[Federal Register: November 26, 2003 (Volume 68, Number 228)]
[Notices]
[Page 66501-66503]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr26no03-141]
=======================================================================
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
Draft Criteria for Determining Feasibility of Manual Actions To
Achieve Post-Fire Safe Shutdown
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of opportunity for public comment.
-----------------------------------------------------------------------
SUMMARY: The U. S. Nuclear Regulatory Commission (NRC) is considering a
revision to the fire protection regulations in 10 CFR part 50, appendix
R, paragraph III.G.2 to allow the use of manual actions by nuclear
power plant operators to achieve hot shutdown conditions in the event
of fires in certain areas provided the actions are evaluated against
specific criteria and determined to be acceptable. Currently, licensees
who rely on operator manual actions which have not been reviewed and
approved by the NRC are generally considered to be in non-compliance
with NRC regulations. However, the NRC believes that manual actions
relied upon by licensees are safe and effective when performed under
appropriate conditions. Accordingly, until the fire protection
regulations are revised, the NRC is planning to issue an interim
enforcement policy to exercise enforcement discretion if licensees'
manual actions meet the NRC's interim acceptance criteria. The NRC is
seeking comments from interested parties on the adequacy and clarity of
draft interim acceptance criteria which will be utilized by the interim
enforcement discretion policy.
DATES: Comment period expires December 26, 2003.
ADDRESSES: Submit written comments to the Chief, Rules and Directives
Branch, Division of Administrative Services, Office of Administration,
U.S. Nuclear Regulatory Commission, Mail Stop T6-D59, Washington, DC 20555-0001. Comments may be submitted by e-mail to nrcrep@nrc.gov.
Comments may be delivered to the NRC's headquarters at Two White Flint
North, 11545 Rockville Pike, Rockville, Maryland 20852.
[[Page 66502]]
FOR FURTHER INFORMATION CONTACT: Richard Dudley, Office of Nuclear
Reactor Regulation, Washington DC 20555-0001, telephone (301) 415-1116, e-mail rfd@nrc.gov or Ray Gallucci, telephone (301) 415-1255, e-mail rhg@nrc.gov.
SUPPLEMENTARY INFORMATION: Nuclear power plant fire protection
regulations and associated guidelines prescribe fire protection
features to ensure that at least one means of achieving and maintaining
safe shutdown conditions will remain available during or after any
postulated fire. The NRC has concluded that a fire protection
regulatory compliance issue exists at many nuclear power plants. This
situation involves fire protection of redundant safe shutdown trains
when these trains are located within the same fire area. Regional
inspections indicate that rather than using fire barriers or physical
separation to maintain safe shutdown capability, many licensees rely on
operator manual actions that have not been approved by the NRC.
Operator manual actions refer to those actions taken by operators to
manipulate components and equipment from outside the main control room
to achieve and maintain post-fire safe shutdown. Operator manual
actions are not permitted in 10 CFR part 50, appendix R, paragraph
III.G.2, for plants licensed to operate before 1979 unless a specific
exemption has been granted. For plants licensed to operate after 1979,
there is uncertainty as to whether operator manual actions can be used
without NRC approval as Appendix R is not required by regulation for
those plants (although most plants committed to Appendix R-equivalent
guidance in their fire protection programs). It is the NRC's
understanding that most of the licensees who rely on unapproved
operator manual actions have done so under the belief that the use of
operator manual actions to achieve safe shutdown is acceptable, without
NRC prior approval, as long as the reliance on operator manual actions
does not adversely affect the ability of a plant to achieve and
maintain safe shutdown. The industry also believes that most operator
manual actions used by licensees for operation of a safe shutdown train
during a fire do not involve any safety significant feasibility
concerns and would likely be approved by the NRC if processed as an
exemption or deviation request. The results from NRC fire protection
inspections to date indicate that there is insufficient evidence that
the generic use of these manual actions poses a safety concern. Thus
the staff believes that use of unapproved manual actions (for both pre-
and post-1979 plants) is typically a compliance issue and is not a
significant safety issue.
The Commission has decided to resolve this issue generically
through rulemaking because rulemaking provides the most efficient and
effective process to align regulatory requirements and safety
objectives. In SECY-03-0100, dated June 17, 2003, the staff proposed
and on September 12, 2003, the Commission approved developing an
interim enforcement policy which would be in effect while the
rulemaking was being undertaken to codify final acceptance criteria for
operator manual actions. This policy would exercise discretion in that
the NRC would refrain from taking enforcement action for those
licensees who rely on operator manual actions, provided these licensees
have demonstrated and documented the acceptability of their operator
manual actions in accordance with interim acceptance criteria developed
by the staff. The Commission approved the staff's recommendation to
engage stakeholders in at least one public meeting to discuss the
interim manual action acceptability criteria and how they would be used
in interim enforcement policy. (See Commission Memorandum dated
September 12, 2003, ADAMS Accession No. ML032550222).
The NRC staff has developed draft interim acceptance criteria for
manual actions. These draft criteria are provided below. They are an
extension of the ``Inspection Criteria for Fire Protection Manual
Actions'' issued by the NRC in March 2003 in Inspection Procedure
71111.05. This inspection procedure is available on the NRC public Web
site (http://www.nrc.gov.) The NRC held a public meeting on November
12, 2003, at NRC headquarters in Rockville, Maryland to allow members
of the public to comment on the preliminary draft criteria below.
