B12258, Clarifies 860819 Response to Potential Violation Item 86-17-08 Re Inadequate Emergency Lighting,Radio Communications & Breakers for Stated Valves Action Items, Per App R Insp During Wk of 860616

Clarifies 860819 Response to Potential Violation Item 86-17-08 Re Inadequate Emergency Lighting,Radio Communications & Breakers for Stated Valves Action Items, Per App R Insp During Wk of 860616

ML20215C154
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/26/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Charemagne Grimes Office of Nuclear Reactor Regulation
References
B12258, GL-86-10, NUDOCS 8610100126
Download: ML20215C154 (4)

Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CONNEOTICuT P o. Box 27o HARTFORD. CONNECTICUT CS141-027o TELEPHONE 2ovess-sooo September 26,1986 Docket No. 50-213 B12258 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Action Items Resulting From NRC Appendix R Inspection of June 16-20, 1986 During facility wasthe week of June conducted by 16, an Appendix the NRC Staff. In R a inspection letter datedofJuly the Haddam Ne(ck3, 1986, 1)

Connecticut Yankee Atomic Power Company (CYAPCO) identified various action items arising from the inspection and provided the Staff with a schedule for their resolution. item No. I of the July 3 letter addressed the Staff's concern regarding inadequate emergency lighting in fire zones A-1B, A-lC (charging pump area), access / egress routes to these areas, and fire zone R-1 (Cable Vault).

CYAPCO agreed to provide eight hour battery-powered emergency lighting in fire zones A-1B and A-lC, illumination to access / egress routes to these areas, and to install additional emergency lighting in fire zone R-1.

On August 1, 1986,(2) the Staff issued the inspection report resulting from the Appendix R inspection of Haddam Neck and identified four (4) potential violations and one potential deviation. Inadequate emergency lighting in fire zones A-1B, A-lC, access / egress routes to these areas, and fine zone R-1 was identified as one of the potential violations. In a letter dated August 19, 1986,(3)

CYAPCO addressed the unresolved items of the August 1,1986 inspection report (1) 3. F. Opeha letter to C. I. Grimes, dated July 3,1986, " Action Items Resulting from Inspection of Haddam Neck on June 16 - 20, 1986."

(2) S. D. Ebneter letter to 3. F. Opeka, dated August 1,1986," Inspection Report No. 50-213/86-17."

(3) 3. F. Opeka letter to C. I. Grimes, dated August 19,1986, "Haddam Neck Plant Action Items Resulting from Appendix R inspection of June 16 - 20, h 1986."

e610100126 860926 PDR ADOCK 05000213 0 PDR

, and provided a schedule for their resolution. In this letter, CYAPCO revised its position on emergency lighting and determined, in accordance with NRC generic guidance, that eight-hour battery-powered emergency lighting is not required for fire zones A-1B and A-IC and that portable, lighting will suffice for the interim period until the new switchgear room is installed. Also, additional emergency lighting powered by a portable generator will be installed in fire zone R-1. This letter committed to provide a response for the four potential violations and one potential deviation by September 3,1986.

CYAPCO's response to these items was presented to the Staff at the September 3,1986 management meeting with the NRC on Appendix R. The purpose of this letter is to further clarify CYAPCO's response to Potential Violation Item 86-17-08, Inadequate Emergency Lighting, and to provide further clarification of two other action items addressed in CYAPCO's August 19, 1986(31 and August 29,1986(4) letters.

During the safe shutdown procedure walk-through, CYAPCO operators were required to climb down into the charging pump cubicles (fire zones A-1B and A-IC) to operate valves BA-MOV-32, BA-MOV-373 and CH-MOV-257. No emergency lights were used. In addition, the operators would have to use portable lights to make instrument connections and take readings in the cable vault room (fire zone R-1). The NRC inspection team concluded that the lack of emergency lights in the two charging pump cubicles and adequate permanent lights in the cable vault constitutes a violation of 10 CFR 50 Appendix R, Section III.J.

CYAPCO's subsequent review of this finding concludes that the current means of providing emergency lighting for accomplishing safe shutdown tasks in fire zones A-1B, A-1C and R-1 does not constitute a violation of Section 111.3 based on the following:

1. The shutdown actions required to be performed in these areas will only be necessary in the interim until the new switchgear room is completed.

