Text

Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements
	ML23026A359
Person / Time
Site:	Wolf Creek
Issue date:	01/26/2023
From:	Boyce M; Wolf Creek
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	ET 23-0004
	Download: ML23026A359 (1)
	v • d • e

W o If Cree Nuclear Operating Corporation k- .rw~,~rrr--

Michael T. Boyce Vice President Engineering ET 23-0004 January 26, 2023 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 22-0010, dated August 2, 2022, from M. T. Boyce, WCNOC, to USNRC

2) Electronic mail dated December 27, 2022, from S. Lee, USNRC, to J.

Turner, WCNOC, Request for Additional Information: Wolf Creek Request for Deviation from Fire Protection Program Requirements (EPID: L-2022-LLA-0107)

Subject:

Docket No. 50-482: Response to Requests for Additional Information (RAI)

Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements To Whom It May Concern:

In Reference 1, Wolf Creek Nuclear Operating Corporation (WCNOC) requested an Amendment to the Renewed Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS). The proposed change would revise the Fire Protection Program to allow for the use of portable lighting as the primary emergency lighting means (with limited exceptions) for illuminating safe shutdown equipment and access egress routes to the equipment.

In Reference 2, the NRC provided WCNOC with Requests for Additional Information (RAIs) to support the NRC staffs review of the License Amendment Request (LAR). The attachment to this letter provides WCNOCs responses to the requested information. Additionally, the enclosure to this letter contains Revision 1 of WIP-E-1F9900-010-A-1, Post-Fire Safe Shutdown Operator Manual Actions. The new revision contains additional information to support the responses provided by WCNOC. The initial revision of WIP-E-1F9900-010-A-1 was previously provided in Reference 1.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, a copy of this letter, with attachments, is being provided to the designated Kansas State official. The additional information provided in this letter does not alter or expand the scope of the application and does P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

ET 23-0004 Page 2 of 3 not impact the no significant hazards consideration determination conclusion reached in Reference 1.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-8831 x8687, or Dustin Hamman at (620) 364-4204.

Sincerely, Michael T. Boyce MTB/jkt Attachments: Wolf Creek Nuclear Operating Corporation (WCNOC) Response to Requests for Additional Information (RAls) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements

Enclosures:

WIP-E-1 F9900-01 0-A-1, Revision 1, "Post-Fire Safe Shutdown Operator Manual Actions" cc: S. S. Lee (NRC), w/a, w/e S. A Morris, (NRC), w/a, w/e G. E. Werner (NRC}, w/a, w/e Senior Resident Inspector (NRC), w/a, w/e J. Meinholdt (KDHE}, w/a, w/e

)

ET 23-0004 Page 3 of 3 STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Michael T. Boyce, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By. ~

MichaelT.oyce Vice President Engineering SUBSCRIBED and sworn to before me this 'lll day of Ja.PlOJ"j , 2023.

~Public Nota wi 'tl.L~~oUt ~.Q.l<.Qr Expiration Date - \ ::( \. 1,,D'l 1

Attachment to ET 23-0004 Page 1 of 2 WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC) RESPONSE TO RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs) REGARDING LICENSE AMENDMENT REQUEST (LAR) FOR DEVIATION FROM FIRE PROTECTION PROGRAM REQUIREMENTS

Background:

By letter dated August 2, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22215A000), Wolf Creek Nuclear Operating Corporation (WCNOC or the licensee) submitted a request for Wolf Creek Generating Station (Wolf Creek), pursuant to License Condition 2.C.(5), to make changes to the approved fire protection program allowing the use of portable lighting as the primary emergency lighting means (with limited exceptions) for illuminating safe shutdown equipment and access egress routes to the equipment. The NRC staff has reviewed the license amendment request and determined that additional information is required to complete the review. The NRC staffs request for additional information (RAI) is listed below. The NRC staff may have additional RAIs. The WCNOC staff determined that a draft RAI clarification call was unnecessary. The WCNOC staff requested, and NRC agreed, to an RAI response by January 27, 2023.

NRC Staff Request RAI-1:

One significant objective of Appendix R to Title 10 of Code Federal Regulations (CFR) Part 50,Section III.J, Emergency lighting, is to provide direction to the operators if electrical power is lost as a result of a fire and to provide reasonable assurance that operators will not become disoriented, particularly in stairwells and at doorways and intersecting corridors. The presence of fixed emergency lighting on some routes, but not all routes, could contribute to operator confusion and impact the timely completion of operator manual actions (OMAs). Depending on the direction of the portable light beam, the operator may not observe obstructions created by the fire brigade or other activities that can be related or unrelated to the fire emergency that would not normally be present in the pathway. Such obstructions would be obvious if fixed emergency lighting were available. Failure to obtain proper direction or to observe obstructions could impede operator access to or egress from areas needed to manually operate or check post-fire safe shutdown equipment. Further, it is not possible to predict the specific conditions under which fires may occur and propagate. Therefore, it is not possible to predict how much time operators will spend on access and egress pathways that do not contain fixed lighting. Further, these pathways generally contain obstructions (e.g., piping, structures), which require visual detection to permit safe transit.

a) Because travel pathways to and from areas where OMAs are performed may no longer have fixed emergency light fixtures subject to regular maintenance under the Maintenance Rule, discuss the impact of using only portable (hard hat mounted) lights to light travel pathways to and from areas where OMAs are performed. At a minimum, the discussion should include any impacts to each OMA timeline; any impacts to OMA uncertainty; any impacts to time margins; and any impacts to demonstrations.

b) The feasibility and reliability review for each fire area where OMAs are conducted has not been updated to reflect the use of portable (hard hat mounted) lights in lieu of fixed emergency light fixtures. The feasibility and reliability review provided for the portable lights, only discusses that the portable lights have sufficient battery capacity to last for the duration needed to perform the OMAs. Provide a summary of the revised feasibility and reliability review to reflect the use of the portable lights in lieu of fixed emergency lights, particularly in the sections of the review that discuss emergency lighting, portable equipment, and demonstrations.

Attachment to ET 23-0004 Page 2 of 2 RAI-1(a) Response:

The enclosure to this letter, WIP-E-1F9900-010-A-1, Rev. 1, Post-Fire Safe Shutdown Operator Manual Actions, was revised to provide additional evaluation discussion in Section E.10.1 of Attachment E (pages E-29 through E-30). The changes are annotated by a revision bar, with red being new text and blue strike through reflecting deleted text. The evaluation addition provides the basis for a reasonable assurance conclusion that the use of hard hat mounted portable lighting as the credited primary means for illuminating safe shutdown implementing procedures, equipment, and the respective access egress routes to the equipment does not adversely affect operator manual action (OMA) implementation, uncertainty, or resulting time margin. A discussion is also included evaluating the acceptability of the multi-hour performance testing, documented in Section E.7 and Attachment E.4, providing ample demonstration that the portable lighting provides superior illumination and flexibility for use when compared to the fixed emergency lighting.

RAI-1(b) Response:

As identified in the response to RAI-1(a), the feasibility and reliability analysis conducted in Attachment E, Section E.10.1 of WIP-E-1F9900-010-A-1, Rev. 1 concluded that there was no adverse change to OMA implementation, uncertainty, or time margin as a result of crediting hard hat mounted portable lighting as the primary emergency lighting means. Therefore, the revision to the individual feasibility and reliability sections within the Section 8 body of WIP-E-1F9900-010-A-1, Rev. 1 provide a direct reference to Attachment E for the emergency lighting evaluation. The new text for these sections is red and annotated by revision bar.

Attachment E References E.15.46 and E.15.47 to WIP-E-1F9900-010-A-1, Rev. 1 were added in support of the RAI response.

