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DOE/DP--0084T
DE91 014933
Safety Evaluation Report
Restart of K-Reactor
Savannah River Site
April 1991
U.S. Department of Energy
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Assistant Secretary for Defense Programs
Deputy Assistant Secretary for Nuclear Materials
Washington, D.C. 20585
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blSTRlBUTfON OF THIS DOCUMENT IS 0NLIMITER
DISCLAIMER
This report was prepared as an account of work sponsored by an
agency of the United States Government. Neither the United States
Government nor any agency Thereof, nor any of their employees,
makes any warranty, express or implied, or assumes any legal
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recommendation, or favoring by the United States Government or any
agency thereof. The views and opinions of authors expressed herein
do not necessarily state or reflect those of the United States
Government or any agency thereof.
DISCLAIMER
Portions of this document may be illegible in
electronic image products. Images are produced
from the best available original document.
TABLE OF CONTENTS
1. INTRODUCTION
2. MANAGEMENT ISSUES
2.1 DOE Management and Program Oversight
2.2 Management and Safety Culture
2.3 Issues Management and Resol utio n
2.4 Reactor Safety Improvement Program
2.5 Contractor Compliance with DOE Orders
3. QUALITY ASSURANCE
4. RADIATION PROTECT ION
5. DESIGN CONTROL AND VERIFICATION
5.1 Safety Analysis Report (SAR)
5.2 Unreviewed Safety Questions (USQs)
5.3 Technical Base1 ine Program
5.4 Design Change Process
5.5 Drawing and Document Control
5.6 Safety-Related Equipment List
5.7 Risk and Reliability Analysis
5.8 Software Quality Assurance (SQA)
6. DESIGN ISSUES
6.1 Seismic
6.2 Core Issues
6.2.1 Core Design
6.2.2 Control Rod Drive System Re1 ia bi 1i t y
6.2.3 Fuel Quality
6.3 Electrical Issues
6.3.1 Ele ctric al Power Systems
6.3.2 Environmental Qualification (EQ)
6;4 Airborne Activity Confinement System
6.5 Safe Shutdown
6.6 Sump Water Removal
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6.7 Systems Integrity
7. FIRE PROTECTION
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8. TESTING AND STARTUP
8.1 Control of Testing
8.2 System/Preoperational Testing
8.3 Power Ascension Testing
9. SAFETY REVIEWS
9.1 Operat io nal Safety Revi ew Process
9.2 Independent Safety Review Process
9.3 Post-Trip Assessment
10. OPE RAT IONS
10.1 Staffing and Qualifications
10.2 Training
10.3 Normal and Abnormal Operat in g Procedures
10.4 Emergency Operating Guide1 in es and Procedures
10.5 Housekeepi ng
10.6 Logkeeping
10.7 Shift Turnover
10.8 Communi cati o ns
10.9 Tagouts/Lockouts
10.10 Notifications/Reporting
10.11 Control o f Equipment and Systems
10.12 Independent Verification
10.13 Fitness-for-Duty
10.14 Piping and Instrumentation Diagrams (P&IDs) i n the Central
Control Room (CCR)
10.15 Control Room Access/Decorum
10.16 Operating Experience Feedback
11. OPERATING LIMITS
11.1 Transient and Accident Analysis
11.2 Technical Specifications
11.3 Power Limits
12. ENGINEERING AND TECHNICAL SUPPORT
13. MAINTENANCE
14. INSPECTION AND TESTING
15. EMERGENCY PREPAREDNESS
16. OPERATIONAL READINESS REVIEW
1. INTRODUCTION
In 1981, in the aftermath of the events at Three Mile Island, the DOE
described certain deficiencies at SRS in a very thorough, 15-volume study of
DOE reactor facilities. In 1987, a group of reactor safety experts assembled
by the National Academy of Science (NAS) reviewed DOE reactor operations and
found that little had been done to correct the deficiencies noted in the 1981
report. Further, the NAS review indicated that reactor power levels had been
reduced to half power due to technical issues that had recently surfaced.
Contractor management had not been aggressive in dealing with safety questions
raised.
In August 1988, with both the L- and K-Reactors in an extended outage, an
incident occurred at the SRS P-Reactor that raised questions about the
operating contractor staff's ability to understand and properly respond to
abnormal events. Pending a review of the incident, the P-Reactor was also
shut down.
In November 1988, the DOE issued the "Savannah River Plant K-Reactor Restart
Strategy" (a1 so known as the "Char1 otte Criteria"). This document was the
result of a diagnostic evaluation of issues raised, not only from the August
1988 event, but also from earlier safety reviews. It contained requirements
to be met before restart.
On April 1, 1989, the operating contract for SRS was transferred from E.I. Du
Pont de Nemours & Company (DuPont) to the Westinghouse Savannah River Company
(WSRC). In preparation for this transition, WSRC performed a corporate safety
assessment of the reactor design and operations. WSRC published the results
of their assessment in the !'Westinghouse Independent Safety Review of Savannah
River Production Reactors" (WISR), April 1, 1989. This document also included
a list of recommendations for improvements to the reactor operations, design
and management for both before and after restart.
