Information Notice No. 86-55: Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies

                                                           SSINS No. 6835  
                                                           IN 86-55        

                                UNITED STATES
                        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 

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. 

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 
operators 
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                                                            IN 86-55
                                                            July 10, 1986
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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 
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. 

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                                                            IN 86-55  
                                                            July 10, 1986 
                                                            Page 3 of 3 

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 
     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
                    (301) 492-4510

                    William L. Fisher, IE
                    (301) 492-4671

Attachment: List of Recently Issued IE Information Notices