DOE O 425.1D Chg 2 (MinChg), Verification of Readiness to Start Up or Restart Nuclear Facilities - Change Chart

U.S. Department of Energy MINOR CHANGE Washington, DC Chg 2 (MinChg): 10-4-2019 SUBJECT: MINOR CHANGE TO DOE O 425.1D, VERIFICATION OF READINESS TO START UP OR RESTART NUCLEAR FACILITIES 1. EXPLANATION OF CHANGES. Changes were made to add the Invoked Technical Standards paragraph, and to clarify that this Order does not invoke any technical standards. 2. LOCATIONS OF CHANGES: Page Paragraph Changed To Throughout DOE O 251.1C DOE O 251.1 Throughout Office of Health, Safety and Security Office of Environment, Health, Safety and Security 19 4.h. DOE Headquarters line management must oversee DOE field processes for verifying readiness to startup and restart nuclear facilities in accordance with DOE O 226.1B, Implementation of Department of Energy Oversight Policy, and DOE-STD-3006, Planning and Conducting Readiness Reviews. DOE Headquarters line management must oversee DOE field processes for verifying readiness to startup and restart nuclear facilities, consistent with the requirements in DOE O 226.1, Implementation of Department of Energy Oversight Policy, current version. See DOE-STD-3006, Planning and Conducting Readiness Reviews, for acceptable methods. 20 6. References INVOKED TECHNICAL STANDARDS. This Order does not invoke any DOE technical standards or industry standards as required methods. Any technical standard or industry standard that is mentioned in or referenced by this Order is not invoked by this Order. Note: DOE O 251.1D, Appendix J provides a definition for “invoked technical standard.” 20-21 6.-7. Renumbered 7.-8. DOE O 425.1D INVOKED TECHNICAL STANDARDS 1. PURPOSE 2. CANCELLATION 3. APPLICABILITY. a. Departmental Applicability b. Contractors. c. Government-Owned, Government-Operated Facilities d. Equivalencies and Exemptions 4. REQUIREMENTS a. Determining the Level of Readiness Review b. Determining the Startup Authorization Authority (SAA). c. Startup Notification Report (1) DOE line management must ensure that SNRs are submitted quarterly or on a periodicity as defined by the PSO. (2) DOE line management must ensure that SNRs project ahead at least one year, update information from previously approved SNRs for startups and restarts that have not yet occurred, and add information for each startup or restart that has been identif... (3) DOE line management must ensure that every startup or restart determined to require a Readiness Review is included in the SNR. (4) Each SNR must be reviewed and approved by DOE field element management. When the SNR includes activities for which the startup authorization authority resides at headquarters, the field element management must approve or reject the activities on t... (5) Each SNR, including field element approval and/or recommendations, must be forwarded to the PSO, the site Lead PSO or CSO, as appropriate, the appropriate Central Technical Authority (CTA), and the Office of Environment, Health, Safety, and Securi... (6) Contractor and DOE Readiness Reviews must not commence until DOE has approved the SNR.

d. Requirements Applicable to DOE Operational Readiness Reviews. e. Requirements Applicable to DOE Readiness Assessments. f. Core Requirements. Core requirements verify the readiness of personnel, procedures, programs, and equipment within the scope of the Readiness Review to safely start nuclear operations. These core requirements are directly related to the seven guidi... (1) Line management has established Safety Management Programs (SMPs) to ensure safe accomplishment of work: (a) Contract requirements for the SMPs have been flowed down into facility-specific procedures; (b) SMP implementing procedures have been effectively implemented in support of the facility; (c) A sufficient number of qualified personnel is available to effectively implement the SMPs in support of the facility; and (d) Adequate facilities and equipment are available to ensure that SMP support and services are adequate for safe facility operation. The following SMPs are identified in 10 CFR Section 830.204, Documented Safety Analysis:  Quality Assurance Programs  Procedures Management  Maintenance Management  Personnel Training Program  Conduct of Operations  Emergency Preparedness  Fire Protection Program  Waste Management Program  Radiation Protection  Criticality Safety Program The SAA should designate and approve via the POA those specific SMPs to be included in the breadth of the readiness review and should specify the scope of the desired review of each designated SMP. Additional support programs may be specified in the P... (2) Functions, assignments, responsibilities, and reporting relationships, including those between the line operating organization and environment, safety and health support organizations, are clearly defined, understood, and effectively implemented, ... (3) The selection, training, and qualification programs for operations and operations support personnel have been established, documented, and effectively implemented. Training and qualification requirements for each position encompass the range of assigned duties and activities. The selection process and applicable position-specific training for managers ensures competence commensurate with their responsibilities. Modifications to the facility have been reviewed for potential impacts on training and qualification. Training has been performed to incorporate all aspects of these changes. (4) Level of knowledge of managers, operations, and operations support personnel is adequate based on reviews of examinations and examination results, selected interviews of managers, operations, and operations support personnel, and observations of o... (5) Personnel exhibit an awareness of public and worker safety and health and environmental protection requirements and, through their actions, demonstrate a high-priority commitment to comply with these requirements. Worker safety and health requirem... (6) Facility safety documentation (normally DSA and TSRs) is in place that describes the “safety envelope” of the facility. (a) The safety documentation characterizes the hazards/risks associated with the facility and identifies preventive and mitigating measures (systems, procedures, administrative controls, etc.) that protect workers and the public from those hazards/ris... (b) Facility safety documentation is approved and has been implemented. (c) Implementation of facility safety documentation has been verified and is current. (d) SSCs are defined. (e) A system to maintain control over facility design with emphasis on Vital Safety Systems (VSS) is established. (f) Procedures for maintaining the safety documentation have been adequately defined and implemented and provide for required updates. (g) A DOE-approved USQ procedure has been effectively implemented.

