ML20205J833
| ML20205J833 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/07/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20205J827 | List: |
| References | |
| NUDOCS 9904120211 | |
| Download: ML20205J833 (4) | |
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4 UNITED STATES j
,j NUCLEAR REGULATORY COMMISSION
't WASHINGTON, D.C. 20555-0001
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR PEGULATION NGARDING LICENSEE REQUEST FOR EXEMPTION FROM SECTION til.J OF APPENDIX R TO 10 CFR PART 50 C2LVfRT CLIFFS NUCLEAR POWER PLANT. UNIT NOS.1 AND_2_
DOCKET NOS. 50-317 AND 50-318
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1.0 INTRODUCTION
Appendix R, " Fire Protection Program for Nuclear Power Facilities Operating Prior to Janusry 1,1979," to Title 'i0 of the Code of Federal Reaulations (10 CFR) Part 50, establishesn fire protection features required to satisfy General Design Criterion 3, " Fire protection," of Appendix A to 10 CFR Part 50 with respect to certain generic issues for r:uclear power plants licensed to operate prior to January 1,1979. Calvert Cliffs Nuclear Power Plant Unit 1 was licensed to operate on July 31,1974, and Unit 2 was licensed to operate on November 30,1976. By letter dated October 6,1997, as supplemented by letter dated July 22,1998, Baltimore Gas and Electric Company, the licensee for Calvert Cliffs Nuclear Power Plant, requested an exemption from certain technical requirements of Appendix R.
2.0 EXEMPTION REQUESTED The licensee requested exemptions from certain technical requirements of Section ill J,
" Emergency lighting," of Appendix R to 10 CFR Part 50 to the extent that it requires e at Emergency lighting units with at least an 8-hour battery supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
Specifically, the licensee requested the following exemptions:
- 1. To credit security lighting, required by 10 CFR 73.55, powered by the security emergency diesel generator, for exterior lighting in lieu of 8-hour battery powered j
- lighting,
- 2. To use portable lights, powered by an 8-hour battery supply, for actions in high radiation areas, and;
- 3. To use helmet lantems inside of switchgear cabinets.
The popose of the Emergency lighting requirement was to aid the access to equipment and components that must be operated by plant personnel to effect safe plant shutdown during plant emergeticles. Cecause such emergencies may extend over a considerable amount of time, an 8-hour battery was required.
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2 3.0 DISCUSSION Section 50.48 of 10 CFR Part 50 specifiou that Section Ill.J of Appendix R applies to nuclear power plants that were licensed to operate prior to January 1,1979. Unit 1 of Calvert Cliffs Nuclear Power Plant was licensed to operate on July 31,1974, and Unit 2 was licensed to operate on November 30,1976. Therefore, Section Ill.J of Appendix R applies to Calvert Cliffs. Section ill.J of Appendix R specifies that Emergency lighting units with at least an 8-hour bcttery supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egrest mutes thereto.
The licensee proposal for the Emergency lighting does not meet the technical requirements of Appendix R because 8-hour battery supplied lighting is not provided in plant exterior areas, inside of electrical cabinets, or in high radiation areas.
4.0 EVALUATION The licentee stated that the security Eghting diesel and wiring was an independent, uninterruptible power supply. The secudty lighting system is backed by a sacurity emergency diesel gerierator that is located in a separate structure from o.her plant area buildings and would not be affected by a fire requiring safe shutdown. Yhe licensee stated that the diesel was maintained with a fuel supply greater than the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> required by Appendix R. Thc lighting requirements of 10 CFR Part 73, required to implement security requirements, provide sufficient illumination for exterior access and egress routes insW of the security protected area. The security lighting system provides an equivalent light r, for access and egress routes for exterior areas.
The licensee requested an exemption from the requirements of 10 CFR Part 50 Appendix R, Section lil.J for the limited activities requiring Emergency lighting in high radiation areas. The exemption was requested to reduce radiation exposure as low as reasonably achievable (ALARA) by eliminating Emergency lighting testing and maintenance in high radiation areas.
The licensee hand held lanterns have a wide base and are designed to be placed on the floor adjacent to the proposeo work activity. The position of the light will then be adjusted to provide illumination at the activity site. The lights are positioned in a controlled cabinet near the work activity, the lights are dedicated for Appendix R safe shutdown activities, and the ligho are periodically tested. The lights have an 8-hour capacity. Emergency lighting is provided on the access and egress routes to the cabinet which contains the portable lights and to the entrance to the high radiation areas. Activities requiring the use of the portable lantems are cold shutdown activities and are not time critical. The reduction of personnel radiation exposure i
from maintenance is in accordance with other NRC requirsments. The portable lantems would provide an Ecceptab!e method for providing Emergency lighting, as described by the licensee, in locked high radiation areanh."h require limited non-time critical safe shutdown activities.
