ML16342C925
| ML16342C925 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/05/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML16342C923 | List: |
| References | |
| NUDOCS 9505110287 | |
| Download: ML16342C925 (10) | |
Text
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~o Cy A.0 UNITED STATES NUCLEAR REGULATORY COMIVIISSION RELATED TO RE UEST FOR EXEMPTION FRO CERTAIN TECHNICAL RE UIREMENTS OF APPENDIX R TO 10 CFR PART 50 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT UNITS 1
AND 2 DOCKET NOS.
50-275 AND 50-323 O
WASHINGTON, D.C. 20555-0001
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S F TY VALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
- 1. 0 INTRODUCTION By letters dated March 15,
- 1994, and Hay 25, 1994, Pacific Gas and Electric Company (PG&E), requested an exemption from the technical requirements of Section III.J of Appendix R to Part 50 of Title 10 of the Code of Federal
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RIDDPRP DDPP Dltl 5
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Pl,ylt and 2 (DCPP).
Section III.J of Appendix R requires that emergency lighting units with at least an 8-hour battery power supply be provided for the access and egress routes to all areas needed for the operation of safe shutdown equipment.
By letters dated March 2,
- 1983, and July 15,
- 1983, PG&E committed to meet the technical requirements of Sections III.G, III.J, III.L, and III.O of Appendix R.
Therefore, the staff treated your exemption request as a
deviation from your commitment to meet Section III.J of Appendix R.
Your exemption request will hereafter be referred to as "deviation request."
Specifically, you requested approval to use procedurally-controlled hand-held portable lights (flashlights) rather than fixed emergency lights for certain access and egress routes for the remainder of plant operation.
Your letter of March 15,
- 1994, also stated that PG&E considered the deviation request a cost beneficial licensing action as defined in T, E. Hurley s memorandum of September 17, 1993, to the U.S. Nuclear Regulatory Commission (NRC) technical staff.
2.0 BACKGROUND
In December 1990, during its Appendix R Design Basis Documentation Enhancement Project and a self-assessment of the DCPP fire hazards safe shutdown analysis, the licensee found emergency lighting deficiencies in a number of plant areas.
In its submittal of Harch 15,
- 1994, the licensee stated that it would install permanent emergency lighting in areas where illumination is needed for operator actions or for obstructed areas along access/egress pathways during the next refueling outage for each unit (1R6 (3/12/94 to 5/7/94) and 2R6 (9/24/94 to 11/4/94)).
In addition, the licensee stated that it had implemented compensatory measures while permanent lights are being installed.
In its submittal of March 15, 1994, the licensee also stated that it had determined that permanently installed lights are not necessary for certain access and egress pathways to achieve the underlying purpose or intent of Appendix R to 10 CFR Part 50.
Therefore, the licensee submitted the subject 9505XX'OV87 950505 F PDR ADOCK 05000275 P
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deviation request.
In that submittal, the licensee stated that it had implemented the use of flashlights as a compensatory measure for the pathways while the deviation request was under staff review.
In its submittal of May 25, 1994, the licensee increased the number of access and egress pathways for which it was requesting a deviation.
The staff discussed the deviation request with the licensee during telephone conversations on June 14,
- 1994, and August 16, 1994.
In addition, the staff visited DCPP during the week of March 27,
- 1995, and walked down most of the access and egress routes for which a deviation was requested.
3.0 DEVIATION RE VESTED The licensee requested a deviation from the technical requirements of Section III.J of Appendix R to 10 CFR Part 50 to the extent that it requires that emergency lighting units with at least an 8-hour battery power supply be provided in access and egress routes to areas needed for operation of safe shutdown equipment.
The licensee identified the specific access and egress routes in revised Table 1 of its letter of May 25, 1994.
- 4. 0 EVALUATION The staff based its evaluation of the subject deviation request on its reviews of the licensee's letters of March 15,
- 1994, and May 25, 1994, telephone calls with the licensee on June 14,
- 1994, and August 16,
- 1994, walkdowns during a
site visit to DCPP during the week of March 27,
- 1995, and consideration of previously-approved emergency lighting deviations for DCPP and other operating reactors.
