ML20236T373
| ML20236T373 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/22/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M99791, TAC-M99792, NUDOCS 9807280139 | |
| Download: ML20236T373 (22) | |
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,e CumEs II. Cat;se Baltimore Gas and Electric Cor oany Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 July 22,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information; Exemption from 10 CFR 50.48. Anoendix R. Requirements (TAC Nos. M99791 and M99792)
REFERENCES:
(a)
Letter from Mr. A. W. Dromerick (NRC) to Mr. C. H. Cruse (BGE),
dated June 22,1998, "Calvert Cliffs Nuclear Power Plant, UnitNos. I and 2 - Request for Additional Information (TAC Nos. M99791 and M99792)"
(b)
Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated October 6,1997, " Exemption from 10 CFR 50.48, Appendix R, Requirements" Reference (a) requested additional clarification to complete the review of Baltimore Gas and Electric Company's exemption request dated October 6,1997 (Reference b). Our response is provided in Attachment (1).
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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.. / v V.. U for C.11. Cruse Vice President - Nuclear Energy
Attachment:
(1) Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 - Response to Request for 6
Additional Information (TAC Nos. M99791 and M99792)
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Enclosures:
(A) Drawings (B) Photographs 9807280139 980722 PDR ADOCK 05000317 F
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Document Control Desk July 22,1998 l
Page 2 cc:
A. W. Dromerick, NRC Resident inspector,NRC H. J. Miller, NRC (Without Enclosure A)
R. S. Fleishman, Esquire R. I. McLean, DNR J. E. Silberg, Esquire J. H. Walter, PSC S. S. Bajwa, NRC i
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ATTACHMENT (1) 6 i
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Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 - Response to Request i
for AdditionalInformation; Exemption from 10 CFR 50.48, Appendix R, i
l Requirements (TAC Nos. M99791 and M99792)
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i Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 22,1998
ATTACHMENT (1) i CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The'following information is required for the Nuclear Regulatory Commission to complete their review of the exemption request.
1.
Describe the location ofthe portable lights that will be used by the operators in the high radiation areas and inside of the electrical cabinets.
BGE Response Portable Lighta for High Radiation Areas The portable lights that will be used in the high radiation areas are stored in a cabinet. The cabinet containing the portable lights and the high radiation rooms in which the portable lights will be 1
l used are located on the same (27'-0") elevation of the Auxiliary Building. In Enclosure (A),
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Drawing Nos. 63402SH0027, Revision 9 and 61402SH0030, Revi* ion 13 show the location of the two high radiation rooms. Drawing No. 63402SH0027, Revision 9 shows the location of the j
l cabinet containing the portable lighting. The portable lights are the type with a wide base, and are j
designed to be stable when positioned on the floor. The lamp head is attached in such a fashion l
that it can be adjusted to aim the light where needed. An operator can enter the room, use the light -
to access the valve, then set the portable light on tl e floor and adjust the head to aim at the valve, then operate the valve. A photograph of the portable light units is provided in Enclosure (B) -
(Photograph No.1).
Helmet I ights for Electrical Cabinets
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The helmet mounted lights that will be used inside the electrical cabinets are stored in the
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Appendix R Safe Shutdown Locker for each Unit. This locker is located inside the respective Unit's 45' Switchgear Room. This locker contains both the helmet lights and the shutdown procedures to be used for Appendix R Post-fire Shutdown. This is the first stop for the operators l
once the decision to enter the Appendix R Shutdown Procedure has been made. The location of the Shutdown Lockers are marked on Drawing Nos. 63402SH0028, Revision 14 and 61402SH0029, Revision 13 provided in Enclosure (A). In Enclosure (B), Photograph No. 2 shows the Appendix R Safe Shutdown Locker in the Unit 145' Switchgear Room. The helmet mounted lights consist of a light head attached to a wide rubber band that is placed around the hardhat. A belt with two attached battery packs, (each weighing about one pound) and a connector to attach the lamps to the battery rounds out the assembly. There are ten sets for each unit, which exceeds the demand. Enclosure (B), Photograph No. 3 shows the helmet light being worn.
2.
Provide a physical description of the high radiation areas including access and egress route lighting andlocation and description ofsafe shutdown activities within the high radiation areas.
BGE Response The specific high radiation areas are located on each Units' 27' elevation West Piping Penetration Room. The shapes of the Unit 127' West Piping Penetration Room and the Unit 2 27' West Piping Penetration Room are shown in Enclosure (A) (Drawing Nos. 61402SH0030, Revision 13 and 63_402SH0027, Revision 9, respectively]. Each room has two elevations separated by a grating floor, 'Ihe upper elevation is a high radiation area. The lower (5'-0") elevation is not a high radiation area. There are emergency lights on the lower elevation below the grating. There is l
a group of pipes clustered in the center of the room that go toward the Containment. There are also pipes along the perimeter walls. However, there is a clear walking pathway through the room.
Enclosure (B), Photograph No. 4 shows the Unit 2 5' Penetration Room, located directly below the locked high radiation area. This photograph is indicative of the arrangement in both Units' 27' 1
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A'ITACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT, UNITNOS. I AND 2 - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
' West Piping Penetration Rooms. There are no unusual efforts required by the operators to access the valves. The portable lighting will provide adequate illumination to access the valves. The portable light can be placed on the floor near the valves that need to be operated to provide
. illumination for the manipulation of the valves.
