Information Notice 1995-36, Potential Problems with Post-Fire Emergency Lighting

Potential Problems with Post-Fire Emergency Lighting

ML031060286
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	08/29/1995
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:
References
IN-95-036, NUDOCS 9508220302
Download: ML031060286 (13)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 August 29, 1995 NRC INFORMATION NOTICE 95-36: POTENTIAL PROBLEMS WITH POST-FIRE EMERGENCY

LIGHTING

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice (IN)to alert addressees to potential problems regarding emergency

lighting for plant areas needed for operation of post-fire safe shutdown

equipment and in access and egress routes thereto. It is expected that

recipients will review the information for applicability to their facilities

and consider actions as appropriate. However, suggestions contained in this

information notice are not NRC requirements; therefore, no specific action or

written response is required.

Description of Circumstances

Several licensees have reported problems regarding post-fire emergency

lighting. The most recent example is herein described. Additional examples

are described in Attachment 1. In Licensee Event Report (LER)94-034, dated

December 12, 1994, and Revision 1, dated February 8, 1995, Nebraska Public

Power District, the licensee for Cooper Nuclear Station, reported problems

with the batteries, lamps, and battery charger circuit boards associated with

emergency lights that were installed to satisfy the technical requirements of

Section III.J, "Emergency Lighting," of Appendix R to Part 50 of Title 10 of

the Code of Federal Regulations (10 CFR Part 50). Specifically, the licensee

reported that (1) it did not consider the effect of temperature in the

performance or in the life of the batteries, (2) the existing maintenance

program did not ensure that the lamps had a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of life

remaining after completion of the functionality test, and (3) the circuit

control boards for trickle charging may be undercharging or overcharging the

batteries. As a result of these conditions, the licensee determined that the

emergency lighting, as designed and maintained, would not fully satisfy design

requirements. The licensee attributed these deficiencies to inadequate

administrative controls on design and preventive maintenance practices. The

licensee initiated corrective actions that included a review of the design

basis for the emergency lighting system and replacement of batteries, lamps, and charger circuit cards, where required. The licensee also conducted a test

to ensure that emergency lighting was adequate to support operator actions for

plant shutdown in the event of fire. As a result of the test, the licensee

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- August 29, 1995 added emergency lights in 14 areas and upgraded 21 other lights in order to

comply with Appendix R requirements. The licensee stated it would also revise

its plant procedures as needed to prevent recurrence.

In addition to the deficiencies reported by licensees, NRC inspections have

also uncovered emergency lighting deficiencies. For example, at South Texas

Project, Units 1 and 2, an inspector found inoperable indicating lights on

battery packs. This deficiency led the licensee to perform a comprehensive

walkdown inspection of the emergency lighting system, which uncovered a large

number of deficiencies. This inspection is documented in NRC Inspection

Report 50-498, 499/94-27, dated September 9, 1994.

Discussion

This notice alerts addressees to potential problems regarding emergency

lighting for plant areas needed for operation of post-fire safe shutdown

equipment and in access and egress routes thereto.

NRC requirements and guidelines for emergency lighting in the event of a fire

are contained in various documents including Appendix R, "Fire Protection

Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to

10 CFR Part 50; Appendix A to Branch Technical Position Auxiliary Power

Conversion Systems Branch, "Guidelines for Fire Protection for Nuclear Power

Plants Docketed Prior to July 1, 1976"; and NUREG-0800, "Standard Review

Plan." The extent to which these requirements or guidelines are applicable to

a specific nuclear power plant depends on plant age, commitments established

by the licensee in developing its fire protection plan, the staff safety

evaluation reports and supplements, and the license conditions pertaining to

the fire protection plan.

The objective of these requirements and guidelines for emergency lighting is

to ensure that in the event of a fire, plant personnel can access and operate

equipment and components that must be manually operated to effect safe plant

shutdown. Because such activities may extend over a considerable period of

time both during and after the fire, 8-hour battery emergency lighting

capability is specified to allow sufficient time for normal lighting to be

restored, with a margin for unanticipated events.

Related Generic Communications

The NRC issued IN 90-69, "Adequacy of Emergency and Essential Lighting," dated

October 31, 1990, to alert addressees to a possible problem concerning the

adequacy of emergency and essential lighting at commercial power reactor

facilities. IN 90-69 described how the failure of emergency lighting delayed

recovery from a reactor trip at Palo Verde Nuclear Generating Station, Unit 3.

