ML20215L658
| ML20215L658 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/21/1986 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | Tam P Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8610290232 | |
| Download: ML20215L658 (10) | |
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$,,9,*g,*,,,,p333o77.o004 October 21, 1986 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn:
Mr. Peter S. Tam, Project Manager Project Directorate No. 2 Division of PWR Licensing - A Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Appendix R - Emergency Lighting Gentlemen:
10 CFR 50, Appendix R, Section III.J requires emergency lighting units with at least an 8-hour battery powered supply shall be provided in areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
NRC Inspection Report No.
50-334/85-25 dated January 15, 1986 identified an unresolved item pending a
demonstration by the licensee that emergency lighting in the areas is adequate (Item 85-25-05).
A test of the emergency lights has been conducted and a summary of the results are attached as Enclosure I.
The results determined that sufficient lighting is available for the operation of safe shutdown equipment and the access / egress pathways to the equipment.
Based on the review, it was determined that some minor modifications such as relocating or adding lights were required to supplement the existing emergency lighting in these areas.
Table II of Enclosure I provides a summary list of these modifications, all of which have all been completed.
The use of portable lighting for specific locations of the plant have been identified by operations personnel as a result of the field walkdowns and are summarized in Table I of the enclosure.
The use of hand-held flashlights would supplement the existing 8-hour battery powered units or security perimeter lighting for all areas noted in Table I.
Based on the functions that would be performed for each
- area, the operator actions would accommodate the use of portable flashlights.
Justification is provided and the specific locations for the use of portable lighting has been incorporated in our previously submitted request for exemption 11.24
The revised exemption request is enclosed as supplement I which supersedes our previous January 21, 1986 submittal with the exception of Figures 11.24-1 through 5 which have not changed and need not be re-issued.
8610290232 861021 PDR ADOCK 05000334 II G
'B nver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 2 This exemption, if
- approved, would minimize the cost impact on DLC in fully meeting the technical requirements of Appendix R,Section III.J
for these situations.
The exemption achieves the Commission's purpose in providing safety benefits with minimal cost impact on licensees.
The cost savings is estimated in the range of $250,000 to $500,000.
Therefore, pursuant to 10CFR50.12, DLC requests an exemption from the specific requirements of Section III.J of Appendix R to 10CFR50 as delineated in the attached request for BVPS, Unit 1.
If there are any questions or clarifications in this matter, please contact my office.
Very truly yours,
.k.
21 b
- i J. D. Sieber Vice President Nuclear Operations cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U.
S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Dr. Thomas E. Murley, Regional Director Region 1 631 Park Avenue King of Prussia, PA 19406
ENCLOSURE I
SUMMARY
RESULTS OF APPENDIX R EMERGENCY LIGHTING TEST - BVPS UNIT I INTRODUCTION A
test was conducted to verify the adequacy of the emergency lighting installed per Section III.J of 10CFR50 Appendix R.
The test, which consisted of operations personnel performing field walk-downs and simulating the required actions identified in the alternate shutdown procedure (Operating Manual Chapter 56C), was conducted during the recently completed 5th refueling outage.
METHODOLOGY A
list of safe shutdown functions requiring operator actions was assembled from the alternate shutdown procedure and plant area drawings were marked with access / egress routes.
A licensed Senior Reactor Operator (SRO) and a
Startup Operator performed the field walkdowns.
The effectiveness of the emergency lighting was determined by the ability of the operators to perform their intended shutdown functions.
This is consistent with guidance provided in Generic Letter #86-10 (Section 4.1).
To simulate loss-of-light conditions due to loss of offsite power and fire damaged lighting
- circuits, the normal AC lighting and the 125 VDC Station Emergency Lighting circuits were de-energized for each area tested.
Only the battery-powered emergency lighting units were utilized.
For outside yard areas, the security perimeter lighting system which is supplied from the Security Diesel Generator was utilized, and the testing was conducted at night.
RESULTS It was determined that the emergency lighting was sufficient in nearly all areas for the operators to reach the required locations and perform their intended shutdown functions.
Some minor i
modifications such as relocating or adding lights were identified and these areas are summarized in Table II.
For each case, emergency lighting existed in the areas.
The operators identified a
few areas where the use of flashlights would aid in effectiveness and versatility.
These areas are summarized in Table I.