On May 19, 1989, the Secretary of Energy directed a number of specific
management and organizational changes within DOE. These changes, which are
discussed in Secretary of Energy Notice SEN-6-89, were specifically designed
to establish line organizations that are fully responsible for their programs.
Among the changes discussed in SEN-6-89, was the establishment of the Savannah
River Restart Office (SRRO) at DOE headquarters in Germantown, MD and the
Savannah River Restart Special Projects Office (SRSPO) at the Savannah River
site. These organizations were tasked with activities in support of the safe
and timely restart of the Savannah River reactors, including the evaluation of
programs developed to correct safety and management problems at SRS. The
results of the SRRO/SRSPO evaluation are included in this SER.
This SER focuses on those issues required to support the restart of the K-
Reactor. Issues related specifically to the L-Reactor will be addressed in a
supplement to this SER, which will be issued prior to restart of that reactor.
This SER provides the safety criteria for restart and documents the results of
the staff reviews of the DOE and operating contractor activities to meet these
criteria. To determine the issues of concern to be addressed by this SER, the
1. o-1
staff first reviewed deficiencies identified i n reports, such as the NAS
Report (November 1987), the Charlotte Criteria and the WISR to identify
general areas of concern that needed to be addressed to support reactor
restart. The DOE Management and Program Oversight issue, for example,
generally summarizes the DOE onsite technical vigilance and monitoring (TV)
issues discussed i n the Charlotte Criteria. Specific management issues, such
as safety culture, were also identified based on experience with commercial
reactors (e.g., Peach Bottom and the Tennessee Valley Authority plants), where
issues such as these have been shown to be the root causes of many long term
deficiencies. Some issues were identified on the basis of a comparison
between the draft DOE Safety Policy (which identifies those areas to be
considered to ensure safe operation of a DOE facility) and previously
identified areas of concern at SRS.
To develop the restart criteria for the issues discussed i n this SER, the SRRO
and SRSPO staffs relied, when possible, on commercial industry codes and
standards and on NRC requirements and guidelines for the commercial nuclear
industry. However, because of the age and uniqueness of the Savannah River
reactors, criteria for the commercial plants were not always applicable. In
these cases, alternate criteria were developed. The restart criteria
applicable to each of the issues are identified i n the safety evaluations for
each issue. The restart criteria identified i n this report are intended to
apply only to restart of the Savannah River reactors. The long range goal for
the Savannah River reactors i s to have them meet criteria that are equivalent
to criteria used for older, commercial reactors.
Following the development of the acceptance criteria, the DOE staff and their
support contractors evaluated the results of the DOE and operating contractor
(WSRC) activities to meet these criteria. The results of those evaluations
are documented i n this report. Deviations or failures to meet the
requirements are either justified in the report or carried as open or
confirmatory items to be completed and evaluated i n supplements to this report
before restart.
1 .o-2
2 MANAGEMENT ISSUES
2.1 DOE Manaqement and Proqram Oversiqht
2.1.1 Background
As a result of the Department of Energy’s (DOE’S) failure to recognize the
developing severity of the problems at the Savannah River Site (SRS),
confidence in the DOE reactor-oversight process was lost. On May 19, 1989,
the Secretary of Energy directed in Secretary of Energy Notice 6-89 (SEN-6-89)
(Reference 1) that a number of management and organizational changes be made
to (1) improve the DOE oversight process, (2) establish direct line
responsibility, and (3) focus Departmental resources on the safe and timely
restart of the SRS reactors. These changes involved, in part, the
establishment of the Savannah River Special Project Office (SRSPO) at SRS and
the Savannah River Restart Office (SRRO) at DOE headquarters. Both groups
report directly to the Deputy Assistant Secretary for Nuclear Materials.
The Director of SRSPO was assigned the responsibility of directing the
contractor’s efforts on matters directly related to the managerial, technical,
operational (including training), and scheduling aspects of the safe restart
of the K-, L-, and P-Reactors.
SRSPO staff currently consists of about 55 management and technical personnel
and 17 administrative personnel. The organization is divided into four
groups: (1) the Technical Support Division (TSD), which is responsible for
overall reactor restart program integration and support activities including
pl anni ng , i ssue management, DOE training and procedures, the Reactor Safety
Improvement Program, environmental activities, and emergency planning; (2) the
Reactor Operations and Training Division (ROTD), which is responsible for
oversight of the day-to-day activities at the reactors including operations,
maintenance, modifications, and testing as well as the oversight of contractor
procedures, training, and response to events; (3) the Safety Oversight
Division (SOD), which is responsible for oversight of quality assurance,
health physics, and the independent oversight of design, management, conduct
of operations, reactive appraisals,and event follow-up; and (4) the Reactor
Engineering Division (RED), which is responsible for review of the design and
analysis of the facility including modifications, system testing, and
inspections.