(7) A program is in place to confirm and periodically reconfirm the condition and operability of VSS. This includes examinations of records of tests and calibration of these systems. The material condition of all safety, process, and utility systems is adequate to support the safe conduct of work. (8) The facility systems and procedures, as affected by facility modifications, are consistent with the description of the facility, procedures, and accident analysis and assumptions included in the safety documentation. A formal program is defined and implemented to control facility modifications. Authorized modifications within the scope of the Readiness Review have been completed and fully closed, or evaluated and determined not to affect the ability to safely star... (9) Adequate and accurate procedures and safety limits are approved and in place for operating the process systems and utility systems. The procedures include necessary revisions for all modifications that have been made to the facility. Facility proc... (10) A routine operations drill program and an emergency management drill and exercise program have been established and implemented. Records for each program are adequate to demonstrate the effectiveness of completed drills and exercises as well as p... (11) An adequate startup or restart program has been developed that includes plans for graded operations and testing after startup or resumption to simultaneously confirm operability of equipment, the viability of procedures, and the performance and k... The plans should indicate validation processes for equipment, procedures, and operators after startup or resumption of operations, including any required restrictions and additional oversight. Any compensatory measures required during the approach to full operations are described. g. DOE Field Element Line Management Oversight of the Process for Verifying Readiness to Start Up or Restart Nuclear Facilities. h. DOE Headquarters Line Management Oversight of the DOE Field Process for Verifying Readiness to Startup and Restart Nuclear Facilities. i. Records Management Program j. Implementation. Implementation of this Order for DOE Line management must be completed in 180 days from the issuance of the Order, unless a different schedule is approved by the PSO with concurrence of the CTA. Those previously identified and defin... 5. RESPONSIBILITIES. a. DOE and NNSA Line Management. b. Office of Environment, Health, Safety and Security. 6. INVOKED TECHNICAL STANDARDS. This Order does not invoke any DOE technical standards or industry standards as required methods. Any technical standard or industry standard that is mentioned in or referenced by this Order is not invoked by this Order... 7. REFERENCES. a. Title 10, Code of Federal Regulations (CFR), Part 830, Nuclear Safety Management. b. 10 CFR Part 851, Worker Safety and Health Program. c. 49 CFR, Part 173, Subpart I, Class 7 (Radioactive Materials) d. DOE O 226.1, Implementation of Department of Energy Oversight Policy, current version. e. DOE O 243.1, Records Management Program, current version. f. DOE O 251.1, Departmental Directives Program, current version. g. DOE O 422.1, Conduct of Operations, current version. h. DOE Standard (STD) 3006-2010, Planning and Conducting Readiness Reviews. i. DOE-Handbook (HDBK) 3012, Guide to Good Practices for Operational Readiness Reviews, Team Leader’s Guide.

8. CONTACT ATTACHMENT 1. CONTRACTOR REQUIREMENTS DOCUMENT 1. DEPARTMENT OF ENERGY (DOE) INCLUDING THE NATIONAL NUCLEAR SECURITY ADMINISTRATION (NNSA) CONTRACTOR RESPONSIBILITIES 2. CONTRACTOR REQUIREMENTS a. Determining the Level of Readiness Review b. Determining the SAA c. Startup Notification Report d. Requirements Applicable to Operational Readiness Reviews. e. Requirements Applicable to Readiness Assessments. f. Core Requirements. Core requirements verify the readiness of personnel, procedures, programs, and equipment within the scope of the Readiness Review to safely start nuclear operations. These core requirements are directly related to the seven guidi... g. Exemptions and Equivalencies. Exemptions and equivalencies may be obtained in accordance with DOE O 251.1, Departmental Directives Program, current version, and DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requ... h. Records Management Program. Requirements for maintenance and disposition of Federal records, such as those pertaining to ORRs or RAs, are provided under the general guidance of DOE O 243.1, Records Management Program, current version. The dispositi...