs required? If yes, a) list the SWPs/JSAs and prpsed changes; b) review the prpsed changes fr safety and health impacts; c) dcument the review; and prvide date(s). Prcess Safety Infrmatin (PSI) Was the current PSI reviewed? If n, state basis fr decisin and skip balance f sectin. Did the current PSI require changes? If yes, amend changes, review, dcument and prvide date cmpleted. Yes / N / NA Yes / N / NA Yes / N / NA Yes / N / NA

15 PAGE 15 OF 17 Was a new PSI created? If yes, list and prvide date cmpleted. Prcess Hazard Analysis (PHA) Was the current PHA reviewed? If n, state basis fr decisin and skip balance f sectin. Did the current PHA require changes? If yes, describe changes needed and prvide date cmpleted. Yes / N / NA Yes / N / NA Yes / N / NA Was a new PHA required? If yes, list and prvide date cmpleted. Temprary r Emergency Changes Is a temprary r emergency change t CAPP prcedures required? If yes, then describe temprary/emergency change, including length f time temprary change wuld be in effect and hw it wuld be implemented (e.g., redlined prcedure). If n r NA, then skip balance f this sectin. Yes / N / NA Yes / N / NA Supervisr: Shuld ther manager s be cnsulted? If yes, then list and btain apprvals. Temprary/Emergency change apprval signature(s) Yes / N Apprved time limit 1 : Have affected emplyees been prvided training n r infrmed f the temprary / emergency change? If yes, then attach list f persns trained/infrmed and date. Training Were current training mdules reviewed fr the need fr changes? D any mdules need t be mdified r new mdules created? If yes, then list r attach a list and prvide date mdule change(s) was / were cmpleted. If n r NA, then skip the rest f this sectin. Yes / N Yes / N / NA Yes / N / NA 1 If additinal time is needed, the initiatr must btain their manager s apprval t extend the temprary authrizatin r must initiate the MOC prcess as a permanent change. Otherwise, the temprary change autmatically expires n the date set by the apprver.

16 PAGE 16 OF 17 Were prcess peratrs, maintenance, r cntract emplyees infrmed f any changes prir t the change taking affect? Yes / N / NA Hw will training be dcumented? Describe. When refresher/new training is cmpleted, Attach dcumentatin (syllabus, names and cmpletin dates). Yes / N / NA Part 5: Staffing Level Changes Will staffing levels fr implementatin f CAPP r Emergency Respnse change? If n r NA, skip rest f this sectin. Yes / N / NA Is there CAPP implementatin r Emergency Respnse impacts t the staffing level changes? If yes, describe and prvide infrmatin n any prgram changes needed t accmmdate the staffing changes, such as reassignment f jb duties; review f Emergency Respnse Plans and Prcedures; changes in chemicals, technlgy, equipment, perating prcedures; r the buildings, structures r equipment used in the Mercury Strage Prgram? Yes / N / NA INITIAL CHANGE APPROVAL SIGNATURES Name & Organizatin with signature

17 PAGE 17 OF 17 MOC VERIFICATION SIGNATURE Reviewed By: SOC Envirnmental Services, Manager DOCUMENT CHANGE HISTORY Revisin Date Review Perid- This dcument will be reviewed at least annually t ensure its suitability. Nature f Revisin Dcument Review Participants 01/19/11 Name change frm DZHC t SOC. Yvnne Dwns, SOC Env 08/24/10 Frmatting s there is mre rm fr written data. Yvnne Dwns, SOC Env