Enclosure to ET 23-0004 WIP-E-1F9900-010-A-1, Revision 1, Post-Fire Safe Shutdown Operator Manual Actions (70 pages)

APF 05-013-01, REV. 04 WIP-E-1F9900-010-A-1 Post-Fire Safe Shutdown Operator Manual Actions ENGINEERING REVIEW:

DRAFTER:

CHECKER:

ENGINEER SUPERVISOR:

1.

~ ELECTRONIC APPROVAL 2.

APPROVED-MFG. MAY PROCEED NOT APPROVED--RESUBMIT FINAL DOCUMENT/DRAWING-MFG. MAY PROCEED 3.

APPROVED INFORMATION NOT CONTROLLED UNDER DESIGN PROCESS YES NO 4.

5.

ACCEPTABLE-MAINTAIN AS RECORD (INFO. ONLY)

RESTRICTED FOR WOLF CREEK PLANNING ONLY-MFG. MAY PROCEED YES NO APPROVAL OF THIS DOCUMENT/DRAWING DOES NOT RELIEVE SUPPLIER/CONTRACTOR FROM FULL COMPLIANCE WITH CONTRACT, SPECIFICATIONS AND/OR PURCHASE ORDER REQUIREMENTS.

COMMENTS:

Do not incorporate WIP-E-1F9900-010-A-1 until approval is obtained from NRC via a License Amendment Request (LAR).

There 70 total WIP pages (including cover sheet).

Attachment E is new attachment for E-1F9900.

Revision 01 was developed to address NRC Request for Additional Information (Reference NRC Accession No. ML22361A005)

P.O.#: N/A VENDOR MANUAL: N/A PAGE: N/A CHANGE PACKAGE #: INCORPORATED CHANGE DOCUMENT(S): N/A 020283 REV. # DC RELEASED:

J DigsigDSR 3 0.50 01 weLF CREEK 'NUCLEAR OPERATING CORPORATION COMPONENT NUMBER(S): See change package 020283.

COMPONENT NUMBERS ARE FOR INITIAL (REV, W01) DATA LINKING ONLY. ADDITIONAL COMPONENT LINKS ARE MADE IN DATABASE ONLY.

Post-Fire Safe Shutdown Operator Manual Actions Page 2 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Table of Contents 1.0 Purpose 3 2.0 Scope 3 3.0 Background 4 4.0 Definitions 7 5.0 Methodology 11 6.0 E-1F9900 Revision Guidance 31 7.0 References 31 8.0 Feasibility and Reliability Review 34 8.1 Fire Area A-16, Auxiliary Building 2026' General Corridor 34 8.2 Fire Area C-18, Control Building 2016' Cable Chase 44 8.3 Fire Area C-21, Control Building 2032' Lower Cable Spreading Room 51 8.4 Fire Area C-22, Control Building 2073'-6 Upper Cable Spreading Room 62 8.5 Fire Area C-23, Control Building 2032' South Cable Chase 71 8.6 Fire Area C-24, Control Building 2032' North Cable Chase 78 8.7 Fire Area C-30, Control Building 2047'-6 85 8.8 Fire Area C-33, Control Building 2073'-6 92 Attachment A Summary of OMAs to Achieve and Maintain Hot Standby A1-1 Attachment B1 Fire Alarm System Response Time B1-1 Attachment B2 Sample FDT Data Sheet NUREG-1805 FDT 11. Estimating Smoke Detector Response Time B2-1 Attachment C Photos of Equipment Manipulated For Operator Manual Action C1-1 Attachment D Fire Area Plan View Sketches D1-1 Attachment E Emergency Lighting Strategy for Safe Shutdown E1-1

Post-Fire Safe Shutdown Operator Manual Actions Page 3 of 98 WIP-E-1F9900-010-A-1, Rev. 01 1.0 Purpose 1.1 The purpose of this document is to evaluate the feasibility and reliability of operator manual actions (OMA) that are potentially necessary to ensure the availability of a post-fire safe shutdown (PFSSD) success path to achieve and maintain hot standby conditions, in response to a single fire event outside the Control Room.

1.2 The OMAs, which are for 10 CFR 50 Appendix R, Section III.G.2, fire areas, are evaluated for feasibility and reliability utilizing the guidance provided in NUREG- 1852.

1.3 This document also evaluates the emergency lighting strategy used by the Station for illuminating implementing procedures, safe shutdown equipment, and the respective access egress routes to the equipment in support of PFSSD or a non-fire event resulting in the loss of all AC power.

2.0 Scope 2.1 This feasibility and reliability review is applicable to OMAs, as defined inSection 4.12. Attachment A summarizes the OMAs, and the fire areas affected.

2.2 Consistent with the scope of NUREG-1852, actions taken within the Control Room that are potentially necessary to mitigate or prevent the undesirable affects of fire induced spurious equipment operation are not addressed within this review for feasibility and reliability. Control Room Actions are identified in E-1F9910, Post-Fire Safe Shutdown Fire Area Analysis, and procedural guidance is provided in OFN KC- 016, Fire Response.

2.3 Fire areas that do not require a mitigating action to ensure preservation of a PFSSD success path, are not addressed within this review. Refer to E-1F9910 for the detailed PFSSD analysis for each fire area.

2.4 Actions required for transition to cold shutdown are not included. Hot standby is a safe, stable condition for the plant. Consistent with 10 CFR 50 Appendix R, Section III.G.1.b, cold shutdown repairs are required to be completed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, cold shutdown is not required to be achieved within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

2.5 The emergency lighting strategy evaluated in Attachment E of this document supporting the following procedures:

OFN RP-017, Control Room Evacuation OFN KC-016, Fire Response EMG C-0, Loss of All AC Power OFN NB-034, Loss of All AC Power - Shutdown Conditions

Post-Fire Safe Shutdown Operator Manual Actions Page 24 of 98 WIP-E-1F9900-010-A-1, Rev. 01 The on shift operator responsible for OFN KC-016 OMAs is required to carry a radio on their person in effort to improve communication diversity.

5.1.10 Portable Equipment The portable equipment needed to successfully implement the OMA was identified and reviewed for availability and dedication to PFSSD, where appropriate.

In addition to the radio discussed above, the on shift operator responsible for OFN KC-016 OMAs is required to carry on their person the following portable equipment:

Hand tool for cutting wire tab type locking devices on components that potentially would be required to be manipulated.

Master key to unlock electronic card reader controlled doors, in the event electronic door function is affected by the fire.

Hard hat mounted portable light to aid access/egress in the event normal lighting is affected by the fire.

Key for ABFHC0002 and ABFHC0003 enclosure housings.

5.1.11 Personnel Protective Equipment (PPE)

The personnel protective equipment required to support the performance of the OMA is identified and assessed for availability. Hard hat, safety glasses, hearing protection, and gloves are not included in this review since this is the standard PPE complement, imposed by the WCNOC Safety Manual, for entry into industrial portions of the plant.

5.1.12 Procedures and Training Each OMA was reviewed to ensure it is included within OFN KC-016, Fire Response. This procedure contains the actions potentially necessary to ensure availability of a PFSSD success path following a single fire event outside the Control Room. The Operations department owns this procedure. Training for the procedure is on a biennial cycle. The procedure is also exercised during fire brigade drill activities that involve postulated fires affecting PFSSD success path.

The procedure identifies the following information, per fire area with a potential OMA, to ensure Control Room personnel are aware of the potential fire impact on safe shutdown.

Equipment susceptible to fire induced spurious operation that could affect PFSSD success path.

