Restart criteria

Resuming Normal Operation and Establishing Restart Criteria... 

Restart criteria should focus on short-term prevention of one or more causal factors while the other causal factors and root causes are determined. One best practice is to have a task force quickly evaluate potential similar underlying causes elsewhere in the plant. Limitations imposed for restart are often undesirable for long-term operation as severe operational limits may be set. These limits, however, allow the system to run with minimal risk of recurrence of the incident. It is the duty of a company to demonstrate it is safe to restart. It is the duty of the regulator to prohibit restart if there is evidence of significant deficiencies. 

Recommendations concerning restart of operations are often developed before the final report is published. This is a management decision, but may or may not be part of the incident investigation scope. Nevertheless, these recommendations should be clearly written, imderstood by all, and be approved and accepted by the management organization responsible for safe operation of the facility. Restart criteria deserve special attention and are addressed in further detail later in the chapter. 

For most process safety related incidents, the remaining or adjacent sections of the facility will be in operable condition. Thus, the question of restart criteria may be an early task for the team. The topic is often addressed in stages. Initially there may be many restrictions because there will be many unanswered questions. Initial restrictions can be gradually lifted as information becomes more available. Some restrictions on operating parameters (such as flow rates, pressures or temperatures) may continue for extended periods. 

Restart criteria recommendations should receive the same degree of scrutiny as the final and formal recommendations. The manage-ment-of-change and pre-startup safety review implications of each restart recommendation should he considered and evaluated for possible adverse consequences. Some common changes encountered in restart criteria recommendations include ... 

Proof The proof is analogous to the proof for Theorem 8.1.1. Specifically, we need to show that for a given input sequence, the precise transition and precise restarting criteria are satisfied. If this is true, thoi since the properties of stateless and direct-sink are dynamically determined, the control implementation is precise. 

Since the precise transition and precise restarting criteria are both satisfied for a particular input sequence, and since statelessa and dsinka for all anchors are dynamically evaluated, the relative control implementation for G is precise with respect to the schedule 12(G). ... 

To develop the restart criteria for the issues discussed in 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 in the safety evaluations for each issue. The restart criteria identified in this report are intended to apply only to restart of the Savannah River reactors. The long range goal for the Savannah River reactors is to have them meet criteria that are equivalent to criteria used for older, commercial reactors. 

In a letter, dated March 15, 1990 (Reference 5), DOE transmitted the SER restart criteria to WSRC. The restart criteria provide clear and specific guidance to the contractor regarding the safety culture by stating minimum standards that must be met before restart of the reactors. These standards are based primarily on safety and health considerations. 

Additional instructions and guidelines, which are expected to address the restart criteria more fully, are being prepared and include (1) AI-105, "Event Notification and Investigation" (Reference 14) (2) AI-107,... 

Operational Readiness Review" (Reference 15) . (3) AI-112, "Commitment Tracking and Document Control" (Reference 16) (4) AI-119, "Issue Management" (Reference 17) and (5) draft AI-124, "Unreviewed Safety Questions" (Reference 18). These instructions and guidelines have been reviewed by SRRO personnel to assess satisfaction of the restart criteria. Those reviewed to date have been satisfactory. 

Some of the restart criteria yet to be fully addressed by published instructions or guidelines include ... 

Procedures and guidelines for the above critera have been prepared and are in draft form. SRRO will continue to review SRSPO s progress in documentation of formal procedures. The results of the continued progress in meeting the restart criteria through development of appropriate procedures will be reported in a supplement to the SER. 

In accordance with the restart criteria, the SRSPO managers are one of two groups with significant mandated restart training, inscluding ... 

The above training requirements are consistent with the restart criteria and if present progress continues, it is anticipated that all the SRSPO managers and facility representatives will meet their mandated restart training commitments. As reflected in draft AI-106, Revision 1, SRSPO is to designate a subset of fully qualified individuals from the two groups, who will have the primary responsibility of overseeing the K-Reactor restart. This subset would be known as the reactor restart task force. 

The training requirements for the RED staff, as documented in EP-303, meet the requirements of the restart criteria with the exception of training in the... 

The training requirements for the SOD staff, as documented in AI-106, Revision 1, meet the requirements of the restart criteria. As indicated previously for the RED staff, essentially all of the SOD staff has completed the restart training mandated in Section 2.1.2(4)(b), with the exception of the yet-to-be developed duties, responsibilities, and authorities course. 

Additional SRSPO inspection procedures/guidelines will be developed, as needed, to complement the SRSPO inspection programs discussed above. Upon completion,these procedures/guidelines will be evaluated and reported in a supplement to the SER.. Those reviewed to date, including OG-450 and OG-451, were found to be consistent with the restart criteria. Based on the above, the inspections and audits criterion is acceptably satisfied. 

In order to assess compliance with the restart criteria and Its Implementation, a team consisting of DOE staff and consultants conducted numerous Interviews of WSRC management and staff performed walkthroughs at K-Reactor and reviewed documents, such as administrative procedures, policies, newsletters, and memoranda. 

In January 1991, an evaluation team Interviewed Paul Rice, Vice President and General Manager, RRD, and Steve Smith, Manager, ROD. These senior managers Joined WSRC In November 1990. Based on the results of the Interviews and reviews of various documentation, the DOE staff s evaluation of the restart criteria Is given below. 

Based on the above evaluation, the DOE staff concludes that WSRC has made substantial and acceptable progress toward satisfying the restart criteria for Management and Safety Culture. Issues remaining to be addressed are clearly identified in the evaluation. The DOE staff will update its evaluation and document the results in an SER Supplement. 

The restart criteria for issue management establish the minimum requirements which must be satisfied to ensure that significant issues related to reactor operation are documented, brought to management attention, and corrected in an efficient manner. The criteria for deterinining the adequacy of the SRS issue management program for restart are described below. 

The following are the five restart criteria as used by the Issue Management Committee ... 

An independent review of the WSRC RIMP was initiated by the DOE-SRSPO to ensure that issues identified by independent external and internal reviews were captured within the RIMP process and were properly dispositioned in accordance with the WSRC restart criteria. The review also included an evaluation of the disposition against the DOE SER restart acceptance criteria. The review ensured that ... 

WSRC dispositioned items in accordance with their Restart Criteria. 

The SER restart criteria bound the WSRC restart criteria. Of the 153 issues reviewed, only 7 issues were identified as being required for restart that did not have specific SER restart acceptance criteria. These seven issues generally discussed very specific component level issues, such as testing of chemicals for contaminants prior to addition to a system, modification of check valves, etc. 

The DOE staff has determined that WSRC fully complies with the restart criteria for RSIP. 

As stated in Section 2.5.3.1, the staff has reviewed the proposed WSRC schedules for verification of compliance with Category I Orders and has determined that they do no fully meet the restart criteria. In several areas, WSRC s verifications are intended to be completed as part of the normal periodic QA surveillances. This results in verifications not being completed in a timely manner. WSRC should submit its plans for verification of compliance with DOE Orders to the staff for approval. This remains as an open item. 

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