Information Notice 1986-55, Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies

Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies

ML031220703
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	07/10/1986
From:	Jordan E NRC/IE
To:
References
IN-86-055, NUDOCS 8607030264
Download: ML031220703 (4)

SSINS No. 6835 IN 86-55 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 July 10, 1986 IE INFORMATION NOTICE NO. 86-55: DELAYED ACCESS TO SAFETY-RELATED AREAS AND

EQUIPMENT DURING PLANT EMERGENCIES

Addressees

All nuclear power reactor facilities holding an operating license or a

construction permit.

Purpose

This notice is provided to alert recipients of a potentially significant problem

concerning the ability to reach and operate essential equipment during an

emergency. The problem involves equipment located in areas where access is

controlled because of potentially high radiation or because it is classified as

a vital area. This concern also includes valves that are chained and locked to

provide positive position control. It is expected that recipients will review

the Information for applicability to their facilities and will consider actions, if appropriate, to preclude a similar problem at their facilities. However, suggestions contained in this information notice do not constitute NRC

requirements; therefore, no specific action or written response is required.

Past Related Correspondence:

IE Bulletin 77-08, "Assurance of Safety and Safeguards During an Emergency,"

December 28, 1977.

IE Bulletin 79-16, "Vital Area Access Controls," July 26, 1979.

IE Information Notice 83-36, "Impact of Security Practices on Safe Operations,"

June 9, 1983.

Description of Circumstances

Two events occurred in 1985, during which local operations necessary to control

these events were hampered or potentially hampered by features designed to

control access to areas or equipment.

During the Davis-Besse loss of feedwater event on June 9, 1985, locked doors

and valves had a significant potential of preventing operator actions necessary

to compensate for equipment malfunctions. With all sources of feedwater

disabled and the steam generators drying out rapidly, a number of operators

8607030264

IN 86-55 Vuly 10, 1986 were required to go to several secured locations to start pumps and open valves

to establish auxiliary feedwater flow. Some operators were concerned about

whether they would be able to open the necessary locks. Not all of the opera- tors had keys. Although some of the areas could be entered with key cards, these had been known to fail. One operator stated he was uncertain that he

would be able to carry out his task.

In this instance, the operators were able to establish the necessary feedwater

flow before the reactor suffered any fuel degradation. However, one of the

principal findings of the NRC investigative team stated: "The locked doors and

valves in the plant had the potential for significantly hampering operator

actions taken to compensate for equipment malfunctions during the event and

were a significant concern to the equipment operators" [NUREG-1154 Section 8, Item (9)].

During a Limerick remote reactor cooldown demonstration on September 11, 1985, a reactor core isolation cooling (RCIC) injection valve failed to open automat- ically and it became necessary for an operator to enter this locked area to

manually open the valve. At this point the operator discovered that the

compartment and equipment access keys had not been made available for the

remote shutdown function. A technician was requested to obtain a key to the

RCIC area from a set maintained by the health.physics personnel. However, the

technician had the wrong key when he met the operator at the RCIC area 15 minutes later. When the operator finally got the right key and entered the

area, he found the valve handwheel chained and locked. Neither the operator

nor the operating crew back at the remote shutdown panel had a key for this

lock. Bolt cutters finally were located and the chain was cut. Again this

problem was resolved without the occurrence of any damage. However, this event

occurred early during plant startup when the decay heat was low and the control

rod drive system was able to provide sufficient water for makeup. Had an actual

emergency required abandonment of. the control room following full-power operation, it is questionable whether the operators would have been able to take the

necessary action in a timely manner.

Discussion:

The need to control access to high radiation areas, vital areas and operational

equipment, and the need for quick access to such areas and equipment in an

emergency, may conflict unless careful plans are made to accommodate both needs.

The locking of high radiation areas is required by 10 CFR 20.203(c)(2)(iii) or

the facility technical specifications. Protection against radiological sabotage

by locking doors to vital areas and equipment is required by 10 CFR 73.55 by

incorporation into the physical security plan. Additionally, some facilities

elect to chain and lock selected valves to ensure positive position control.

However, an emergency may require the configuration of the equipment to be

changed quickly. If the emergency procedures and actions to provide quick

access are inadequate, there is concern that equipment may not be immediately

accessible if local operation is necessary in an emergency.

U

IN 86-55

- iJuly 10, 1986 The two events described above indicate that the emergency provisions at some

plants may not have been developed sufficiently to ensure timely access to

essential equipment. The emergency provisions at both of the above plants have

been upgraded as a result of their experiences. These provisions include

changing the remote shutdown procedures to require the transfer of the necessary

keys from the control room to the personnel at the remote panel at Limerick and

the provision of additional means of access at Davis-Besse. The subject of

access and equipment control has been addressed before (see past related

correspondence) from the standpoint of emergency access. The need for security, radiological protection and the positive position control of valves has not

diminished. However, it is suggested that licensees consider whether their

personnel would have timely access to essential equipment during an emergency.

Such consideration might include whether:

1. The emergency procedures have been reviewed and updated to ensure that

they provide adequate information to facilitate safe, rapid access to high

radiation, vital areas and operational equipment during emergencies.

2. The necessary keys, cards, or other means of access are available for all

foreseeable emergencies, while still maintaining adequate access control.

3. Training and drills in the use of emergency access provisions have been

conducted for essential plant personnel. (Personal safety in high radia- tion areas should be addressed in the training.)

4. Breakable seals with appropriate periodic verification could be used as a

way to detect tampering with or inadvertent manipulation of essential

equipment, instead of chains and locks.

No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the Regional

Administrator of the appropriate regional office or this office.

40 dwar L iordan, Director

Division f Emergency Preparedness

and En ineering Response

Office of Inspection and Enforcement

Technical Contacts: Donald C. Kirkpatrick, IE

(301) 492-4510

William L. Fisher, IE

(301) 492-4671 Attachment: List of Recently Issued IE Information Notices

Attachment 1 TjN 86-55 July 10, 1986 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

86-54 Criminal Prosecution Of A 6/27/86 All holders of by- Former Radiation Safety product, source, or

Officer Who Willfully special nuclear

Directed An Unqualified material

Individual To Perform

Radiography

86-53 Improper Use Of Heat Shrink- 6/26/86 All power reactor

able Tubing facilities holding

an OL or CP

86-52 Conductor Insulation Degrada- 6/26/86 All power reactor

tion On Foxboro Model E facilities holding

Controllers an OL or CP

86-51 Excessive Pneumatic Leakage 6/18/86 All BWR facilities

In The Automatic Depressuriza- holding an OL or CP

tion System

--

86-50 Inadequate Testing To Detect 6/18/86 All power reactor

Failures Of Safety-Related facilities holding

Pneumatic Components Or an OL or CP

Systems

86-49 Age/Environment Induced 6/16/86 All power reactor

Electrical Cable Failues facilities holding

an OL or CP

86-48 Inadequate Testing Of Boron 6/13/86 All BWR facilities

Solution Concentration In The holding an OL or CP

Standby Liquid Control System

86-47 Feedwater Transient With 6/9/86 All BWRs and PWRs

Partial Failure Of The facilities holding

Reactor Scram System an OL or CP

86-46 Improper Cleaning And Decon- 6/12/86 All power reactor

tamination Of Respiratory facilities holding

Protection Equipment an OL or CP and

fuel fabrication

facilities

OL = Operating License

CP = Construction Permit