The 1; censes proposed using helmet lantems for operators to use inside electrical cabinets.
Insumcient space exists within some electrical cabinets to in?hl an 8-hour battery pack Eght.
Emergency lighting units installed outside of the cabinet may not provide adequate lighting to the activity inside of the cabinet due to shadows cast by the operator. Activities performed inside of the cabinets requiring the use of helmet '.inhts are limited to pulling fuses to isolate the cabinet from fire effects. The helmet lights are stored inside of the Appendix R Safe Shutdown
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.. Locker for each unit. This locker also contains the safe shutdown procedures and the locker is the first stop for the operators upon control room evacuation. The helmet mounted lights consist of a light head attached to a wide rubber band that is placed around a hardhat. A belt with two attached battery packs (each weighing about one pound) and a connector to attach
- the lamps to the battery completes the assembly. The helmet tantems for pulling fuses inside of electrical switchgear, as descrioed by the licensee, will provide an adequate method of providing adequate illumination to accomplish the limited activity.
5.0 CONCLUSION
The underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J is to ensure that adequate lighting is available to aid the operater for an extended time during plant fire emergencies. Inside of electrical cabine3, where installation of 8-hours battery supplied lighting is not achievable, the helmet lights and exterior 8-hour lights accomplish the purpose of achieving adequate Emergency lighting. Forlimited activities inside of normally locked high
- radiation areas, the iicensee would provide 8-hour battery supplied portable lighting, for exterior lighting the licensee provides adequate lighting using a system required by NRC regulations for security.
On the basis of its evaluation, the staff concluded that the security lighting, portable lighting, and helmet lights, as described by the licensee satisfy the underlying purpose of 10 CFR Part 50, Appndix R, Section Ill.J to provide 8-hour lighting to aid access to equipment during plant emergencies. Therefore, the licensee's request for an exemption from full compliance with Section Ill.J of Appendix R to 10 CFR Part 50, as described ebove, should be granted.
Principal Contributor. P. Qualis j
Date: April 7,1999 -
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I DISTRIFUTim:
M PDI-1.R/F S.Rajwa S. Little yj 7, jg,
i A. Ihrer1ck OCC MEMORANDUM TO:
Rules and Directives Eranch Division of Administrative Services.
j Office of Administration
- FROM:
Office of Nuclear Reactor Regulation SUSJECT:
EX9 film FPIN Bf REUJIDrJENTS (F 10 (7R PART r;0, AoM'ffny 9, 9r Tim i17.3*
EFERENCY LimTifE - CN.NERT Q.IFFS firtIAR Pr1{R PLNfT, IP!IT fr$.1 #D 2 (TAC tOS. f 90791 #D fM792)
One signed original of the Federal Register Notice identified below is attached for your transmittal to the Office of the Federal Register for publication.- Additional conformed copies ( 5
) of the j
Notica are enciosed for your use.
Notice of Receipt of Application for' Construction Permit (s) and Operating License (s).
Notice of Receipt of Partial Application for Construction Permit (s) and Facility License (s):
Time for submission of Views on Antitrust matters.
Notice of Consideration of issuance of Amendment to Facility Operating License. (Call with
)
30-day insert date).
Notice of Receipt of Application for Facility License (s); Notice of Availability of Applicant's Environmental Report; and Notice of Conside2ation of lasuance of Facility License (s) and Notice
- of Opportunity for Hearing.
. Notice of Availability of NRC Draft / Final Environmental Statement.
Notice of Limited Work Authorization.
Nof. ice of Availability of Safety Evaluation Report.
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, Notice of lasuance of Construction Permit (s).
C Notice of issuance of Facility Operat!ag License (s) or Amendment (s).
' Order.
]
8 Exemption.
)
C Notice of Granting Exemption.
Environmental Assessment.
q C Notice of Preparation of Environmental Assessment.
Receipt of Petition for Director's Decision Under 10 CFR z.206.
Issuance of Final Director's Decision Under 10 CFR 2.206.
i Other:
I DOCKET NO. 50-57 md 50-318 S
j Attachment (s): As stated
Contact:
M Little Telephone:4te;.pnpc;
' DOCUMENT NAME:
. Ta rective e copy of this docurnent, indicate in the box:
"C' = Copy without ettschmentjenclosurs
- E* = Copy with attachment / enclosure
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OFFICE on u A All l l
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NAME-Ott3@4 I
DATE 4/ r7l99 1_
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' OFFICIAL RECORD COPY