- . . . . . - . . . . .. . . .. . . .. . .. . . .. I ? 3 DOE/DP--0084T DE91 014933 Safety Evaluation Report Restart of K-Reactor Savannah River Site April 1991 U.S. Department of Energy ~ Assistant Secretary for Defense Programs Deputy Assistant Secretary for Nuclear Materials Washington, D.C. 20585 STER & 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 liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, 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 . 6.7 Systems Integrity 7. FIRE PROTECTION \ 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