OMAs that are required to achieve PFSSD hot standby.

OMA to mitigate spurious equipment operation.

Post-Fire Safe Shutdown Operator Manual Actions Page 38 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Fire Area A-16 Ope rat or Manual Action T imeline

( 1inutesp

~ Fire hitiru:ed H Fire hdicated H [lagnos is Tm-e OMl\. Lricerlainty f l I 10 20 30 40 50 60 70 BO 90 mo 110 120 130 '140 150 160 170 WO 190 200 Tlme Marg in Available Time Figure 8.1.4-1, Fire Area A-16 OMA Timeline 8.1.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline.

The OMA Timeline for Fire Area A-16 reveals that a one hundred thirty six (136) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.

8.1.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within the general corridor area of the Auxiliary Building 2026' elevation. The location of the OMAs is within the Main Steam Enclosure on the 2037'-7" elevation of the Auxiliary Building (Fire Area A-23).

Based on fire barrier separation, the fire will be confined to Fire Area A-16. Access to Fire Area A-23 does not require transition through Fire Area A-16. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means.

Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting. Normal radiation conditions within the areas of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

Post-Fire Safe Shutdown Operator Manual Actions Page 47 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means.

Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting. Normal radiation, temperature, and humidity conditions within the OMA area will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.2.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.2.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3419. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm.

This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

RWST level indicators BNLI0931 and BNLI933.

Containment pressure indicators GNPI0934 and GNPI0936.

8.2.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems. The OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been

Post-Fire Safe Shutdown Operator Manual Actions Page 55 of 98 WIP-E-1F9900-010-A-1, Rev. 01 8.3.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs.

The postulated fire event is within Lower Cable Spreading Room on the 2032' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000 ' elevation of the Control Building, within the north ESF Switchgear Room.

Based on fire barrier separation, the fire will be confined to Fire Area C-21.

The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.

8.3.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.3.8 Available Indications Point addressable smoke detection is provided for the Lower Cable Spreading Room. Upon detector activation, main fire alarm panel KC- 008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

Post-Fire Safe Shutdown Operator Manual Actions Page 64 of 98 WIP-E-1F9900-010-A-1, Rev. 01 8.4.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-22 reveals that a thirty nine (39) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.4.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA.

The postulated fire event is within Upper Cable Spreading Room on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to Fire Area C-22 Upper Cable Spreading Room. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire-rated barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.4.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker.

The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access

Post-Fire Safe Shutdown Operator Manual Actions Page 73 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Fire Area C-2,3, Operator Manual Jl.ction T imeline (Mnutes)

Fire Initiated

.Fire hdicated

, [lagnosis line 91\1\1\ Tlme OM\ U1certainty 1 1 I~ 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Tim e Marg in Available Time Figure 8.5.4-1, Fire Area C-23 OMA Timeline 8.5.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-23 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.5.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA.

The postulated fire event is within Cable Chase 3505 located on the 2032' elevation of the Control Building. The location of the OMA for stopping PEN01B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to the Fire Area C-23 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment.

The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting.

Normal radiation, temperature, and humidity

Post-Fire Safe Shutdown Operator Manual Actions Page 81 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment.

The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting.

Normal radiation, temperature, and humidity conditions within the OMA area will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.6.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.6.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3504. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

RWST level indicators BNLI0931 and BNLI933.

Containment pressure indicators GNPI0934 and GNPI0936.

8.6.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMAs do not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

Post-Fire Safe Shutdown Operator Manual Actions Page 88 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.7.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker.

The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.7.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3617. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

RWST level indicators BNLI0930 and BNLI0932.

Containment pressure indicators GNPI0935 and GNPI0937.

8.7.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face

Post-Fire Safe Shutdown Operator Manual Actions Page 94 of 98 WIP-E-1F9900-010-A-1, Rev. 01 Fire Area C-33 Operator M anual AcUon TimeUne (Mnutes)

~* Fire Initiated Fire ndfrcated Dagnosis line rnM lklcertainty l l

,) 2 4 6 8 10 12 14 16 18 20 22 24 16 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Tim ,e Marg in Avanable Time Figure 8.8.4-1, Fire Area C-33 OMA Timeline 8.8.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-33 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.8.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA.

The postulated fire event is within Cable Chase 3804 located on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01B containment spray is on the 2000' elevati on of the Control Building within the south ESF Switchgear Room.

The fire will be confined to the Fire Area C-33 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Hard hat mounted portable lighting, evaluated in Attachment E, is the primary emergency lighting means for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment.

The Attachment E evaluation determined that there is no adverse impact to OMA implementation, uncertainty, or time margin with crediting portable lighting as the primary emergency lighting means. Existing fixed emergency lighting provides 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months supplemental lighting to the portable lighting.

Normal radiation, temperature, and humidity

Post-Fire Safe Shutdown Operator Manual Actions Page E-1 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E to E-1F9900 Emergency Lighting Strategy for Safe Shutdown

Post-Fire Safe Shutdown Operator Manual Actions Page E-2 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table of Contents E.1 Purpose E-3 E.2 Scope E-3 E.3 Background E-4 E.4 Regulatory Information E-6 E.5 Updated Safety Analysis Report E-9 E.6 Portable Lighting Selection E-10 E.7 Demonstrations E-14 E.8 Preventive Maintenance Activities E-25 E.9 Defense-In-Depth E-26 E.10 Feasibility and Reliability Analysis E-28 E.11 Future Evaluation of Equivalent Portable Lighting E-32 E.12 Maintenance Rule Application E-34 E.13 Precedent E-34 E.14 Conclusion E-36 E.15 References E-37 Attachment E.1, Portable Lighting Information E-40 Attachment E.2, Light Meter Information E-47 Attachment E.3, Peer Plant Portable Lighting Information E-50 Attachment E.4, Photos from Lighting Performance Test E-51

Post-Fire Safe Shutdown Operator Manual Actions Page E-3 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.1 Purpose E.1.1 The purpose of this Attachment is to evaluate the acceptability of utilizing the following diverse emergency lighting approach for illuminating safe shutdown implementing procedures, equipment, and the respective access egress routes to the equipment in support of post-fire safe shutdown (PFSSD) or a non-fire event resulting in the loss of all AC power.

8-hour fixed battery units for the locations that may require long term attendance in support of safe shutdown. These units and respective locations are identified in Table E.2.5-1.

Portable (hard hat mounted) lighting for illuminating safe shutdown implementing procedures, equipment, and the access egress routes to the equipment. This will be the primary emergency lighting method for most locations. This attachment will focus on evaluating portable lighting as an acceptable primary emergency lighting means, since fixed emergency lighting is the standard.

1.5-hour fixed battery units for firefighting activities, life safety access/egress, and supplementary lighting to portable lighting.

E.2 Scope E.2.1 Operator manual actions (OMAs) located outside the Control Room for a fire outside the Control Room. These OMAs are evaluated in Attachment A of this document and are implemented by OFN KC-016, Fire Response. WIP-E-1F9900-004-A-1, Rev. 1 for E-1F9900 was approved by the NRC via License Amendment 191 (Reference E.15.3). E-1F9900 has been revised since License Amendment 191.

E.2.2 OMAs for a fire in the Control Room requiring Control Room evacuation.

These OMAs are evaluated in E-1F9915 and are implemented by OFN RP-017, Control Room Evacuation. A markup of E-1F9915, Rev. 5, was approved by the NRC via License Amendment 214 (Reference E.15.6). E-1F9915 has been revised since License Amendment 214.