- 4. 1 Plant-S ecific Considerations The proposed deviation was requested for certain access and egress pathways from the DCPP control room to fire areas and zones where operators must perform post-fire manual actions to achieve safe shutdown in the event of a fire.
Mith the exception of one outdoor pathway at the 140-foot level of the auxiliary building, the pathways are interior to the auxiliary, fuel handling, and turbine buildings.
The pathways encompass doorways, corridors, and stairwells.
The technical requirements of Section III.J are not met in these access and egress routes because they lack 8-hour battery-operated emergency lighting units.
The licensee proposed to use procedurally-controlled hand-held portable lights (flashlights) in these access and egress pathways rather than emergency lighting units.
The licensee did not submit a technical basis for the deviation request.
- Rather, the licensee stated that the deviation is consistent with the intent of Section III.J of Appendix R and is based on the presence of particular circumstances at DCPP.
In addition, the licensee contended that compliance with Section III.J would present undue hardship and costs significantly in excess of those expected when Appendix R was implemented.
In its letter of March 15, 1994, the licensee stated that the following circumstances at DCPP allow the use of flashlights:
(1) emergency procedures
specify that flashlights may be needed for access and egress, (2) the flashlights will be dedicated and procedurally controlled, (3) the use of flashlights will not pose an additional burden on the operators, (4) the flashlights will provide sufficient duration of emergency lighting because they will be on only during periods of access and egress, and (5) the flashlights will reveal minor obstruction in the pathways.
The staff discussed the circumstances with the licensee during telephone conferences on June 14,
- 1994, and August 16,
- 1994, and during the site visit to DCPP during the week of March 27, 1995.
The staff concluded that these five circumstances which the licensee identified exist at DCPP.
However, the circumstances are not unique to DCPP.
Acceptance of these circumstances as justification for the subject deviation request would be tantamount to generic approval to use flashlights rather than fixed emergency lighting units for many access and egress routes at DCPP or any nuclear power plant.
With respect to the specific circumstances, the staff concluded that the need to obtain flashlights prior to control room evacuation and to carry and use the flashlights under the stressful and unusual conditions of a fire emergency would place burdens on'he plant operators that Section III.J of Appendix R
specifically intended to preclude (see Section 4.2 below).
One significant objective of fixed emergency lighting units is to provide direction to the operators if electrical power is lost as a result of a fire and to provide reasonable assurance that operators will not become disoriented, particularly in stairwells and at doorways and intersecting corridors.
The presence of fixed emergency lighting in some routes, but not all routes, which is the current configuration at DCPP, could contribute to operator confusion and impact the timely completion of manual operator actions.
In addition, the beam of a flashlight cannot provide light coverage and illumination levels equivalent to that of fixed emergency lighting.
Depending on the direction of the flashlight beam, the operator may not observe obstructions created by fire brigade or other activities that can be related or unrelated to the fire emergency that would not normally be present in the pathway.
Such obstructions would be obvious if fixed emergency lighting is available.
Failure to obtain proper dir ection or to observe obstructions could impede operator access to or egress from areas needed to manually operate or check post-fire safe shutdown equipment.
It is not possible to predict the specific conditions under which fires may occur and propagate.
Therefore, it is not possible to predict how much time the operators will spend in access and egress pathways that do not contain fixed lighting.
Thus, the flashlight batteries may not be sufficient to cover these periods of time.
In addition, because a flashlight is not a fixed plant
- feature, there is no reasonable assurance that it would remain in the possession of the operator and remain functional throughout the fire event.
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4.2 Other Considerations In its letter of March 15, 1994, the licensee stated that the staff had previously approved similar emergency lighting deviations for DCPP in Supplemental Safety Evaluation Reports (SSERs) 23 and 31.
The staff reviewed these SSERs and found that it did not approve the use of flashlights.
