ML20086B392
| ML20086B392 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/29/1995 |
| From: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-95-71, NUDOCS 9507050355 | |
| Download: ML20086B392 (3) | |
Text
{{#Wiki_filter:r T VERMONT: YANKEE NUCLEAR POWER CORPORATION 3 Ferry Road, Brattleboro, VT 05301-7002 ENGINEERING OFFICE (v $80 MAIN STREET BOLTON, M A 01740 (508) 779-6711 e June 29,1995 BW 95-71 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
References:
(a) License No. DPR-28 (Docket No. 50-271) (b) Letter, T.E. Murley, USNRC, to E.J. Mroczka, Connecticut Yankee Atomic Power Company, dated November 27,1987 (c) Letter, USNRC to WNPC, NW 89-137, dated June 26,1989 (d) Letter, WNPC to USNRC, BW 94-100, dated October 11,1994 (e) Letter, WNPC to USNRC, BW 94-107, dated November 3,1994 (f) Letter, WNPC to USNRC, BW 94-128, dated December 28,1994
Subject:
Revised Request for Exemption,10 CFR Part 50, Appendix R, Section Ill.J, " Emergency Lighting" In accordance with the provisions of 10 CFR Part 50.12, Vermont Yankee Nuclear Power Corporation hereby requests an exemption from the provisions of 10 CFR 50, Appendix R, Section Ill.J. " Emergency Lighting." Specifically, an exemption is requested from the requirement for lighting units, with eight-hour battery power supply, in outdoor areas. In addition, Vermont Yankee requests the withdrawal of a previously cpproved exemption from the requirements of 10 CFR 50, Appendix R, Section Ill.J, " Emergency Lighting." Specifically, we request withdrawal of an exemption for the use of emergency ac lighting in the Torus area of the Reactor Building. Please note that this revised exemption request supersedes Reference (f) in its entirety. Backaround: As outlined in References (d) and (e), Vermont Yankee recently identified that, in the event of a fire, emergency lighting units with eight-hour battery power supply were not provided in all areas requiring operation of safe shutdown equipment, and in access and egress routes thereto. With the exception of one location in the Reactor Building Torus area, Vermont Yankee had previously installed eight-hour battery powered emergency lighting in areas requiring action for alternate shutdown. An exemption was previously granted for use of Emergency Diesel Generator backed lighting for the location identified in the Torus area. Vermo'it Yankee has completed installation of additional eight-hour battery powered lighting units in allindoor areas of the plant where operator action is required, and in access and egress routes thereto. Some actions, however, must be performed outdoors, or require operators to traverse outdoor areas. In these areas, Vermont Yankee intends to make use of existing Security lighting. i With regard to Torus area !!ghting, new indoor lighting units have been installed that allow Vermont Yankee to meet the Appendix R r1guirements for Torus area lighting without an exemption. l }-{ 9507050355 950629 PDR ADOCK 05000271 p PDR o
4 VERMONT YANKEE NUCLEAR POWER CORPORATION I United States Nuclear Regulatory Commission June 29,1995 Page 2 4 Justification: Vermont Yankee has identified three actions which require an operator to proceed outdoors. One action involves the manual hookup of a portable fuel oil transfer pump. Portable pump fuel oil transfer is only required in the case of a Turbine Building fire which damages the control circuits for normal fuel oil transfer to the day tanks of the En,ergency Diesel Generators, or for a fire within the fuel oil transfer pump building. The procedure to estabilsh portable pump fuel oil transfer includes action outdoors, within the protected area of the plant. The area is well lit with existing Security lighting. Another outdoor action is at the Northwest Cooling Tower valve pit. Action in this area would be required if there were a fire in the intake Structure which disables the Service Water pumps. The procedure to establish alternate cooling involves valve manipulation at tne valve pit. Normal, as well as eight-hour battery powered lighting has been provided at the valve pit to permit operators to perform the necessary actions. Since the valve pit is located at the cooling tower, however, operators would either drive the vehicle designated for their use, or walk to the location. Walking can be accomplished safely because of the illumination provided by the Security lighting along the perimeter of the protected area. This has been confirmed by measurements of illumination levels utilizing the criteria contained in 10 CFR 73.55, Section (c)tSL The third action requiring operators to proceeo outdoors is for valve manipulation in the intake Structure. This action may be required for a fire in the Control Room Building or certain areas of the Reactor Building which causes delayed restart of the Service Water System. The procedure to prevent water hammer in the Service Water System involves walking outdoors to get to the intake Structure, and throttling the Service Water Pump discharge valves located within the intake Structure. Eight-hour battery powered lighting has been provided for the actions within the Intake Structure. As above, walking to the intake Structure can be safely accomplished because of the illumination provided by the Security lighting within ano along the perimeter of ) the protected area. Plant Security lighting is supplied from a backup power source. This power supply is not vulnerable to a fire which would necessitate the actions in the outdoor areas defined above. In addition, the Security lighting is inspected and maintained as part of plant security requirements. i Precedence has been established for use of Security lighting in lieu of eight-hour battery powered lighting in outdoor areas needed for safe shutdown and in access and egress routes thereto. Reference (b) provides details of an exemption granted to the Connecticut Yankee Atomic Power Company from the technical requirements of Section lil.J of Appendix R to 10 CFR Part 50. Vermont Yankee has completed installation of additional eight-hour battery supplied lighting units in all indoor areas of the plant where og erator action is required, anJ In access and egress routes thereto. As part of this effort, lights have been installed in the vicinity of valves RHR-38A and RHR-66 in the Torus area of the Reactor Building. These valves must be checked closed as part of our alternate shutdown procedure. Vermont Yankee has relied upon emergency ac lighting to provide the necessary illumination to perform this task. An exemption from the requirement for eight hour battery powered lighting was previously received, Reference (c). Vermont Yankee no longer relles upon the emergency ac lighting in the vicinity of these valves to meet the intent of 10 CFR 50, Appendix R, Section Ill.J. Spfcial Circumstances: Special Circumstances, as defined in 10 CFR Part 50.12,a(2)(ii), are present which warrant granting of an l exemption from the requirements of the regulation. By making use of existing Security lighting in outdoor { areas, Vermont Yankee believes that the underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J is achieved. The public health and safety is protected in a fashion equivalent to that resulting from compliance j with the specific requirements of the regulation, j
.1-VERMONT YANKEE NUCLEAR POWER CORPORAT ON United States Nuclear Regulatory Commission l June 29,1995 - Page 3
== Conclusion:== Based upon the technical justification and special circumstances detailed above, Vermont Yankee requests an exemption from the requirements of 10 CFR Part 50, Appendix R, Section lil.J " Emergency Lighting." The exemption is requested for the use of Security lighting for outdoor areas of the plant where operators may be required to perform safe shutdown actions, and in access and egress routes thereto. Vermont Yankee also requests withdrawal of a previously approved exemption from tne requirements of 10 CFR 50, Appendix R, Section lit.J, " Emergency Lighting." This exemption was approved for the use of emergency ac lighting in the Torus area of the Reactor Building. We trust that our request is acceptable; however, should you have any questions on this matter, please contact us. Sincerely, Vermont Yank Nuclear Power Corporation 5 ( e < ^Y o al' A. eld Vice President, Operations cc: USNRC Region i Administrator USNRC Resident inspector - VYNPS USNRC Project Manager-VYNPS a h t l .}}