E.2.3 Operator Actions not within the Control Room, the Auxiliary Shutdown Panel Room, or at the Emergency Diesel Generator Control Panels KJ121 or KJ122 necessary for safe shutdown absent a fire. These are described in USAR Section 9.5.3.2.3 and per LER 95-005 (Reference E.15.33) include the OMAs for EMG C-0, Loss of All AC Power, and OFN NB-034, Loss of All AC Power-Shutdown Conditions.

E.2.4 Access and egress routes to all equipment locations supporting OMAs in Sections E.2.1 through E.2.3 above.

Post-Fire Safe Shutdown Operator Manual Actions Page E-4 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.2.5 For the Control Room, the Auxiliary Shutdown Panel Room, the Emergency Diesel Generator Panels (KJ121 or KJ122), and the Operations hard hat rack outside of the Control Room, fixed emergency lighting units with 8-hour battery capacity will continue to be credited in the emergency lighting illumination response strategy for safe shutdown. These emergency lighting units are identified in Table E.2.5-1.

Table E.2.5-1, Fixed Emergency Light Units Credited for Safe Shutdown Asset Location QDC036 Control Room Equipment Cabinet Area QDC037 Control Room QDC038 Control Room QDC039 Control Room QDC040 Control Room QDC057 / QDC067 Control Room Equipment Cabinet Area QDC060 I QDC061 Control Room Shift Manager's Office QDT018 Comm Corridor - Operations' Hard Hat Rack QDA053 Auxiliary Shutdown Panel Room QDC046 'A' Emergency Diesel Generator Control Panel KJ121 QDC047 'A' Emergency Diesel Generator Panel NE107 QDC048 'A' Emergency Diesel Generator Panel NG03D QDC052 'B' Emergency Diesel Generator Panel KJ122 and NE106 QDC053 'B' Emergency Diesel Generator Panel NE106 QDC054 'B' Emergency Diesel Generator Panel NG04D Note: Multiple industry terms such as operator manual action, operator action, post-fire safe shutdown action, recovery action, and safe shutdown action are used to describe the actions taken by Operations to achieve and maintain safe shutdown following an event. Considering this, operator manual action (OMA) will be used as the inclusive term within this Attachment for actions taken by Operations to achieve and maintain safe shutdown following an event.

E.3 Background Historically, Wolf Creek has credited fixed emergency lighting with 8-hour battery capacity as the means for illuminating safe shutdown equipment and egress paths to the safe shutdown equipment. This was driven by the regulatory requirements identified in Section E.4.1 below. Wolf Creek continues to maintain a deterministic fire protection license bases, with no plan to transition the fire protection program to a NFPA 805 risk informed license bases. However, the Station does desire to apply the flexibility allowed by NFPA 805 (identified in Section E.4.6) regarding emergency lighting for OMAs. In multiple instances NFPA 805 plants have successfully evaluated the use of portable lighting as the primary emergency lighting means for the illumination of OMAs. The

Post-Fire Safe Shutdown Operator Manual Actions Page E-5 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 NFPA 805 evaluation approach utilized for the portable emergency lighting strategy is comparable to that conducted within this evaluation.

The fixed emergency lighting historically credited for illuminating safe shutdown equipment and egress paths to the safe shutdown equipment has been Teledyne Big Beam Model S6L with Model L6100S battery, as shown in Figure E.3-1. This emergency lighting unit is maintenance intensive, particularly regarding the refillable lead acid battery. Addition of battery electrolyte is frequently required, especially in high temperature locations. This results in a high number of preventative maintenance (PM) activities in the effort to ensure unity functionality. An alternative approach for OMA emergency lighting is desired, with portable lighting being the selected resolution, as it is a relatively maintenance free option.

Figure E.3-1, Teledyne Big Beam Emergency Lighting Unit The lamp options approved for use at Wolf Creek for the Teledyne Big Beam Emergency lighting units are identified in Table E.3-1.

Table E.3-1, Teledyne Big Beam Lamp Data Lamp Model Type Power (watt) Distance Where Illumination is 1 foot-candle (ft.)

Par 36 Halogen 12 26 Par 36 LED 4 15 Par 46 Incandescent 21 24 Par 46 LED 4 15 The use of light emitting diodes (LEDs) and the improvement in battery longevity for small device application has resulted in advancements in flashlight technology in recent years. This now makes portable lighting viable as a primary option within the emergency lighting strategy for the Station. The Fenix HM65R headlamp assembly is adequate compensation for the lower illumination distance provided by the LED lamp for Teledyne Big Beam emergency lighting unit application.

Post-Fire Safe Shutdown Operator Manual Actions Page E-6 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.4 Regulatory Information E.4.1 10 CFR 50 Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.

Section III.J, Emergency lighting "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 in access and egress routes thereto.

As identified in the Fire Protection Regulatory Bases (Reference E.15.32),

Appendix R to 10 CFR 50 does not apply to Wolf Creek as a Part 50 Rule. Wolf Creek's relationship to Appendix R is established in Appendix 9.5E of the USAR as part of the approved Fire Protection Program (FPP) documented in the USAR. USAR Appendix 9.5E is a design comparison of the Wolf Creek FPP to 10 CFR 50 Appendix R.

E.4.2 Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Revision 4 Section 4.1.6, Emergency Lighting Emergency lighting should be provided throughout the plant as necessary to support fire suppression actions and safe-shutdown operations, including access and egress pathways to safe-shutdown areas during a fire event.

Section 4.1.6.2, Post Fire Shutdown Lighting is vital to post-fire safe shutdown and emergency response in the event of fire. The licensee should provide suitable fixed and portable emergency lighting, as follows:

a. Fixed, self-contained lighting consisting of units with individual 8-hour minimum battery power supplies should be provided in areas needed for operation of safe-shutdown equipment and for access and egress routes to these areas.

The level of illumination provided by emergency lighting in access routes to and in areas where shutdown functions are performed is sufficient to enable an operator to reach that area and perform the shutdown functions. At the alternative or dedicated shutdown panels, the illumination levels should be sufficient for control panel operators. If a licensee has provided emergency lighting in accordance with Section III.J of Appendix R to 10 CFR Part 50, the licensee should verify by field testing that this lighting is adequate to perform the intended tasks.

Routine maintenance and initial and periodic field testing of emergency lighting systems should ensure their ability to support access, egress, and

Post-Fire Safe Shutdown Operator Manual Actions Page E-7 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 operations activities for the full 8-hour period accounting for anticipated environmental conditions, battery conditions, and bulb life.

b. Suitable battery-powered portable hand lights should be provided for emergency use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

If a central battery or batteries power the emergency lights, the distribution system should contain protective devices necessary to preclude a fire in one area from causing a loss of emergency lighting in any unaffected area required for safe-shutdown operations.

Wolf Creek is not committed to Regulatory Guide 1.189. The Purpose section of the Regulatory Guide states the following:

This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) to meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) section 50.48(a) and (b) (Ref. 1), and 10 CFR Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979" (Ref.

2). These regulations state the requirements governing a civilian nuclear power generating plant's fire protection program (FPPJ.

E.4.3 NUREG-0800, Standard Review Plan Section 9.5.3, Lighting Systems The emergency lighting system(s) is acceptable if the integrated design of the system(s) will provide adequate emergency station lighting in all areas, required for fire fighting, control and maintenance of equipment used for implementing safe shutdown of the plant during all plant operating conditions, and the access routes to and from these areas.

The lighting systems designs will be acceptable if they conform to the lighting levels recommended in NUREG-0700, which is based on the Illuminating Engineering Society of North America (IESNA) Lighting Handbook as related to systems design and illumination levels recommended for industrial facilities.