IN 90-69 also discussed deficiencies in the maintenance and testing of

emergency lighting and emphasized the importance of adequate lighting

conditions.

IN 95-36 August 29, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

. Crut

C e r

Division of Reactor ogram Management

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachments:

1. Additional Examples of Licensee Reported Problems

Regarding Post-Fire Emergency Lighting

2. List of Recently Issued NRC Information Notices

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<> Attachment 1 IN 95-36 August 29, 1995 Vermont Yankee Nuclear Power Station (Vermont Yankee)

In LER 94-011, dated October 5, 1994, Vermont Yankee Nuclear Power

Corporation, the licensee for Vermont Yankee, reported that 8-hour battery- powered emergency lighting units required by Section III.J of Appendix R to

10 CFR Part 50 were not installed in several areas. The licensee attributed

this condition to its failure to properly identify all areas requiring post- fire safe shutdown lighting units. The licensee had not considered areas for

fire scenarios that do not require control room evacuation. Subsequently, in

LER 95-003, dated February 17, 1995, the licensee reported that while

reviewing procedures to ensure operator actions in response to cable vault or

control room fires, it discovered that the existing emergency lighting in the

intake structure did not meet the technical requirements of Section III.J of

Appendix R to 10 CFR Part 50. The licensee attributed this condition to a

lack of comprehensive review of an emergent issue and a lack of comprehensive

documentation of its Appendix R program. The corrective actions include (1)a

comprehensive walkdown inspection to ensure that appropriate emergency

lighting was provided; (2)the addition of emergency lighting units in the

areas in which, during a fire, shutdown would require manual action;

(3)review and evaluation of its processes to ensure that when new issues are

identified, they receive a comprehensive review to identify all areas and

programs to which they apply. The licensee also requested an exemption for

certain areas from the technical requirements of Section III.J on the basis

that existing security lighting satisfies the underlying safety objective.

The NRC staff will evaluate the exemption request.

Indian Point Nuclear Generating Unit No. 3 (IP3)

In LER 93-007, dated February 8, 1993, New York Power Authority, the licensee

for IP3, determined that two operator egress pathways did not have the 8-hour

battery-powered emergency lighting units required by Section I11.J of

Appendix R to 10 CFR Part 50. The licensee reported that it made erroneous

assumptions about operator pathways out of the control room in the event of a

fire and overlooked these two egress routes. The licensee revised the

modification procedures to include an assessment of Appendix R requirements

and revised its Appendix R operating procedures so that an assessment of

emergency lighting will be performed after procedure revisions and during

biannual reviews. Another event was reported by the licensee in LER 93-055, dated January 26, 1994 and Revision 1, dated July 21, 1994. The licensee

found that 1-1/2-hour emergency lights were installed in three areas in which

Appendix R requires at least an 8-hour battery power supply. The licensee

identified this error during an emergency lighting blackout test. According

to the licensee, the error occurred during installation of the lights and its

modification closeout process failed to recognize the deficiency. The

licensee changed the insufficient emergency lights to 8-hour emergency lights.

Other licensee actions included (1)a blackout test for fire scenarios that

require alternate shutdown, (2)a blackout test for fire scenarios that do not

require control room evacuation, and (3)a revision of the Modification

Control Manual Program to ensure that modifications comply with Appendix R

requirements.

KA> Attachment 1 IN 95-36 August 29, 1995 Washington Public Power Supply System Nuclear Project No. 2 (WNP-2)

In LER 92-018, dated May 28, 1992, Washington Public Power Supply System, the

licensee for WNP-2, reported that 8-hour battery-powered emergency lighting

units required by Appendix R to 10 CFR Part 50 were not installed in six areas

that would require manual operator actions for fire scenarios not requiring

control room evacuation. In addition, the licensee reported that it had

failed to incorporate into its procedures the operator actions that were

identified during followup reviews. The licensee attributed this oversight to

inadequate design and lack of interdepartmental communication. For corrective

actions, the licensee (1)added emergency lighting units in the six deficient

areas, (2)reviewed procedures to ensure that all operator actions required by

the plant shutdown analysis were addressed, and (3)evaluated the process by

which design information is incorporated into plant procedures.

Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon)

In LER 2-92-001-01, dated October 29, 1992, Pacific Gas and Electric Company, the licensee for Diablo Canyon, reported that it found a number of emergency

lighting deficiencies during its Appendix R Design-Basis Documentation

Enhancement Project and a self-assessment of the Diablo Canyon fire hazards

safe shutdown analysis. Later, in submittals of March 15, 1994, and

May 25, 1994, the licensee stated that it would install permanent emergency

lighting units in certain areas and requested an exemption from the technical

requirements of Section III.J of Appendix R for other areas. (Diablo Canyon

is not an Appendix R plant; therefore, the NRC staff treated the exemption

request as a deviation from a commitment to meet the requirements of

Section III.J of Appendix R.) On the basis of its evaluation of the

deviation, which included reviews of the licensee's submittals and walkdown

inspections during a site visit, the NRC staff concluded that the licensee did

not provide an adequate technical Justification for the proposed deviation.

The staff also concluded that the alternative proposed by the licensee (the

use of hand-held flashlights rather than fixed emergency lighting units) did

not provide a level of safety equivalent to that provided by Section III.J of

Appendix R to 10 CFR Part 50. The NRC staff transmitted its denial of the

deviation request and its safety evaluation to the licensee in a letter dated

May 5, 1995. By letter dated May 9, 1995, the licensee committed to install

battery-operated lights where required.

".z'achment 2 IN 95-36 August 29, 1995 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

95-35 Degraded Ability of 08/28/95 All holders of OLs or CPs

Steam Generators to for pressurized water

Remove Decay Heat by reactors (PWRs).

Natural Circulation

95-34 Air Actuator and Supply 08/25/95 All holders of OLs or CPs

Air Regulator Problems in for nuclear power reactors.

Copes-Vulcan Pressurizer

Power-Operated Relief Valves

93-83, Potential Loss of Spent 08/24/95 All holders of OLs or CPs

Supp. 1 Fuel Pool Cooling After a for nuclear power reactors.

Loss-of-Coolant Accident

or a Loss of Offsite Power

95-33 Switchgear Fire and 08/23/95 All holders of OLs or CPs

Partial Loss of Offsite for nuclear power reactors.

Power at Waterford

Generating Station, Unit 3

95-10, Potential for Loss of 08/11/95 All holders of OLs or CPs

Supp. 2 Automatic Engineered for nuclear power reactors.

Safety Features Actuation

95-32 Thermo-Lag 330-1 Flame 08/10/95 All holders of OLs or CPs

Spread Test Results for nuclear power reactors.

95-31 Motor-Operated Valve 08/09/95 All holders of OLs or CPs

Failure Caused by Stem for nuclear power reactors.

Protector Pipe Inter- ference

95-30 Susceptibility of Low- 08/03/95 All holders of OLs or CPs

Pressure Coolant Injection for nuclear power reactors.

and Core Spray Injection

Valves to Pressure Locking

94-66, Overspeed of Turbine- 06/16/95 All holders of OLs or CPs

Supp. 1 Driven Pumps Caused by for nuclear power reactors.

Binding in Stems of

Governor Valves

OL = Operating License

CP - Construction Permit

• 1A

K> IN 95-36 August 29, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Original signed by

Dennis M. Crutchfield, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachments:

1. Additional Examples of Licensee Reported Problems

Regarding Post-Fire Emergency Lighting

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: 95-36. IN

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August xx, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Dennis M. Crutchfield, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachments:

1. Additional Examples of Licensee Reported Problems

Regarding Post-Fire Emergency Lighting

2. List of Recently Issued NRC Information Notices

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one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Dennis M. Crutchfield, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachment:

List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\NKH\LIGHTING.IN

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June xx, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachment:

List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\NKH\LIGHTING.IN

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June xx, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachment:

List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\NKH\IGH~MTING.IN

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IN 95-XX

June XX, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate Office of Nuclear

Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Operating Reactor Support

Office of Nuclear Reactor Regulation

D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachment: 1. List of Recently Issued

NRC Information Notices

DOCUMENT NAME: G:\NKH\LIGHTING.IN

• See previous concurrence

'E' - Copy with attachment/enclosure 'N' = No copy

To receive a copy of this document, Indicate In the box: C, Copy without attachment/enclosure

OFFICE OECB/DOPS I TECH/ED I OECB/DOPS I /OECB/DOPS j D/DOPS I

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DATE c6 log /95 /95 _95 I /95 I _

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IN 95-XX

June xx, 1995 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contacts: D. Oudinot, NRR

(301) 415-3731 Neal K. Hunemuller, NRR

(301) 415-1152 Attachment:

List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\NKH\LIGHTIKG.DS

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NAME CMcCracken RKiessel AChaffee S

DATE I /95 / 95 1/ /95 1 /95 / /95 OFFICIAL RECORD COPY