Additional written comments on these criteria may be submitted to the
NRC during the 30 day comment period.
During the rulemaking process to codify the final acceptance
criteria for manual actions, additional public notices will be issued
and additional public comments will be solicited to further ensure that
public stakeholder input is considered.
Draft Interim Criteria for Determining the Acceptability of Manual
Actions To Achieve Post-Fire Safe Shutdown
Licensees who have relied on operator manual actions to comply with
Paragraph III.G.2 of Appendix R may be allowed enforcement discretion
if the area where the fire occurs has fire detectors and an automatic
fire suppression system installed in the fire area and if the manual
actions relied upon are consistent with all of the following acceptance
criteria \1\:
---------------------------------------------------------------------------
\1\ The criteria are not listed in any particular order.
---------------------------------------------------------------------------
1. Available Indications
Diagnostic indication, if credited to support operator manual
actions, shall be capable of:
[sbull] Confirming that the action is necessary;
[sbull] Being unaffected by the postulated fire;
[sbull] Providing a means for the operator to detect whether
spurious operation of safety-related equipment has occurred; and
[sbull] Verifying that the operator manual action accomplished the
intended objective.
2. Environmental Considerations
Environmental conditions encountered while accessing and performing
operator manual actions shall be demonstrated to be consistent with the
following human factor considerations for visibility and habitability:
[sbull] Emergency lighting shall be provided as required in
Appendix R, Section III.J, or by the licensee's approved fire
protection program, [e.g., lit with 8-hr battery-backed emergency
lighting], and sufficient lighting shall be provided for paths to and
from locations requiring any actions.
[sbull] Radiation shall not exceed 10 CFR Part 20, Section 20.1201,
limits.
[sbull] Temperature and humidity conditions shall be evaluated to
ensure that temperature and humidity do not adversely affect the
capability to perform the operator manual action (See, e.g., NUREG/CR-
5680, Vol. 2, ``The Impact of Environmental Conditions on Human
Performance'') or the licensee shall provide an acceptable rationale
for why temperature/humidity do not adversely affect performing the
manual actions.
[sbull] Fire effects shall be evaluated to ensure that smoke and
toxic gases from the fire do not adversely affect the capability to
access the required equipment or to perform the operator manual action.
3. Staffing and Training
There shall be a sufficient number of plant operators, under all
staffing levels, to perform all of the required actions in the times
required for a given fire scenario. The use of operators to perform
actions shall be independent
[[Page 66503]]
from any collateral fire brigade or control room duties they may need
to perform as a result of the fire. Operators required to perform the
manual actions shall be qualified and continuously available to perform
the actions required to achieve and maintain safe shutdown. A training
program on the use of operator manual actions and associated procedures
during a postulated fire shall demonstrate that operators can
successfully achieve these objectives.
4. Communications
To achieve and maintain safe shutdown, adequate communications
capability shall be demonstrated for operator manual actions that must
be coordinated with other plant operations, with this communications
capability continuously available.
5. Special Equipment
Any special equipment required to support operator manual actions,
including keys, self-contained breathing apparatus (SCBA), and
personnel protective equipment, shall be readily available, easily
accessible and demonstrated to be effective.
6. Procedures
Procedural guidance on the use of required operator manual actions
shall be readily available, easily accessible and demonstrated to be
effective.
7. Local Accessibility
All locations where operator manual actions are performed shall be
assessed as accessible without hazards to personnel, with controls
needed to assure availability of any special equipment, such as keys or
ladders, being demonstrated.
8. Demonstration
The capability to successfully accomplish required operator manual
actions within the time allowable using the required procedures and
equipment shall be demonstrated using the same personnel/crews who will
be required to perform the actions during the fire; documentation of
the demonstration shall be provided.
9. Complexity and Number
The degree of complexity and total number of operator manual
actions required to effect safe shutdown shall be limited such that
their successful accomplishment under realistically severe conditions
is assured for a given fire scenario. The need to perform operator
manual actions in different locations shall be considered when
sequential actions are required. Analyses of the postulated fire time
line shall demonstrate that there is sufficient time to travel to each
action location and perform the action required to support the
associated shutdown function(s) such that an unrecoverable condition
does not occur.
10. Equipment Pre-Conditions
Possible failure modes and damage that may occur to equipment used
during a fire shall be considered to the extent that the equipment's
subsequent use could be prevented, or at least made difficult. Credit
for using equipment whose operability may have been adversely affected
by the fire due to smoke, heat, water, combustion products or spurious
actuation effects shall account for such possibilities (e.g., over-
torquing an MOV due to a spurious signal, as discussed in Information
Notice 92-18).
Dated at Rockville, Maryland, this 20th day of November, 2003.
For The Nuclear Regulatory Commission.
Catherine Haney,
Program Director, Policy and Rulemaking Program, Division of Regulatory
Improvement Programs, Office of Nuclear Reactor Regulation.
[FR Doc. 03-29560 Filed 11-25-03; 8:45 am]
BILLING CODE 7590-01-P