Volume 1 of the Safety Evaluation Report for Wolf Creek (Reference E.15.36) identifies that the July 1981 version of NUREG-0800 was used in the review of the of Wolf Creek Generating Station.

Post-Fire Safe Shutdown Operator Manual Actions Page E-8 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.4.4 NUREG-0700, Human-System Interface Design Review Guidelines (Rev. 3) 12.1.2.4-4 Emergency Lighting Levels The control room emergency illumination system should be designed to provide a minimum illumination level of 108 lux (10 fc) at all work stations in the main operating area.

Volume 1 of the Safety Evaluation Report for Wolf Creek (Reference E.15.36) identifies that Wolf Creek was required to conduct a detailed control room design review in accordance with NURE-0700 [August 1981 edition].

E.4.5 NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire Section 4.2.3, Information Regarding Environmental Factors Emergency lighting should be provided as required in Section IlI.J of Appendix R to 10 CFR Part 50, or by the plant's approved fire protection program.

Wolf Creek is not committed to NUREG-1852, but it is the guidance document utilized in the OMA feasibility and reliability analysis that was approved by the NRC in License Amendment 191 (Reference E.15.3).

E.4.6 NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

Section 1.5.3(2), Provide adequate protection, including emergency lighting, for essential personnel to perform necessary safety functions as a result of a fire event.

Section B.5.2(3), The lighting should be evaluated to ensure sufficient lighting is available to perform the intended action.

As identified in Section E.3 Wolf Creek is not committed to NFPA 805.

E.4.7 NFPA 101, Life Safety Code (2021 Edition)

Section 7.8.1.3, The floors and other walking surfaces within an exit and within the portions of the exit access and exit discharge designated in 7.8.1.1 shall be illuminated as follows:

(1) During conditions of stair use, the minimum illumination for new stairs shall be at least 10 foot-candles (108 lux), measured at the walking surfaces.

(2) The minimum illumination for floors and other walking surfaces, other than new stairs during conditions of stair use, shall be to values of at least 1 foot-candle (10.8 lux), measured at the floor.

Post-Fire Safe Shutdown Operator Manual Actions Page E-9 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Section 7.9.2.1.1, Emergency lighting facilities shall be arranged to provide initial illumination that is not less than an average of 1 foot-candle (10.8 lux) and, at any point, not less than 0.1 foot-candle (1.1 lux), measured along the path of egress at floor level.

Section 7.9.2.1.2, Illumination levels shall be permitted to decline to not less than an average of 0.6 foot-candle (6.5 lux) and, at any point, not less than 0.06 foot-candle (0.65 lux) at the end of 1-1/2 hours.

Wolf Creek is not committed to NFPA 101. It is utilized as a guide for the design and maintenance of Wolf Creek facilities.

E.4.8 License Event Report 95-005, Failure To Develop Adequate Fire Protection Program Emergency Lighting (Reference E.15.33)

In LER 95-005, Wolf Creek identified the following three procedures that contain safe shutdown actions requiring emergency lighting:

OFN RP-017, Control Room Evacuation

EMG C-0, Loss of All AC Power

OFN NB-034, Loss of All AC Power - Shutdown Conditions E.5 Updated Safety Analysis Report The Updated Safety Analysis Report (USAR) has been revised by change package 20283 to reflect that portable lighting is the primary credited means for illuminating safe shutdown implementing procedures, equipment, and the respective access egress routes to the equipment in the event of a loss of off-site power, a design basis event, or a fire, that renders normal lighting and standby lighting unavailable. The supporting License Amendment Request generated from the change package addresses the USAR 9.5.3.2.3 discussion that emergency lighting is also provided to support firefighting efforts.

Post-Fire Safe Shutdown Operator Manual Actions Page E-10 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.6 Portable Lighting Selection Operations personnel who are responsible for manipulating safe shutdown equipment are required to wear ANSI approved protective hard hats as part of their personal protective gear. The portable emergency lighting will attach to the required hard hat.

Alternatively, it can be directly attached to the head, via the elastic straps, if desired.

The portable emergency lighting equipment supplied is as follows:

Commercially available, Fenix HM65R dual LED beam headlamp, that can be attached to a standard hard hat via an adhesive headlamp attachment or elastic strap with helmet clips. Both attachment options may be used together if desired.

The headlamp can be powered by a single model 18650 rechargeable battery or two disposable CR123 / CR123A batteries. The 18650 rechargeable battery tested in Section E.7 of this document was a 3500 mAh battery (Fenix model ARB-L18-3500). Fenix is now packaging the HM65R headlamp with a 3400 mAh battery (Fenix model ARB-L18-3400). The ARB-L18-3400 is an acceptable alternative, as the capacity reduction is less than 3% which still provides ample margin when comparing performance to the fixed Teledyne Big Beam emergency light. Each of the rechargeable battery models is provided with an electronic circuit that protects it from over charge, over discharge, overheating, and short circuit. In the event that the electronic circuit protection fails, pressure relief vents are provided to expel waste gas generated from an internal short. Additionally, as documented in References E.15.42 and E.15.43, the rechargeable batteries conform to the testing requirements of section 38.3 from the United Nations (UN) Publication:

Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria. Section UN 38.3 addresses testing requirements for lithium metal and lithium ion batteries that are shipped internationally. The UN required testing includes: altitude simulation, thermal, vibration, shock, external short circuit, impact/crush, overcharge, and forced discharge. The protection features described above and the independent testing confirming UN38.3 conformance, provides reasonable assurance that consequential failure for the Fenix model ARB-L18-3400 or ARB-L18-3500 rechargeable battery is unlikely.

See Figure E.6-1 for the headlamp attached to a standard hard hat via an adhesive headlamp attachment. Figure E.6-2 is the head lamp attached with adhesive headlamp attachment and elastic strap with helmet clips. Attachment E.1 provides the detailed product specifications for the headlamp, adhesive attachment, and rechargeable battery.

The Fenix HM65R stated performance is per ANSI/PLATO FL 1 criteria for the following:

Light Output - Total light output measured in Lumens.

Run Time - Tested with fresh batteries from 30 seconds after the light is turned on until the light output reaches 10% of the initial measurement.

Post-Fire Safe Shutdown Operator Manual Actions Page E-11 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01

Beam Distance - The distance, measured in meters, at which the light projects a useful amount of light, measured at 0.25 lux. (0.25 lux is approximately the equivalent of light emitted from a full moon "on a clear night in an open field.")

Peak Beam Intensity - The brightest point in the beam measured in candela.

Impact Resistance - The height, measured in meters, from which the light can be dropped onto cured concrete and still work properly. This testing is completed by dropping the product six (6) times using drop orientations that approximate each side of a cube. Dropped samples cannot have any visible cracks or breaks and the light must remain fully functional.

Water Proof - Water submersion depth rating, measured in meters. This test must be done after impact resistance testing is completed to ensure water tightness under real-life conditions.

In addition to the testing required by ANSI/PLATO FL 1, the headlamp is subject to the following test protocols to ensure reliability in extreme environments:

Shakeout Test - Evaluates the scratch and wear resistance of the light's surface.

Bending Test - Challenges the bending degree and inherent strength of internal wiring systems.

Salt Spray Test - Puts the light into corrosion provoking conditions beyond what most will ever face.

Ultraviolet Radiation Test - Monitors the light's performance after intense exposure to UV radiation.

Environmental Test - Pushes low and high temperature ranges to verify performance at extremes.

Vibration Test - Jars the light over thousands of cycles to validate resistance to rigorous forces.

Switch Test - Checks the switch function well over the projected lifespan of the light.

Temperature Test - determines heat generation and dissipation of the light.

