Topic:  Use of Manual Actions for III.G.2 Compliance


Draft Revision to IP-71111.05 issued March 6, 2003


Draft IP-71111.05 Revision 3/6/2003 includes inspection guidance relative to licensee use of manual operator action. Below is the new text.


Level of Effort:

Additionally, in the selection process of the areas to be inspected, consider the licensee uses of manual actions in lieu of full implementation of Section III.G.2 requirements. Manual actions will be evaluated using guidance provided in Enclosure 2 to this procedure.


Changes in Scope

For triennial inspections starting November 2002, the scope of this procedure was changed to integrate inspection guidance for manual actions associated with licensee commitment to 10 CFR 50. Appendix R, Section III.G.2 (hence referred to as Section III.G.2). The background, objectives and specific guidance are provided in Enclosure 2 to this document. If the inspectors determine that manual actions are reasonable and are expected to meet the criteria outlined in Enclosure 2, then the inspection report will identify this issue as a Green finding pending the Commissionís acceptance of the proposed staff initiative to incorporate the use of manual actions into Section III.G.2.of the code. (The Green finding is an indicator that while compensatory measures in the form of manual actions have been implemented and are acceptable, the licensee continues to be in violation of the code requirements). If the inspectors determine that the manual actions are not reasonably accomplishable and therefore implementation may not lead to a safe plant condition, the preliminary finding will be

identified as potentially greater than Green and entered into the SDP.

Reference Enclosure 2 for Details

SECY Letter 03-0100 RULEMAKING PLAN ON POST-FIRE OPERATOR MANUAL ACTIONS, and Attachment, dated June 17, 2003

Plan recommended by the NRC Staff for Commission approval.

Federal Register / Vol. 68, No. 228, November 26, 2003, "Draft Criteria for Determining Feasibility of Manual Actions to Achieve Post-Fire safe Shutdown"