Information Notice No. 86-55: Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies
SSINS No. 6835
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
July 10, 1986
Information Notice No. 86-55: DELAYED ACCESS TO SAFETY-RELATED AREAS
AND EQUIPMENT DURING PLANT EMERGENCIES
All nuclear power reactor facilities holding an operating license or a
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.
Information Notice No. 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
July 10, 1986
Page 2 of 3
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
operators 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
automatically 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
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.
July 10, 1986
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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
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
2. The necessary keys, cards, or other means of access are available for
all foreseeable emergencies, while still maintaining adequate access
3. Training and drills in the use of emergency access provisions have been
conducted for essential plant personnel. (Personal safety in high
radiation 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.
Edward L. Jordan Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contact: Donald C. Kirkpatrick, IE
William L. Fisher, IE
Attachment: List of Recently Issued IE Information Notices
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