The Fenix HM65R headlamp is not a wireless communication device, as such it does not transmit or receive radio waves. Additionally, Wolf Creek subjected the Fenix HM65R headlamp to a commercially available electromagnetic field (EMF) radiation tester (Lutron EMF-823). Contact readings with the meter sensor and headlamp were 0.00 micro Tesla for all lighting operation modes using both battery types (a rechargeable battery and two CR123 batteries). Therefore, the Fenix HM65R headlamp may be used around components that are sensitive to radio frequency and/or EMF interference.

Post-Fire Safe Shutdown Operator Manual Actions Page E-12 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Figure E.6-1, Fenix HM65R Headlamp on Standard Hard Hat (with adhesive attachment)

Figure E.6-2, Fenix HM65R Headlamp on Standard Hard Hat (with adhesive attachment, elastic strap and helmet clips)

Post-Fire Safe Shutdown Operator Manual Actions Page E-13 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 The Fenix HM65R headlamp selected provides a reliable method for hands free use, excellent lumen output, long LED life, flexibility of multiple lighting modes, long battery life, a battery life indicator, and battery recharging capability. The headlamp has the option for the following lighting configurations:

Spot Light (turbo, high, medium , and low) - best for distance lighting when traversing from one area to another.

Flood Light (high, medium, and low) - best for close range lighting such as reading a procedure or manipulating a component.

The headlamp battery level indication for the rechargeable battery is accessed by a single click of either the Spotlight or Floodlight switch with the headlamp in the off position. See Figure E.6-3 for the battery light indicator. Battery life indicator is as follows:

Four lights on: Battery is charged 81% to 100%

Three lights on: Battery is charged 61% to 80%

Two lights on: Battery is charged 41% to 60%

One light on: Battery is charged 21% to 40%

One light flashes: Battery is charged between 0% and 20%

Figure E.6-3, Fenix HM65R Headlamp with Battery Charge Status Illuminated

Post-Fire Safe Shutdown Operator Manual Actions Page E-14 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 The headlamp is provided with a USB Type C connection. This allows direct charging with a cable via an AC adapter or a Type A USB connection. The connection is for charging only and does not transfer data (Reference E.15.40). Typical battery charging will be provided from a multi-bay battery charger located in the Work Control Center area across from the Control Room.

E.7 Demonstration E.7.1 Performance Test In an effort to compare illumination levels between the fixed Teledyne Big Beam emergency lighting, the Fenix HM65R headlamp, and a portable light model (Underwater Kinetics UK4AA-AS2) approved by the NRC for a peer Nuclear Power Plant that has transitioned to NFPA 805, a lighting performance test was conducted. The test method and results are documented in Work Order 21-468651-000. Photos from the performance test are provided in Attachment E.4. A series of tests were conducted as identified in Table E.7.1-

1. Relevant illumination test setup information is as follows:

Portable lighting was attached to ANSI hard that was then zip tied to a step ladder to ensure stability when obtaining illumination level readings.

The Fenix HM65R headlamp was placed in the High Spotlight mode when discharging batteries for the specified duration.

Each component light test was in line to the target representing a component in the plant (see Attachment E.4, Photo E.4.A-1).

Target illumination levels for 8 and 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months discharge testing was collected at 5 and 10 ft. distances only.

Each component light test was conducted a specified distance from the target.

Aiming for portable lighting and the Teledyne Big Beam unit was adjusted to provide optimum target illumination at each tested distance.

Only one beam from the Teledyne Big Beam unit was aimed directly at the target, consistent with plant aiming configurations. The remaining beam was configured so that it would not contribute significant illumination to the target.

The bottom of the Teledyne Big Beam unit was located 7'-1", from the floor, comparable to the in-plant configuration.

The Teledyne Big Beam unit was connected to AC power, with a fully charged battery, until the 8-hour illumination test was conducted.

Post-Fire Safe Shutdown Operator Manual Actions Page E-15 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01

The Teledyne Big Beam unit was illuminated by pressing the test switch with AC power connected. The unit illuminated automatically with AC power removed.

Discharge testing for the Teledyne Big Beam unit was conducted at 8-hours only, consistent with 10 CFR 50 Appendix R, Section III.J.

Photos of component illuminating tests were taken from a tripod at similar locations and the same camera setting for each photo.

A light meter (reading in foot-candle) was attached to the target.

The model LX-1128SD light meter (Serial No. T016275) utilized has an accuracy of + 4%. The light meter readings recorded in Tables E.7.1-2 through E.7.1-8, do not account for meter accuracy. See Attachment E.2 for light meter data and calibration certificate.

Post-Fire Safe Shutdown Operator Manual Actions Page E-16 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table E.7.1-1, Lighting Tests Performed Light Type Test 1 Test 2 Test 3 Test 4 Test 5 Test 6 Test 7 Test 8 Test 9 1.A 2.A 5.A 6.A Illumination of Illumination of Illumination of Illumination of target at target at procedure target at a various various (120 volt AC distance of 5 Teledyne distances distances power and 10 ft. with N/A N/A N/A N/A N/A Big Beam (120 volt AC with Operator provided) battery power 2 ft. in front of discharged provided) Target (120 8-hours volt AC power provided) 3.B 4.B Illumination of Illumination of 7.B 8.B 9.B Illumination of Illumination of procedure target with Illumination of Illumination of Illumination of target at target at 5.B.1 rechargeable target at target at target at a various various Rechargeable battery at various various distance of 5 Fenix distances distances battery distance of 5 distances distances and 10 ft. with HM65R with with discharged at and 10 ft. and with new with CR123 CR123 Headlamp rechargeable rechargeable least 1.5 battery CR123 batteries batteries battery fully battery hours discharged: batteries discharged discharged N/A N/A Each charged discharged 6.B.1 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 8-hours 5.B.2 individual 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 8-hours CR123 lighting 6.B.2 batteries mode tested 16-hours (test discharged conducted for at least three 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months separate times) 3.C 4.C 5.C 6.C Illumination of Illumination of Illumination of Illumination of Underwater target at target at procedure target at a Kinetics N/A N/A various various with batteries distance of 5 N/A N/A N/A UK4AA-AS2 distances distances discharged and 10 ft. with with new with batteries 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months batteries batteries discharged discharged 8-1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months hours

Post-Fire Safe Shutdown Operator Manual Actions Page E-17 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Tables E.7.1-2 through E.7.1-8 provide the results of the lighting performance test for Teledyne Big Beam emergency light, a Fenix HM65R headlamp, and an Underwater Kinetics UK4AA-AS2 flashlight. The Underwater Kinetics flashlight has been approved for a peer Nuclear Plant by the NRC via a NFPA 805 license amendment request. The Underwater Kinetics UK4AA-AS2 model flashlight with hard hat clip was not selected for illuminating operator actions at Wolf Creek. The performance data was included as a comparison point for the portable lighting proposed by Wolf Creek and portable lighting that has been previously approved for a plant with a NFPA 805 licensing bases. Attachment E.3 provides the detailed product specifications for the Underwater Kinetics UK4AA-AS2 flashlight.

The illumination testing revealed the following:

The Fenix HM65R headlamp with a rechargeable battery that has been continuously discharged on High Spotlight mode for a period of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months provides superior illumination in all lighting modes, with the exception of Low Floodlight, when compared to a fully charged Teledyne Big Beam fixed emergency lighting unit comparable to those installed at Wolf Creek.

This demonstrates that the Fenix HM65R headlamp will provide lighting levels for illuminating implementing procedures, safe shutdown equipment, and the respective access egress routes to the equipment that exceed those provided by fixed emergency lighting units.