The access / egress route from the stairwell to the storage cabinet that contains the portable lights is illuminated with fixed eight-hour battery powered emergency lights. The access / egress routes from the cabinets to the High Radiation Rooms are well illuminated with fixed eight-hour battery powered emergency lights. In Enclosure (A), Drawing Nos.61402SH0030, Revision 13 and 63402SH0027, Revision 9, provide the location of the fixed eight-hour battery pcwered emergency lights. Enclosure (B), Photograph No. 5, shows the location of the fixed eight-hour battery powered emergency lights i the corridor between the storage cabinet and the Unit 2 27' West Piping Penetration Room. Enclosure (B), Photograph No. 6, shows the proximity of the fixed eight-hour battery powered emergency light to the Unit 2 West Penetration Room access / egress door. Enclosure (B), Photograph No. 7, shows a sign on the door of the Unit I West Penetration Room advising operators where hand held lights are stored.
The required actions in the high radiation rooms consist of operating several valves manually.
3.
Describe any time critical activities inside of high radiation areas and the electrical cabinets and any afect that usingportable lighting may have on time critical activities.
BGE Response The activities inside of the high radiation rooms are associated with cold shutdown and as such, are not time critical. Obtaining the portable lights from the cabinets for use in the high radiation areas will not add more than a minute to the time required to access these rooms. The cabinet is locked, but a breakaway style lo:k was used in case the operator did not get the key in advance.
He time critical activity inside of the electrical cabinets is pulling fuses to isolate the cabinet from fire effects. When the Appendix R post-fire shutdown procedure is initiated, the operators report to the Shutdown Locker where they obtain the appropriate shutdown precedure and are issued a helmet light. De helmet light takes only seconds to put on, thus time critical activities are not impacted.
4.
' Describe the reason that an exemption is requestedfor the high radiation areas.
BGE Response l
De 27' West Piping Penetration Rooms,(each unit has a similar room), is a locked high radiation area. De radiation levels do vary over time; recent general area dose rate readings in the rooms were 300 to 1100 mrem (note that this value doubles with two charging pumps running).
Quarterly maintenance performed on the fixed battery powered emergency lights require that the l
batteries be tested and the lights verified as aimed. Even if the battery boxes were relocated outside of the room, entry would still be required to verify the lights are aimed properly. Eight-hour deep discharge tests would require replacement of the lamps. These activities result in unnecessary radiation dose to plant personnel. Since the exemption was submitted, there has been a renewed effort to eliminate activities in high radiation areas if other options are available. The use of portable handlights stored outside of the high radiation room provides an alternate means of emergency illumination that will permit the operator to safely and quickly access the valves and manipulate them as needed.
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ENCLOSURE (A) TO ATTACHMENT (1) l l;
Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 - Response to Request 1
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for AdditionalInformation; Exemption from 10 CFR 50.48, Appendix R, Requirements (TAC Nos. M99791 and M99792) l DRAWINGS i
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l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 22,1998
OVERSfZE
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DOCUMENT'^
PAGE(S) PULLED SEE APERTURE CARD FILES ^
APERTURE CARD / PAPER COPY AVAILABLE THROUGH NRC FILE CENTER
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kUMBER OF OVERSIZE PAGES FILMED ON APERTURE CARD (S ACCESSION NUMBERS OF DVERSIZE PAGES:
9Forosoa4 990705013 9 SoFOSOI33 920%C50I%
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ENCLOSURE (B) TO ATTACHMENT (1)
Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 - Response to Request for Additional Information; Exemption from 10 CFR 50.48, Appendix R, Requirements (TAC Nos. M99791 and M99792)
PHOTOGRAPHS I
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 22,1998 l
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Photograph No.1 - A photograph of the portable light units. Photograph shows a storage cabinet containing the portable handheld lights. One is in normal storage position and the other has been placed on the edge of the cabinet with the light on. Note the proximity of the fixed emergency lights.
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Photograph No. 2 - A photograph of an Appendix R Safe Shutdown Locker. The Appendix R Safe Shutdown Locker shown in the photograph is located in the Unit 145' Switchgear Room. The Locker contains Appendix R shutdown procedures, Operators pouch (containing fuse pullers), and the helmet mounted lights. Note the proximity of the fixed emergency lights to the locker. Unit 2 is similar.
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Photograph No. 3 - A photograph of the helmet light being worn. The battery packs are worn around the waist.
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i Photograph No. 4 - A photograph of the Unit 2 5' Penetration Room, located directly below the Unit 2 27' West Penetration Room (a Locked High Radiation area). The photograph shows a room arrangement that is indicative of the arrangement in both Units' 27' West Penetra&n Room.
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Photograph No. 5 - A photograph showing the location of the fixed eight-hour battery powered emergency lights in the corridor between the storage cabinet containing the portable lights and the Unit 2 27' West Piping Penetration Room. The door to the Unit 2 27' West Penetration Room is just around the bend in the corridor.
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Photograph No. 6 - Photograph showing the proximity of the fixed eight-hour battery powered emergency light to the U-2 West Penetration Room access / egress door.
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s-4 Photograph No. 7 - A photograph showing a sign on the door of the U-l West Penetration Room advising operators where hand held lights are stored.
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