RECOMMENDATION 92-3 TO THE SECRETARY OF ENERGY pursuant to 42 U.S.C.  2286a(5) Atomic Energy Act of 1954, as amended. Dated: May 29, 1992 As indicated in our recent Recommendation 92-1, the Board is continuing its oversight and investigation of health and safety issues related to the proposed resumption of plutonium processing in the HB-Line at the Savannah River Site, South Carolina. Our review of Department of Energy (DOE) and contractor documents, as well as other information obtained during the investigation to date, leads the Board to conclude that the Operational Readiness Review (ORR) of the HB-Line conducted by Westinghouse Savannah River Company (WSRC) during the summer of 1991, and DOE's subsequent review called an "ORE", were premature, limited in scope, and inadequate. Moreover, some of the conclusions reached seem suspect. The Board was particularly concerned that some safety issues requiring resolution prior to resumption of operations (Category 1) were reclassified as post-resumption issues (Category 2), without the concurrence of certain DOE team members, raising a question regarding the supportability of the findings. The ORRs did not ensure adequate resolution and closure of safety and health issues associated with the HB-Line, which had not been operated since 1987. When attempts were made to resume operations in the HB-Line during the summer of 1991, following the ORRs, a series of radiological exposures to workers and other safety incidents occurred, causing operations to be suspended. In October of 1991, the HB-Line resumed operations until March of 1992, when operations were again suspended due to an unreviewed safety question. The Office of Nuclear Safety's review, as well as other assessments of HB-Line, identified safety issues which still have not been resolved. The Department has placed a priority upon safely resuming HB-Line operations to meet commitments made to NASA. While recognizing that the HB-Line may not pose an undue risk to the off-site public, the Board remains concerned with protection of on-site personnel, since an adequate assessment of operational readiness has not been conducted, nor has an adequate assessment of an accidental ground level release been performed. The Board has determined that the conduct of adequate and thorough ORRs by WSRC and DOE are essential for identifying and resolving remaining health and safety issues affecting workers, and at the same time promptly achieving readiness for restart. Therefore, the Board recommends that, prior to resuming operations in the HB-Line: 2 1. DOE direct WSRC to reopen its ORR, and that WSRC and DOE conduct adequate ORRs in accordance with previous Board recommendations and DOE implementation plans for ORRs at other facilities. 2. Comprehensive criteria documents be established for judging and measuring readiness to restart. The criteria documents should include the bases for judging which safety issues must be resolved prior to resumption, and which issues may be deferred for resolution subsequent to restart. 3. WSRC issue a Readiness to Proceed Memorandum requesting DOE approval for resumption of operations after WSRC has completed its ORR and has determined that safety issues appropriate for closure prior to resumption have been adequately resolved. 4. DOE provide whatever assistance it deems appropriate to WSRC during the contractor's conduct of its ORR, recognizing that such assistance is separate and distinct from DOE's subsequent and independent execution of its own ORR. 5. A DOE ORR team, including a Senior Advisory Group, conduct an independent and comprehensive ORR for HB-Line after (a) WSRC has conducted an adequate ORR and issued a Readiness to Proceed Memorandum requesting DOE approval for resumption of operations, and (b) DOE has sufficient reason to believe that significant deficiencies affecting the resumption and safe operation of HB-Line have been corrected by the contractor. 6. The DOE ORR team consist of experienced individuals whose backgrounds collectively include all important facets of the operations involved; that the majority of the team members be independent of HB-Line direct line management responsibilities to ensure an independent and unbiased assessment. 7. In preparing for the Operational Readiness Reviews for the HB- Line, DOE and WSRC should reexamine the HB-Line Safety Analysis Report (SAR) to ensure that: (a) the accident analyses adequately consider all credible scenarios; (b) all appropriate engineered safety systems which are necessary to prevent accidents or mitigate the on-site and off-site consequences of those accidents are identified; and (c) the information obtained from the updated Fire Hazards Analysis is consistent with the accident analyses. 3 8. WSRC and DOE should complete their assessment of compliance with DOE safety orders at HB-Line, and finish their review, approval, and implementation of any compensatory measures that are necessary and appropriate to achieve the objectives of order compliance and safe resumption of operations at HB-Line. /s/ John T. Conway Chairman ATTACHMENT A The review should include, but not be limited to, the following items: a. an assessment of WSRC resolution and closure of safety issues identified by Office of Nuclear Safety, Office of Environment, Safety and Health, and WSRC's and DOE's 1991 ORR teams; b. an assessment of the adequacy and accuracy of procedures governing process systems and safety systems during unusual and abnormal operating conditions and emergencies; the assessment should include walkdown of selected procedures; c. a determination of the adequacy of safety system as-built drawings by walkdown of selective systems; d. a determination of whether plant changes and modifications have been reviewed for potential impact on procedures, training, and qualification; e. a determination that training and qualification of operators was accomplished using the procedures that will be used during plant operation; f. an assessment of the level of knowledge achieved during operator qualification (or requalification) as evidenced by review of oral and written examination questions and results, and by selective oral examinations of operators by members of the review team; g. a review of conduct of operations of HB-Line and operator response to simulated abnormal and emergency situations; h. an examination of records of tests and calibration of safety systems and other instruments monitoring Limiting Conditions of Operations [or that satisfy Operating Safety Requirements and/or Technical Standards]; i. an evaluation of the WSRC and DOE safety order compliance effort with specific focus on the adequacy of the review, and the adequacy of the justification for, and implementation of, compensatory measures; and j. evaluate the DOE Field Office's capability to provide technical oversight of contractor operations, include in this review such areas as DOE Facility Representative qualification and training, level of knowledge, and technical surveillance.