The Teledyne Big Beam fixed emergency lighting unit maximum illumination level was 3.8 foot-candles at 5 ft. from the target with a fully charged battery.

Consistent with NUREG-0700 guidance for control room emergency illumination, the Fenix HM65R headlamp provides an illumination level greater than 10 foot-candles at a distance of 5 ft. from the target for the following configurations:

o Rechargeable battery on Turbo Spotlight, High Spotlight, Medium Spotlight, or High Flood Light with a battery that has been discharged up to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months on High Spotlight mode.

o CR123 batteries on Turbo Spotlight, High Spotlight, Medium Spotlight, or High Flood Light with batteries that have been discharged up to 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months on High Spotlight mode.

With an individual positioned directly in front of the target component, the Fenix HM65R headlamp provides significant illumination improvement of target component compared to the illumination provided by the fixed emergency light unit.

The Fenix HM65R headlamp provided substantial illumination improvement of the procedure in hand when compared to the illumination provided by the fixed emergency lighting unit.

Post-Fire Safe Shutdown Operator Manual Actions Page E-18 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01

The Fenix HM65R headlamp with disposable CR123 batteries did not perform as well from a runtime perspective when compared to rechargeable battery performance. This is expected since the capacity for the two series CR123 batteries is 1500 mAh compared to a 3500 mAh rating for the single rechargeable 18650 battery. Considering this, the CR123 battery will not be the primary battery source for normally daily use of the headlamps. However, due to its long storage life (approximately 10 years), CR123 / CR123A will be preferred battery for strategically staging in the plant for emergent battery replacement.

The Fenix HM65R headlamp on Turbo Spotlight mode does provide superior lighting to the other lighting modes for the headlamp but at a sacrifice of reduced runtime. Considering this, it will be recommended that Operations personnel use either High Spotlight or High Floodlight illumination modes as the preferred illumination selections in an effort to optimize runtime performance while still realizing a high illumination output from the headlamp.

When battery capacity for the Fenix HM65R headlamp does not support the selected illumination mode, the headlamp will automatically adjust to a lower illumination level that the battery can support. At its lowest performance level, the headlamp will switch to Low Floodlight mode. This transition can be used by the operator as an aid to signal that battery replacement is warranted. Additional informational testing (not documented in work order 21-468651-000) of the Fenix HM65R headlamp with a rechargeable battery revealed that the headlamp remained in the Turbo Spotlight illumination mode for over four hours. It ultimately switched to Low Floodlight mode where it continued to illuminate for more than eight hours. At Low Floodlight mode, as shown in Photo E.4.E-5, sufficient lighting is available to provide immediate travel path illumination. This provides reasonable assurance that an Operator should not be left in the dark with a significantly discharged headlamp battery.

The Fenix HM65R headlamp performance was significantly superior to the Underwater Kinetics UK4AA-AS2 model flashlight in both illumination levels and battery run time.

Post-Fire Safe Shutdown Operator Manual Actions Page E-19 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Illumination Level (foot-candle)

Turbo Test # Light Type Battery Information Spot High Med Low High Med Low (ft.- Spot Spot Spot Flood Flood Flood candle) 3.B Rechargeable Battery Fully 221.3 114.5 36.3 14.8 35.8 11.7 0.8 Charged 4.B Rechargeable Battery Fenix HM65R 224.1 116.1 36.6 14.9 36.6 11.9 0.8 Discharged 1.5 Hours1 Headlamp 7.B New CR123 Batteries 222.2 116.7 37.1 15.2 32.7 10.7 0.7 8.B CR123 Batteries Discharged 220.4 119.1 37.9 15.8 33.5 11.0 0.7 1.5 Hours1 3.C Underwater New AA Batteries 42.4 Kinetics UK4AA-4.C AS2 AA Batteries Discharged 1.5 39.7 Hours Note:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

2. Teledyne Big Beam emergency lighting unit was not tested at 2 ft. distance, as fixed emergency lighting in the plant is not located within 2 ft.

of components to be illuminated.

Post-Fire Safe Shutdown Operator Manual Actions Page E-20 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Illumination Level (foot-candle)

Test # Light Type Battery Information Turbo High Med Low High Med Low Spot Spot Spot Spot Flood Flood Flood 3.B Rechargeable Battery Fully 116.6 64.3 20.4 8.3 17.9 5.8 0.3 Charged 4.B Rechargeable Battery 116.9 63.9 20.4 8.3 17.8 5.8 0.3 Discharged 1.5 Hours1 6.B.1 Rechargeable Battery 105.4 57.6 18.2 7.5 17.2 5.4 0.3 Discharged 8 Hours1 6.B.2 Rechargeable Battery Discharged 16 Hours1 108.4 58.2 18.5 7.6 17.4 5.5 0.3

1 Fenix HM65R 6.B.2 Rechargeable Battery Headlamp 109.0 65.5 20.8 8.5 18.7 5.9 0.3

2 Discharged 16 Hours1 6.B.2 Rechargeable Battery Discharged 16 Hours1 107.5 63.7 20.4 8.3 18.6 5.9 0.3

3 7.B New CR123 Batteries 119.1 63.0 20.1 8.2 17.2 5.6 0.3 8.B CR123 Batteries Discharged 114.4 61.9 19.4 7.9 16.9 5.5 0.3 1.5 Hours1 9.B CR123 Batteries Discharged Note 2 Note 2 Note 2 Note 2 Note 2 Note 2 0.3 8 Hours1 3.C New AA Batteries 27.9 4.C AA Batteries Discharged 1.5 Underwater Kinetics 23.6 Hours UK4AA-AS2 6.C AA Batteries Discharged 8 Note 3 Hours 1.A Battery on AC Power 3.8 Teledyne Big Beam 6.A Battery Discharged 8 Hours 2.6 Notes:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

2. At some point during the eight hours of discharge on High Spotlight mode, the Fenix HM65R headlamp automatically transferred to Low Flood Light mode due to low battery capacity. The values recorded for 8-hour test results were all with the Fenix HM65R headlamp on Low Flood Light mode. Based on results of 8-hour testing, no testing was conducted with the CR123 batteries for a 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months discharge duration.

3. Between hour 6 and 7 of discharge, the battery capacity for the Underwater Kinetics UK4AA-AS2 flashlight was depleted.

Post-Fire Safe Shutdown Operator Manual Actions Page E-21 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 1ao1e t:. t .1-4, L1gn11ng t"errormance - L1gm I en 11 UJ n. rrom I ar get Illumination Level (foot-candle)

Test # Light Type Battery Information Turbo High Med Low High Med Low Spot Spot Spot Spot Flood Flood Flood 3.B Rechargeable Battery Fully Charged 34.4 19.2 6.1 2.5 5.6 1.8 0.0 4.B Rechargeable Battery Discharged 1.5 35.8 19.5 6.2 2.5 5.6 1.7 0.0 Hours1 6.B.1 Rechargeable Battery Discharged 8 34.8 19.3 6.1 2.5 6.0 1.8 0.0 Hours1 6.B.2 Rechargeable Battery Discharged 16 33.1 18.8 6.0 2.4 5.8 1.8 0.0

1 Hours1 Fenix HM65R 6.B.2 Headlamp Rechargeable Battery Discharged 16 35.3 19.9 6.3 2.6 6.3 1.9 0.0

2 Hours1 6.B.2 Rechargeable Battery Discharged 16 33.2 19.9 6.1 2.5 6.1 1.8 0.0

3 Hours1 7.B New CR123 Batteries 36.1 18.9 6.0 2.5 5.7 1.8 0.0 1

8.B CR123 Batteries Discharged 1.5 Hours 35.3 18.9 6.0 2.4 5.8 1.8 0.0 1

9.B CR123 Batteries Discharged 8 Hours Note 2 Note 2 Note 2 Note 2 Note 2 Note 2 0.0 3.C Underwater New AA Batteries 6.4 4.C Kinetics UK4AA- AA Batteries Discharged 1.5 Hours 4.2 6.C AS2 AA Batteries Discharged 8 Hours Note 3 1.A Teledyne Big Battery on AC Power 1.4 6.A Beam Battery Discharged 8 Hours 1.3 Notes:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

2. At some point during the eight hours of discharge on High Spotlight mode, the Fenix HM65R headlamp automatically transferred to Low Flood Light mode due to low battery capacity. The values recorded for 8-hour test results were all with the Fenix HM65R headlamp on Low Flood Light mode. Based on results of 8-hour testing, no testing was conducted with the CR123 batteries for a 16-hour discharge duration.

