ML20214D524
| ML20214D524 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/19/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 5211-56-2197, NUDOCS 8611240125 | |
| Download: ML20214D524 (2) | |
Text
--
6 Nuclear Eues =" "
Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 November 19,19ggws Duect Dial men 5211-86-2197 Office of Nuclear Reactor Regulation Attn:
J. F. Stolz, Director PWR Projects Directorate No. 6 U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Stolz:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 10 CFR 50 Appendix R - Emergency Lighting GPUN hereby withdraws the exemption request to 10 CFR 50 Appendix R Section III.J regarding emergency lighting outside of reactor building containment as outlined in GPUN letter to NRC, dated August 19, 1986, (5211-86-2143). GPUN will install fixed 8-hour battery powered emergency lighting for access and egress routes as well as at manual work stations outside the reactor building contai nment. These fixed 8-hour battery powered lighting units will be supplemented by 8-hour battery powered portable hand-held emergency lights in accordance with TMI-l commitment to NRC Branch Technical Position APCSB 9.5-1 as documented in the TMI-1 Fire Hazards Analysis Report, Revision 7, page 5-29, position D.5 (b).
GPUN still requests exemption from 10 CFR 50 Appendix R, Section III.J for emergency lighting inside the reactor building containment, as previously submitted in GPUN letter to NRC dated August 19, 1986, (5211-86-2143). Access to the reactor building containment within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is required only for a fire which causes spurious operation of one of three normally open valves, located in zone RB-FZ-lc, associated with the reactor coolant letdown cooler in operation.
Such a fire could potentially prevent alignment of the redundant valves and letdown cooler in the same fire zone. Manual realignment is required within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to reestablish reactor coolant letdown. We feel that
+
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides sufficient time for trained operators to gain access to and mm manually realign these valves in an orderly fashion utilizing 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered portable lighting. Portable lights dedicated for this purpose will be ao administratively controlled and maintained at the entrance of the reactor building containment.
y Reactor building containment entry would be a planned activity by at least two ao operators to perform the above task, if required.
Therefore, the operators N
could carry enough lighting units to complete the manual operation. The portable lighting units will provide adequate illumination levels at the work station as they could be held by one operator to illuminate the required valve
-m&
location while the other operator would be able to perform the manual actions poh with both hands, GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
5211-86-2197 November 19, 1986 In addition, the installation of fixed emergency lighting inside containment would present an undue burden to the plant operators to maintain these units in accordance with the existing preventive maintenance program.
Use of portable lighting would eliminate personnel exposures received during maintenance and surveillance of installed fixed emergency lights, which is consistent with ALARA program objectives.
Inaccessibility during normal operation reduces the reliability of fixed lighting units inside containment.
Radiation degradation of the battery enclosure installed inside containment could lead to leakage or rupture over a period of time. Also, battery packs are not qualified to postulated accident temperature and pressure inside containment and therefore could introduce hazardous material such as battery acid which would increase hydrogen generation and also pose a potential threat to cables and other components.
Installation of battery powered lighting inside containment will not significantly enhance the level of post-fire shutdown capability and its omission will not endanger the health and safety of the public.
We trust that this additional information clariffes the justification for the exemption request for use of portable lighting in lieu of fixed lighting units inside the Reactor Building as previously submitted in GPUN letter to NRC dated August 19, 1986, (5211-86-2143). Please note that a check in the amount of $160.00 has been forwarded via GPUN letter to NRC dated September 11, 1986 (5211-86-2158) for this exemption request.
Sincerely, H. D. Hukill Vice President & Director, TMI-l HDH:DJD:ng 0712A cc:
J. Thoma, USNRC J. Rogers, USNRC, Region I, TMI-l Site D. Kubicki, USNRC, PEISCB A. Krasopoulos, USNRC, Region I l
i i
l
_