Generic Lessons Learned That Apply to the Design, Construction, Operation, and Decommissioning of DOE Facilities
During startup of new facilities, numerous cases have been observed in which the surveillance requirement supporting the safety basis could not be completed, or if completed, did not properly verify the safety basis requirement. Surveillance procedures should be completed, validated, and executed as part of the startup program, prior to the implementation of the supported Technical Safety Requirements (TSRs). Actually executing the surveillance will reveal such problems as: test points that are not installed; test points that are inaccessible; and other interfering interlocks or functions. These problems have occurred repeatedly in previous ORR/RAs.
Additionally, determination must be made that the surveillance actually tests the function or protective action upon which the safety basis depends. Previous ORR/RAs have revealed numerous occasions in which surveillances have been conducted and through either invalid acceptance criteria or a misunderstanding of the as-built configuration, the surveillance did not test the required functions.
For further information or comments on the ORR web site, please contact James M. Heffner.