The rerouting of power and control cables, insta!!ation of fire barriers, and providing the availability oi other valve lineups will climinate the need for manual actions in these fire areas when the new switchgear room is completed.

2. The method used to provide emergency lighting during the inspection consisted of flashlights and lanterns to accomplish the manual actions in fire zones A-1B, A-lC and R-1. All other areas had permanently installed D.C. lighting units.

a. Generic letter GL-36-10 specifies that requirements for emergency lighting be in accordance with IES guidelines and the ability of an operator to perform the intended tasks.

(4) 3. F. Opeka letter to S. D. Ebneter, dated August 29,1986, "Haddam Neck Plant Response to I&E Inspection No. 50-213/86-17."

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, b. The IES guidelines clearly recognize the use of portable emergency D.C. lighting to perform tasks. This is the basis for the determination to utilize portable lighting as an interim measure in these areas.

c. The portable lanterns have been randomly tested ' )r illumination and duration and were found to be equivalent to the fixed lighting.

d. Utilizing the portable lights, our Human Factors Engineering staff has evaluated operators' ability to safely and efficiently perform the required tasks and determined that no problems exist.

e. In addition to the fixed emergency D.C. lighting system, 14 portable battery powered emergency lanterns are distrib1ted throughout the plant. The reliability of these units is assured by a monthly preventative maintenance procedure. If an operator had to deviate from a planned pathway or perform a task on an interim bases, these lanterns would be utilized.

3. To ensure the availability of emergency lighting and to enhance lighting levels in these areas, additional portable lighting units have been stationed in fire zones A-1B, A-IC and additional emergency lighting fixtures (quartz and incandescent) will be added to R-1 when the additional instrumentation unit is added. The emergency lighting fixtures in the cable vault (R-1) will be powered by a portable generator and will be mounted to the portable instrument cabinet. The fixtures will provide light to support connection and reading of temporary instruments. Work progression is consistent with the January 1,1987 schedule.

4. CYAPCO has made a commitment to establish a fixed D.C. emergency lighting system. To date, $750,000 has been spent establishing this system. It is estimated that an additional $50,000 would have to be spent to provide fixed D.C. lighting in fire zones A-1B, A-IC and R-1 on an interim basis.

In CYAPCO's letter to the NRC dated August 19,1986,(3) CYAPCO provided the NRC Staff with the status of 13 action items resulting from the June 1986 Appendix R inspection. One of the items addressed was radio communications to be used in the event of a fire within the plant. The letter stated that in the event of a fire within the plant, the plant operators and fire brigade will switch to channel F1 and security will utilize channel F2 which will provide reliable communications throughout the plant with systems that have back-up emergency power. Both channels F1 and F2 will provide reliable communications throughout the plant; however, while channel F2 has the security emergency generator as a back-up emergency power supply, channel F1 has no back-up emergency power supply. Channel F1 utilizes a 75 watt repeater on Jenks Hill and its power supply is independent of site power. Therefore, a fire within the plant will not interrupt the power supply to channel F1.

In a letter dated August 29, 1986,(4) CYAPCO submitted a reply to a deviation resulting from the June 1986 Appendix R inspection. The deviation involved a previous commitment of September 1985 to lock open breakers for valves RC-MOV-510, RC-MOV-515, RC-MOV-528, and RC-MOV-577.

, The reply noted that the four breakers were de-energized (racked out) as of August 14, 1985 and were checked weekly by the Operations Department in accordance with Normal Operating Procedure 2.16-1. This action was sufficient to address the safety concern; however, immediate corrective action was taken and the breakers were locked open. CYAPCO also concurred with the NRC Staff that failure to lock the racked-out breakers was not a violation of Appendix R but simply a deviation from a commitment. CYAPCO modified its September 16, 1986 commitment to have the breakers locked open and informed the NRC Staff that unless a different agreement was reached during the September 3, 1986 management meeting, CYAPCO planned to remove the locks for the subject breakers during September,1986. This is to inform the NRC Staff that, subsequent to the September 3, 1986 management -meeting, CYAPCO has removed the locks from the subj,ect breakers in accordance with the modified commitment of August 29,1986.W)

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

., b.b J. F. Opeka '

Senior Vice President

, D ,

By: C. F. Sears Vice President cc: Dr. T.E. Murley A.G. Krasopoulous

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