ML20137E345
| ML20137E345 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/23/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20137E329 | List: |
| References | |
| NUDOCS 9703270161 | |
| Download: ML20137E345 (2) | |
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UNITED STATES p
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NUCLEAR REGULATORY COMMISSION j
e, WASHINGTON, D.C. 30006 4001 i
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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EXEMPTION RELATED TO 10 CFR PART 50. APPENDIX R. SECTION III.J EMERGENCY LIGHTING l
l VERMONT YANKEE NUCLEAR POWER CORPORATION j
VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 l
1.0 INTRODUCTION
I By letter dated June 17, 1996, Vermont Yankee Nuclear Power Corporation (the l
licensee) requested exemption from the requirements of 10 CFR Part 50, i
i Appendix R,Section III.J, " Emergency Lighting." This section requires that j
" Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and 1
in access and egress routes thereto." The requested exemption would allow the l
use of existing security lighting in lieu of additional 8-hour battery powered i
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lighting in specified outdoor areas of the pl. ant.
2.0 DISCUSSION l
i 2.1 Exemotion Reauest j
2.1.1 Licensee's Basis for Reauestina Exemotion l
The licensee has identified a task which an operator may be required to perform outdoors in either of two areas.
If this occurs the operator must 4
also move outdoors to and from these areas. The action it, the alignment of equipment to provide a long term source of nitrogen beyond the capacity of the safety relief valve (SRV) accumulators. The need for this action arises for l
certain Appendix R fire scenarios whose safe shutdown strategy does not 4
immediately depressurize the reactor and uses low pressure injections systems, and the SRV's are actuated multiple times during cooldown. A long term source of nitrogen, beyond the capacity of the SRV accumulators, is required to i
4 provide multiple valve strokes. The nitrogen may be provided from either of two outdoor locations: 1 the 15,000 gallon liquid nitrogen containment i
inerting tank located ea)t of the reactor building, or 2) nitrogen storage i
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bottles located on the west wall of the reactor building equipment air lock.
Both areas are well lit with existing security lighting. Walking to and from these areas can be accomplished safely because of the illumination provided by j
the security lighting along the perimeter of the protected area.
I 9703270161 970321 DR ADOCK 05000271 PDR i
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Plant security lighting is supplied from a backup power source. This power i
supply is not vulnerable to a fire that 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.
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2.1.2 Evaluation l
The licensee proposes to use the existing security lighting for a portion of 1
outdoor access and egress routes and for tasks performed in either of two j
locations. The licensee has justified the requested exemption based on the adequacy of the alternative lighting to satisfy the underlying purpose of the regulation. The technical requirements of Section III.J are not met in the above-referenced locations because 8-hour battery powered emergency lighting units have not been provided where manual actions are required for safe j
shutdown and in routes of travel to and from these areas.
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The licensee demonstrated that the fires that result in the need to take the i
described actions in the areas covered by the existing security lighting would not cause loss of that lighting. This lighting is powered from a separate
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power source and is not vulnerable to fire loss under the postulated fire scenarios.
The licensee confirmed the adequacy of the illumination levels in the affected areas by direct measurement using the criteria of 10 CFR 73.55(c)(5). This provides reasonable assurance that the safe shutdown function could be achieved. This lighting is inspected and maintained as part of the plant security requirements.
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Based on the above evaluation, the staff considers the licensee's alternate
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lighting configuration to be equivalent to that achieved by conformance with j
Appendix R to 10 CFR Part 50. Application of the regulation in these j
circumstances is not necessary to achieve the underlying purpose of the rule.
3.0 CONCLUSION
i The staff concludes that the requested exemption from the emergency lighting requirements of 10 CFR Part 50, Appendix R,Section III.J, is authorized by i.
law, will not present an undue risk to the public health and safety, and is i
consistent with the conson defense and security. Application of the regulation in these circumstances is not necessary to achieve the underlying i
l purpose of the rule. Therefore the exemption is approved.
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Principal Contributor:
V. L. Rooney
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Date: March 23, 1997 i
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