The specific locations for the use of portable lighting to supplement the existing emergency lighting are being incorporated into our previous Exemption Request submittal of January 21, 1986.
l s
TABLE I
Emergency Lighting Test Results Portable Lighting Recommendation List LOCATION FUNCTION Intake Structure Access / Egress pathway to Pump Cubicles and monitor river water pump operation in the A,
B C
cubicles.
Turbine Deck Access / Egress pathway to Turbine Pedestal and manually trip turbine, if necessary.
Primary Auxiliary Access / Egress pathways, identify Bldg. (PAB) valve positions and monitor Charging Pump operations.
Service Bldg. rooftop Access / Egress pathway to FW Reg.
to FW Reg. Valve Room Valve Room Normal 4KV Switchgear De-energize non-essential electrical Room, AE & DF Emergency equipment and switch off DC control Switchgear Rooms, and power.
Process Rack Room NOTE:
Use of portable hand-held flashlights would enhance the permanently installed 8-hour battery powered emergency lighting units for the above listed areas.
The operator actions are all hands-free activities (access / egress, observe a
- gauge, etc.) or actions that require one-hand (operate switch, etc.) which would accommodate use of flashlights.
Specific areas noted above will be added to our Exemption Request for use of portable lighting.
TABLE II Emergency Lighting Modifications Summary List LOCATION CORRECTIVE ACTIONS 1.
Main Steam Valve Room Install supplemental lighting in the area for manual operation of the Steam Generator atmospheric dump isolation valves and monitoring of steam pressure indication.
2.
PAB 722 area and Blender Install supplemental lighting to Room support manual valve operation.
3.
Quench Spray Pump Room Install supplemental lighting to support manual valve operation.
4.
Turbine Dock Install supplemental lighting to support operator actions.
5.
Intake Structure Relocate lighting units to support monitoring of Unit i
river water pump operation in B & C cubicles.
i
Supplcmant I to January 21, 1986 Submittal dated; i
EXEMPTION REOUEST 11.24 Emergency Lighting (See attached Figures 11.24-1 thru 5 previously submitted)
A.
Introduction Per the provisions of 10 CFR 50.12, Duquesne Light Company requests exemption from Section III.J of Appendix R to 10 CFR 50 to the extent that it requires 8-hour battery powered emergency lighting for access and egress routes to safe shutdown equipment Unit 1.
Specifically, we for Beaver Valley Power Station request exemption for allowing the use of:
1.
Security perimeter lighting for outside yard area access / egress routes.
2.
Portable hand-held lighting units for specific plant areas (See Table I) 3 Two (2)-hour battery powered emergency lighting supply capability in the Brigade Room.
i B.
Discussion i
1.
Security Perimeter Lighting For certain fire scenarios, the operators may be required to follow outdoor pathways to achieve and maintain safe shutdown from outside the control room. The outdoor pathways as denoted on Figure 11.24-2 and 4, are described below:
i Control Room to Emergency Diesel Generator Buildings via cast yard area.
Control Room to Intake Structure via north yard area.
Across rooftop between the Safeguards Building Stairwell (S-2) to the Service Building (Feedwater Regulating Valve Room)
The security perimeter lighting system consists of permanently mounted lights on poles and on outside building walls.
This permanent lighting system is powered from Motor Control Center MCC-1-37 located in the Security Guardhouse
- which, on loss of offsite power, would be supplied from the Security Diesel Generator (NHS-EG-1).
This emergency diesel i
generator has a
fuel supply capable of operating for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
11.24-1
.. - -...... - - ~
The security perimeter lighting circuits powered from MCC-1-37 are not routed through any fire areas where safe shutdown equipment or cables are located.
The transfer circuit that switches power between the normal source and security diesel generator has some dependence in fire areas TB-1 (Turbine Building) and NS-1 (Normal Switchgear) in that a
fire-induced hot short could cause an overcurrent trip indication of the 480 VAC Bus Breaker 1-4 which blocks the transfer to the security diesel generator.
However, for a fire in these two areas a control room evacuation would not be required.
For all other fire areas of concern for Appendix R,
the security diesel generator and transfer circuitry are independent.
2.
Portable Hand-Held Lights Operators performing the alternate safe shutdown procedure are provided with flashlights to enhance the permanently installed emergency lighting systems.