SRRO’s staff of approximately 17 technical and management personnel is divided
into three divisions: (1) the Environmental, Occupational Safety, and
Emergency Preparedness Division, which is responsible for oversight of
environmental requirements and compliance, environmental impact
studies/statements, worker/publ ic health.a nd safety, emergency preparedness,
and quality assurance; (2) the-Plant Readiness Division, which is responsible
for issues re1 ated to reactor operations, trafining,s tandards and procedures,
operational tests, maintenance and ‘technical support; and (3) the Project
Control Division, which-is responsible for the coordination of the Safety
Evaluation Report .(SER) for reactor restart and the oversight of budget,
schedules, mi 1 estones, and issues management.
2.1-1
The Director of SRSPO has the line responsibility for the oversight of the SRS
reactors. For this reason, the evaluation of DOE'S oversight of the SRS
reactors focuses primarily on the efforts of the SRSPO organization. The
review and evaluation of SRSPO, which was performed by the SRRO staff, was
divided into five discipline areas: (1) Safety Culture, (2) Documentation and
Formality, (3) Involvement in Reactor Operations, (4) Training and Technical
Proficiency, and (5) Inspections and Audits. The restart criteria evolved
1 argely from the November 1988 Savannah River P1 ant K-Reactor Restart Strategy
(Reference 2) which is also known as the Charlotte Criteria, and are based on
those deveded for similar NRC oversiaht activities. The restart criteria
supplementary requirement: based on corrective ac ion plans from
designated by the NRC as "prob em plants."
Zl.2 Restart Criteria
The criteria for determining the adequacy of DOE oversight act vities for
restart are described below.
SRSPO shall oversee the efforts of its contractors at SRS to ensure safe
reactor operation and satisfaction of production objectives without violation
of applicable operational, environmental, safety, health, or security
standards. This shall be accomplished by providing clear direction to the
contractor and by verifying acceptable performance based on inspections of
reactor, engineering, and facilities operations. SRSPO oversight
responsibilities for each of the five discipline areas include:
(1) Safety Culture
(a) The DOE safety culture shall reflect the philosophy that
protection of the environment, safety, and health is to be more
heavily weighted than production. There should be formally stated
policy guidance to this effect. Performance elements for all
technical, professional, and management personnel at SRSPO shall
emphasize the importance of safety. In addition to stated
pol icies and performance elements, SRSPO management shall use
additional means (e.g., performance awards, staff meetings,
training) to identify and communicate the cultural values of (1)
adherence to safety, environment, and health requirements and
policies, (2) engineering#excellence, and (3) individual
accountability for performance.
(b) The DOE safety culture shall be expressed to the contractor
through clear and specific guidance, and commitment to this
principle shall .be further evidenced by a willingness on the part
of DOE management and staff to challenge the contractor to
demonstrate conformance to stated policies, laws, and regulations.
In addition, the emphasis on safety, environment, and health shall
be clearly reflected in the operating contract and in the process
of awarding fees. DOE procedures shall also clearly state actions
to be taken when unacceptable performance is discovered during
daily oversight activities. DOE line accountability for
performing these actions shall also be clearly stated.
2.1-2
(2) Documentation and Formality
(a) Formally documented procedures and policies that assign clear
lines of responsibility shall be developed for SRSPO. The
following list includes the minimum issues for which formal
procedures and policies should be developed and implemented:
assessment and appraisal process
tracking and resolution of identified problems and issues
receipt and dissemination of notification of events
receipt and dissemination of lessons learned on issues
applicable to the SR reactors
formal actions in response to event reporting requirements
formal process for review of new or revised orders,
procedures, and policies from inside and outside DOE
formal safety evaluation process, including review of
unresolved safety questions
formal process for feedback to employees on performance and
the resolution of employee concerns
(b) SRSPO procedures shall clearly define 1 i ne responsi bi 1 it i es for
identifying and pursuing problems at the SR reactors. In
addition, the procedures shall clearly state actions to be taken
if contractor response is inadequate for the situation.
(3) Involvement in Reactor Operations
SRSPO management and staff shall be directly involved in the daily
operation of the SR reactors. This involvement should be evidenced by
fol 1 owing :
SRSPO facility representatives stationed at each of the reactors
a formal plan for unannounced SRSPO management walkthroughs of the
reactors, including a process for recording the time spent, the
reactor inspected, the findings from the visit, and the actions
being taken to effect contractor resolution of significant
f i ndi ngs
a plan for enhancing the technical capability of the SRSPO staff
and management
defined SRSPO management and staff roles and duties for coverage
of contractor activities, including backshift and deep backshift
coverage where appropriate
cl early defined and documented SRSPO stop work authority
formal and timely SRSPO review and approval process for unreviewed
safety questions
oversight of contractor review groups
2.1-3
