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RE: NY Times Article on NRC changes in fire safety rules



> 

> But the idea of substituting humans for physical protections has

> attracted some skepticism. In September, at a meeting of the

> commission's Advisory Committee on Reactor Safeguards, Dana A. Powers,

> the committee's vice chairman asked: "Is there any hope? It's not like

> you can set up a simulator and test an operator action."

> 

> "How do you simulate smoke, light, fire, ringing bells, fire engines,

> crazy people running around?" he asked.

> 

> A commission staff member, Eva Brown, replied that in some cases,

lights

> could be turned off to make a drill seem more realistic, and

inspectors

> could check preparations by seeing if air packs were available.

> 

> Mr. Gunter, in a telephone interview, said that relying on manual

> actions would mean that plant workers would be counted on to perform

> heroic, or even suicidal, tasks.

> 



Nuclear plants can and do set up simulator tests to perform operator

actions, in which they perform a walkdown to ensure the operator action

is feasible under the assumed conditions.  Note that the assumed

conditions are worst case and the typical event would not be those same

worst case conditions.  They determine (by the walkdown) how much time

it takes to perform the mission to do the manual action and the

simulated plant conditions and simulated plant response.



If the fire protection actions are similar to other manual actions

performed by operators, they would have to address the following (from

NEI-96-07 Rev. 1):

1.  The action (including required completion time) is reflected in

plant procedures and operator training programs.

2.  The licensee has demonstrated that the action can be completed in

the time required considering the aggregate affects, such as workload or

environmental conditions, expected to exist when the action is required.

3.  The evaluation of the change considers the ability to recover from

credible errors in performance of manual actions and the expected time

required to make such a recovery.

4.  The evaluation considers the effect of the change on plant systems.



Granted, it is difficult to simulate the emotions involved if an event

occurs.  But, I don't think anyone is expected to perform suicidal

tasks, either.  





Cindy Ledbetter

Nuclear Engineer

Watts Bar Nuclear Plant

EQB 2N-WBN

423-365-1582



*The opinions expressed are mine and mine alone*

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