ML20081F160
| ML20081F160 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/15/1995 |
| From: | William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IPN-95-037, IPN-95-37, NUDOCS 9503220016 | |
| Download: ML20081F160 (5) | |
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% 123 Main Gtreet E*1
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914 4814849 '
914 287G309(FAX) y N
E william J. cahill, Jr.
Chief Nuclear Othcer March 15,1995 IPN-95-037 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 1
Washington, DC 20555 l
Subject:
Indian Point 3 Nuclear Power Plant i
Docket No. 50-286 Revised Exemption from the Requirement for Battery i
Powered Emergency Lighting Units in the Yard Area Section_ilLJ_ofl9gendiaLR_to_10CEB50 i
References:
- 1. _ NYPA letter, J.C. Brons to S.A. Varga, NRC (IPN-85-29),
" Appendix R, Section Ill.J, Exemption for Battery Powered Ughts in the Yard Area," dated May 31,1985.
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- 2. NRC letter, S.A. Varga to J.C. Brons, NYPA, dated J'anuary 7,1987.
Dear Sir:
This letter requests a revision to an existing exemption (Reference 1) pertaining to the use of the security lighting system in the outside yard in lieu of self-contained 8-hour battery powered emergency lighting units. The revision will apply the exemption to additional j
activities performed in the outside yard area associated with certain Appendix R fire scenarios.
j By letter dated May 31,' 1985 (Reference 1), the Authority requested an exemption from the requirements of Section Ill.J of Appendix R to 10 CFR 50 to the extent that self-contained 8-hour battery powered emergency lighting units be installed in the yard area. The yard area contains access and egress routes to the Appendix R diesel generator, and its associated switchgear and equipment, that would require operator manual actions for certain fires in the plant. Technical justification for this requested exemption was the existence of an outside area security lighting system, which is powered from a dedicated propane powered generator, and installed in accordance with the requirements of 10 CFR 73.55(c)(5). The security lighting system provides adequate lighting of the yard area, and is as reliable as individual battery powered lighthig units.
By letter dated January 7,1987 (Reference 2), the staff approved this requested exemption. In Section 6.2 of the NRC's Safety Evaluation, which supported this exemption, c-the staff limited their consideration to the request as it was presented by the Authority; i.e.,
only local activities in the yard associated with the Appendix R diesel generator were addressed This is clearty shown by the first paragraph of Section 6.2 which states:
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"To effect and maintain safe shutdown under certain fire scenarios, the licensee has indicated that operators would need to start the alternate diesel generator locally as well as locally manipulate certain circuit breakers which provide the -
proper electrical bus alignment."
l A recent re-aaaaaament of Appendix R compliance at indian Point 3 determined that -
additional operator actions in the yard area' may be warranted under certain Appendix R fire scenarlos. This matter was discussed with the NRC staff during a telephone conference call on December 21,1994. Information given to the staff during that conference call was as follows:
1.
Level Indication for the Condensate Storage Tank (CST) and the Refueling Water i
Storage Tank (RWST)
The Authority's Appendix R review identified several scenarios where the water inventory of the RWST and the CST could be reduced due to spurious actuation of the containment spray pumps. The minimum water levels in the RWST and the -
CST are specified in the Technical Specifications. In the event of a spurious pump actuation, the operators would have ample time to manually shut off the containment spray pump, and maintain sufficient RWST and CST inventory to rupport safe shutdown However, the Authority has determined that it would be prudent for an operator to verify the water level in these tanks within the first hour, since a spurious operation may have reduced tank inventory below Technical Specification limits. The level gauges are inside a cabinet next to the tanks. This issue concems the lighting to read those gaugcs. In addition, if the fire event '
occurred during sub-freezing weather, and installed heat tracing was not operable, portable heaters could placed in the area to maintain the level gauges functional.
2.
Service Water Strainers The Authority's Appendix R review also determind that cables associated with the automatic strainers for both the normal and the back-up sen4ce water pumps may be damaged in certain fire scenarios. In addition, in cold weather there is the potential for instrument sensing lines to freeze if the heat tracing is lost. Therefore, the Authority has developed procedures for manually back-flushing the strainers, and for placing portable heaters. The normal Service Water Pump strainers are inside a structure and the Authority is in the process of installing permanent emergency lighting capability. However, the back-up Service Water Pumps, and their strainer, are outside. Self-contained 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> hattery powered emergency lighting units are not necessary since the area where the pumps and strainer are located is illuminated by j
the security lighting system.
All of these activities are performed in the outside yard area which is illuminated by the security lights. The Authority has confirmed that the security lighting system provides adequate illumination to read the RWST and CST gauges, to place portable heaters, and to operate the back-up service water strainers. As discussed in the previously granted exemption (Reference 2), the security lighting has a dedicated propane powered generator, and would provide lighting in excess of 8-hours during loss of off-site power. The security j
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e lighting generator is located in the security building which is physically separated from areas subject to the Appendix R evaluation. Therefore, an Appendix R fire will not impact the security lighting generator.
