Frequently Asked Questions About Managing Fatigue - 10 CFR 26.5 - Definitions
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Q1. Please provide clarification on how to determine significance to the public health and safety for maintenance and ops covered activities. Part 26 rule states use 10 CFR 50.65(a)(4), but lot of items in a(4) are not safety-significant during outages. For example auxiliary feedwater is not risk-significant during an outage. Everything in a(4) is significant to public health and safety per definition, so everything is covered.
Maintenance rule a(1) and a(2), high safety-significance is a different set of systems than a(4). Which part of the maintenance rule should we be using?
Covered Work
Q1. Please provide clarification on how to determine significance to the public health and safety for maintenance and ops covered activities. Part 26 rule states use 10 CFR 50.65(a)(4), but lot of items in a(4) are not safety-significant during outages. For example auxiliary feedwater is not risk-significant during an outage. Everything in a(4) is significant to public health and safety per definition, so everything is covered.
Maintenance rule a(1) and a(2), high safety-significance is a different set of systems than a(4). Which part of the maintenance rule should we be using?
Regarding the definition of maintenance, for the purposes of Part 26, use the 10 CFR 26.05 definition. In the example presented in this question, the auxiliary feed water system is safety significant when the unit is operating. If an individual works on the auxiliary feed water system either during outage or operations, the individual would be considered to be subject to the work hour controls in 10 CFR 26.205.
Note: The information herein is provided as a public service and solely for informational purposes and is not, nor should be deemed as, an official NRC position, opinion or guidance, or "a written interpretation by the General Counsel" under 10 CFR 26.7, on any matter to which the information may relate. The opinions, representations, positions, interpretations, guidance or recommendations which may be expressed by the NRC technical staff responding to your inquiry are solely the NRC technical staff's and do not necessarily represent the same for the NRC. Accordingly, the fact that the information was obtained through the NRC technical staff will not have a precedential effect in any legal or regulatory proceeding.