Portable lighting would supplement the fixed emergency lighting systems to provide versatility and effectiveness for operators to perform their intended shutdown functions.
The specific locations where the use of portable lighting has been identified as a
result of field walkdowns are listed on Table I (attached).
3.
Fire Brigade Room (2-hour battery powered supply units)
The Brigade Room is a self-contained enclosure located on the Turbine deck adjacent to the Control Room main entrance / exit area (See Figure 11.24-2).
The Turbine deck has 8-hour battery powered lighting units installed for access / egress routes around the Brigade Room.
Within the Brigade Room
- itself, 2-hour battery powered emergency lighting units were supplied as part of the original design of the room built in 1979 for BTP 9.5-1 considerations.
For the postulated fire scenario requiring immediate control room evacuation, operators performing the alternate shutdown procedure would utilize the Brigade Room as a staging area.
The Nuclear Shift Supervisor (NSS) would brief the operators on job assignments, distribute key rings and procedure
- packets, and supply personnel with extra flashlights.
The time duration expected at this staging area would be less than 30 minutes.
C.
Justification 1.
Security Perimeter Lighting The security perimeter lighting system would provide emergency outside yard area lighting capability equivalent to technical requirements of Section III.J (8-hour battery power supply) based on the following:
11.24-2
t a.
The security perimeter lighting system including its emergency power supply are independent of fire
[
areas where control room evacuation may be required under the postulated fire scenario.
b.
The Regulatory Effectiveness Review dated August 29, 1985 reviewed the security perimeter lighting and found it exemplary.
c.
The security lighting system provides an acceptable margin of safety equivalent to the technical requirements of Section III.J.
2.
Portable hand-held lights Based on field walkdowns by operations personnel simulating the alternate shutdown procedure, specific locations where the use of portable lighting will enhance the effectivenes of operational activities have been identified and these are listed in Table 1.
Use of portable hand-held flashlights should be acceptable for use to enhance the permanently installed 8-hour battery powered units based on the versatility and additional effectiveness provided.
a.
Guidance contained in Generic Letter 85-01 (Section 4.1) references the Illuminating Engineering Society (IES)
Handbook for the industry standards.
The IES Handbook is a guide which gives considerable latitude with regard to illumination levels und recognizes the acceptability of the use of portable lighting to supplement fixed D.C. units, b.
Use of portable flashlights would offer more flexibility with respect to aiming which may be needed for unexpected transient hazards or any unanticipated events.
c.
The functions or actions required by the operators (listed in Table I) would accommodate the use of a portable flashlight to enhance their effectiveness.
For each case, the operator could hold a
flashlight and perform the function (i.e.,
access /cgress
- pathway, observe a gauge, operate a switch, etc.)
3.
Brigade Room The Brigade Room emergency light capability provides an acceptable margin of safety equivalent to tFe requirements of Section III.J based on the following:
11.24-3
e a.
The effectiveness of the lighting system is determined by the ability of the operator to perform the intended functions.
For the Brigade Room area, the intended function would be to utilize the room as a staging area where the Nuclear Shift Supervisor would brief the
- crew, distribute key rings and procedure packets, and supply extra flashlights.
The time expected at this i
area would be less than 30 minutes.
Therefore, the 2-hour emergency lighting capability in the Brigade Room would be sufficient for performing the requisite actions.
s f
11.24-4
. _ ~
J TABLE I
Emergency Lighting Test Results Portable Lighting Recommendation List LOCATION FUNCTION Intake Structure Access / Egress pathway to Pump Cubicles and monitor river water pump operation in the A,
B C
cubicles Turbine Deck Access / Egress pathway to Turbine Pedestal and manually trip turbine, if necessary.
Primary Auxiliary Access / Egress pathways, identify Bldg. (PAB) valve positions and monitor Charging Pump operations.
Service Bldg. rooftop Access / Egress pathway to FW Reg.
to FW Reg. Valv3 Room Valve Room Normal 4KV Switchgear De-energize non-essential electrical Room, AE & DF Emergency equipment and switch off DC control Switchgear Rooms, and power.
Process Rack Room NOTE Use of portable hand-held flashlights would enhance the permanently installed 8-hour battery powered emergency lighting units for the above listed areas.
The operator actions are all hands-free activities (access / egress, observe a
- gauge, etc.) or actions that require one-hand (operate switch, etc.) which would accommodate use of flashlights.
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