Therefore, please consider this request to amend the existing exemption pertaining to the use of security lighting system in the outside yard area, in lieu of self-contained 8-lwur i
battery powered emergency lighting units, to include the additional activities specified above.
i This request satisfies the criteria of 10 CFR 50.12 as described in Attachment 1 to this letter.
If you have any questions, please contact Ms. C. D. Faison.
Very truly yours, William J.
r.
Chief Nuclear Officer i
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Attachment:
Evaluation Pursuant to 10 CFR 50.12 Criteria.
cc:
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511 Mr. Nicola F. Conicella, Proj. Manager Project Directorate 1-1 Division Of Reactor Projects 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14B2 Washington, DC 20555
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.,e 1:
7 Attachment I to IPN-95-037 Revised Exemption from the Requirement for Battery Powered '
j Emergency Lighting Units in the Yard Area Evaluation Pursuant to 10 CFR 50.12 Critaria The NRC approved (Reference 2) the Authority's exemption request (Reference 1) to the requirements of 10 CFR 50, Appendix R, Section Ill.J, that permits the use of the security.
lighting system in the outside yard in lieu of self-contained 8-hour battery powered emergency lighting units for a certain Appendix R activit/. The activity associated with the exemption
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involved manual operator actions at the Appendix R diesel generator and associated equipment during certain fires in the plant. As a result of a recent re-assessment of Appendix R compliance at Indian Point 3, the following additional operator actions in the yard area may be warranted for certain fire scenarios. These activities involve: (1) the reading of the Refueling Water Storage Tank (RWST) and Condensate Storage Tank (CST) level gauges, (2) the placement of portable heaters for freeze protection, and (3) the manual operation of the back-up Service Water Pump strainer.
Accordingly, the Authority requests that the previously referenced exemption be revised to include these additional outside yard activities to avoid the need to install self-contained 8-hour battery powered emergency lighting units to illuminate the areas of the yard where these activities will be pedormed.
Justification for Examotion
'i 10 CFR 50.12(a) states that the Nuclear Regulatory Commission may grant exemptions from -
the requirements of the regulations contained in 10 CFR 50 provided that:
The exemption is authorized by law; The exemption does not present an undue risk to the public health and safety; The exemption will not endanger the common defense and security; Special circumstances are present as defined in 10 CFR 50.12(a)(2).
The requested revision to the referenced exemption satisfies the 10 CFR 50.12 criteria as stated below:
1.
The requested exemption is authorized by law.
The Nuclear Regulatory Commission is authorized by law to grant this exemption, as evidenced by the granting of exemptions to selective requirements of Appendix R for Indian Point 3, and other plants, in the past.
' to IPN-95-037
- 10 CFR 50.12 Evaluation Page 2 of 2 II.
The requested exemption does not present an undue risk to the public health and safety.
The Authority has confirmed that the security lighting system provides adequate illumination to perform the additional activities mentioned, and to provide access and egress to the yard areas where the activities will be performed. The security lighting system is powered from a dedicated propane powered generator, and has sufficient capacity and fuel supply to power yard lighti.eg in excess of 8-hours during loss of off-site power. Consequently, the security lighting system is as reliable as individual battery powered lighting units. The security lighting generator is located in the security building which is physically separated from the area subject to the Appendix R evaluation.
Therefore, an Appendix R fire will not impact the security lighting generator.
Accordingly, reliance on the secudty lighting system in lieu of self-contained 8-hour battery powered emergency lighting units for illumination of the subject areas does not present an undue risk to the public health and safety.
Ill.
The requested exemption is consistent with the common defense and security.
The common defense and security are not affected by this request for exemption.
IV. Special circumstances are present which necessitate the request for an exemption.
The following special circumstance presented in 10 CFR 50.12(a)(2) applies to this exemption:
Circumstance (ii) states: " Application of the regulation in the particular circumstances would not serve the undertying purpose of the rule or is not necessary to achieve the undedying purpose of the rule."
10 CFR 50, Appendix R, Section Ill.J, requires emergency lighting for a period of eight hours in all areas needed for operation of safe shutdown equipment, and in access and egress routes thereto. The regulation is prescriptive in that it requires a battery powered supply. The security lighting system achieves the underlying purpose of the rule in that it provides adequate illumination to perform the previously mentioned activities in the outside yard for a period of at least eight hours, and is not impacted by fires in other areas of the plant for which Appendix R fires need to be considered.
Conclusion The Authority concludes that this request to revise a previous exemption is warranted under the provisions of 10 CFR 50.12, in that it does not present an undue risk to the public health and safety, and a "special circumstance" is present.
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