Therefore, the staff has not approved similar emergency lighting deviations at DCPP.
The staff did, however, approve the use of alternative fixed emergency lighting, rather than 8-hour battery powered emergency lighting, on the basis of the results of an analysis regarding the effects of fire on the alternative DCPP lighting system.
The analysis demonstrated that in the event of a fire, emergency lighting would be available in all necessary DCPP areas, including access and egress routes.
The licensee did not submit a similar analysis with its deviation request of March 15, 1994.
During telephone conversations on June 14,
- 1994, and August 16,
- 1994, the licensee informed the staff that it had not performed such an analysis to provide a technical basis for the subject deviation request and that it would not perform such an analysis.
Therefore, although the licensee has stated that fixed lighting is available in some of the affected access and egress
- pathways, the staff does not have assur ance that the existing lighting will be available in the event of a fire.
As part of its review of the licensee's deviation request, the staff also surveyed a number of emergency lighting exemptions/deviations that it had previously approved for other operating reactors.
The staff found that it has approved exemptions/deviations to Section III.J of Appendix R on the basis of the availability of alternative fixed lighting (similar to that approved in DCPP SSERs 23 and 31).
The staff has also accepted the use of lighting units with less than an 8-hour battery power supply and portable hand-held lights on a limited basis.
During telephone calls with the licensee on June 14,
- 1994, and August 16,
- 1994, the staff discussed with the licensee its previously-approved emergency lighting exemptions/deviations.
Later, during its site visit of March 1995, with the exception of the fuel handling building, the staff walked down the access and egress pathways that are the subject of the licensee's deviation request of March 15, 1994.
During the walkdowns, the staff confirmed that the licensee's deviation request is different from these previously-approved exemptions/deviations.
In its letter of March 15, 1994, the licensee stated that permanently installed lights are not necessary for access and egress pathways to achieve the underlying purpose or intent of Appendix R to 10 CFR Part 50.
The Commission provided its technical bases for fixed 8-hour battery emergency units capability in the Statement of Considerations (SOC) for Appendix R
(Fede al Re ister, Vol. 45, No. 225, November 19, 1980).
The Commission
- stated, in part:
Lighting units with 8-hour battery supplies are to be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
The reasoning behind the requirement for 8-hour battery power supply is that there can be a
great deal of other activity during a fire emergency and operators involved in safe plant shutdown should not also have to be
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concerned with lighting in the area.
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~ The Commission has decided to require an 8-hour battery power supply in all areas needed fo operation of safe shutdown equipment and in access and egress routes.
It is clear from the SOC that the underlying purpose and intent of Section III' of Appendix R is to provide fixed emergency lighting units of sufficient duration to eliminate the availability of a light source as an element requiring operator consideration when responding to a fire emergency that requires plant shutdowns It is also clear that the alternative proposed by the licensee, i.e., flashlights, does not satisfy this purpose or intent In its letter of March 15,
- 1994, the licensee also contended that the installation of permanent lighting and routing of associated cabling would result in undue hardship and a cost significantly in excess of that expected when Appendix R was implemented.
The licensee did not provide justifications or bases for these positions'ection III' is one of three sections of Appendix R that the Commission retroactively applied to those facilities licensed prior to January 1,
1979, for the protection it afforded over and above that previously accepted by the staff.
The Commission followed the backfitting regulations 5.0 CONCLUSIO On the basis of its evaluation, the staff has concluded that the licensee has not provided an adequate technical justification for the proposed deviation on a permanent basis.
The staff also has concluded that the use of flashlights for the access and egress routes identified by the licensee in revised Table 1
of its submittal of Hay 25, 1995, will not provide a level of safety equivalent to that provided by complying with the technical requirements of Section III.J of Appendix R to 10 CFR Part 50 over the long term.
Therefore the staff denies the licensee's request for a deviation from Section III.J of Appendix R to 10 CFR Part 50
'rincipal Contributor:
A. Singh Date:
May 5, i995
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