3. Between hour 6 and 7 of discharge, the battery capacity for the Underwater Kinetics UK4AA-AS2 flashlight was depleted.

Post-Fire Safe Shutdown Operator Manual Actions Page E-22 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table E.7.1-5, Lighting Performance - Light Fifteen (15) ft. from Target Illumination Level (foot-candle)

Test # Light Type Battery Information Turbo High Med Low High Med Low Spot Spot Spot Spot Flood Flood Flood 3.B Rechargeable Battery Fully 18.4 9.7 3.0 1.3 2.8 0.9 0.0 Charged 4.B Rechargeable Battery Fenix HM65R 18.3 9.9 3.1 1.3 2.8 0.9 0.0 Discharged 1.5 Hours1 Headlamp 7.B New CR123 Batteries 18.2 9.3 3.0 1.3 2.9 0.9 0.0 8.B CR123 Batteries Discharged 17.8 9.5 2.9 1.2 2.7 0.9 0.0 1.5 Hours1 3.C Underwater New AA Batteries 4.3 Kinetics UK4AA-4.C AS2 AA Batteries Discharged 1.5 2.9 Hours 1.A Teledyne Big Beam Battery on AC Power 0.8 Note:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

Post-Fire Safe Shutdown Operator Manual Actions Page E-23 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table E.7.1-6, Lighting Performance - Light Twenty (20 ft. from Target Illumination Level (foot-candle)

Test # Light Type Battery Information Turbo High Med Low High Med Low Spot Spot Spot Spot Flood Flood Flood 3.B Rechargeable Battery Fully 10.6 5.6 1.7 0.7 1.7 0.5 0.0 Charged 4.B Rechargeable Battery Fenix HM65R 10.6 5.8 1.8 0.7 1.7 0.5 0.0 Discharged 1.5 Hours1 Headlamp 7.B New CR123 Batteries 10.4 5.5 1.7 0.7 1.7 0.5 0.0 8.B CR123 Batteries Discharged 9.7 5.3 1.6 0.6 1.6 0.5 0.0 1.5 Hours1 3.C Underwater New AA Batteries 2.4 Kinetics UK4AA-4.C AS2 AA Batteries Discharged 1.5 1.7 Hours 1.A Teledyne Big Beam Battery on AC Power 0.5 Note:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

Post-Fire Safe Shutdown Operator Manual Actions Page E-24 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table E.7.1-7, Lighting Performance - Procedure Illumination Level Illumination Level (foot-candle) Standing in Front of Target Test # Light Type Battery Information Turbo High Med Low High Med Low Spot Spot Spot Spot Flood Flood Flood 5.B.1 Rechargeable Battery 690.0 383.1 124.8 51.7 108.6 35.4 2.5 Fenix HM65R Discharged 1.5 Hours1 5.B.2 Headlamp CR123 Batteries Discharged 647.2 348.7 113.3 47.0 107.6 35.6 2.5 1.5 Hours1 5.C Underwater AA Batteries Discharged 1.5 Kinetics UK4AA- Hours 72.1 AS2 5.A Teledyne Big Beam Battery on AC Power 0.0 Note:

1. Fenix HM65R headlamp battery was discharged on High Spotlight.

Table E.7.1-8, Liahtina Perf, Teled Bia B T Ill Level with 0 . F fT Distance Light Test 5.A Test # Light Type Battery Information from Target Procedure Illumination Level (foot-candle)

(ft.)

5 0.0 10 0.0 2.A Teledyne Big Beam Battery on AC Power 15 0.0 20 0.0

Post-Fire Safe Shutdown Operator Manual Actions Page E-25 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.7.2 Operations' Assessment In an effort to solicit feedback from Operations regarding their opinion of the portable lighting and its use as the primary emergency lighting method for illuminating operator manual actions, the portable lighting equipment discussed in E.6 was provided to multiple Operators for in plant use. Feedback received was positive for the Fenix HM65R headlamp assembly.

E.8 Preventive Maintenance Activities E.8.1 The Fenix HM65R headlamp assembly will be standard issue to all on shift Operations personnel responsible for manipulating plant equipment. It will be attached to their hard hat and used in situations where plant activities require additional illumination to safely perform their job function. Each Operator will be responsible for proper operation and upkeep of the headlamp, including battery charge status and battery replacement. Information regarding headlamp responsibilities and upkeep will be provided in a Standing Order, Desktop Instruction, or equivalent. There will be no formal PM for the individual headlamps issued to Operations personnel.

E.8.2 AP 21-001, Conduct of Operations Attachment H, Start of Shift Crew Briefing This Attachment is utilized by the Control Room Supervisor (CRS) to ensure a consistent crew briefing at the beginning of the shift. It has been revised to include a step for the CRS to ensure that Operators assigned OFN RP-017, OFN KC-016, EMG C-0, and/or OFN NB-034 manual action responsibility to confirm acceptable function of their headlamp and that it is indicating a charged condition (four battery level indication lights on) at the beginning of the shift. Typically, rechargeable batteries will be utilized during daily operation considering their increased run time, and to limit the amount of waste associated with the use of disposable batteries.

Post-Fire Safe Shutdown Operator Manual Actions Page E-26 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.8.3 Spare Portable Lights and Batteries Sufficient replacement batteries and spare portable headlamps are strategically located in the plant, and periodically inventoried, to ensure that a minimum eight hours of portable lighting is available for Operations staff personnel responsible for the manipulation of safe shutdown equipment. Specifically, the following emergency equipment lockers in the plant are equipped with at least three (3)

Fenix HM65R headlamps and at least six (6) sets of CR123 / CR123A batteries (12 total batteries). The equipment in the lockers is inspected and inventoried in accordance with STN GP-009, Emergency Equipment Verification.

Auxiliary Building 2026' - Aux Shutdown Panel Locker

Auxiliary Building 2026' - South Electrical Penetration Room Locker

Control Building 2000' - 'B' ESF Switchgear Room Locker

Turbine Building 2033' Locker Additional Fenix HM65R headlamps, rechargeable batteries, charging station, and CR123 / CR123A batteries are located in the Work Control Center area across from the Control Room.

Spare hardhats with portable lighting will also be provided in the Control Room for OFN RP-017 assigned Operators that would be exiting from the Control Room directly into the Auxiliary Building, without passing by the hard hat rack storage area. This equipment will also be inventoried in accordance with STN GP-009.

E.9 Defense-In-Depth E.9.1 8-Hour Fixed Emergency Lights That Remain in Safe Shutdown Strategy As identified in Section E.2.5, fixed emergency lighting units with 8-hour battery capacity for the Control Room, Auxiliary Shutdown Panel, and emergency diesel generator control panel areas will continue to be credited in the emergency lighting illumination response strategy for safe shutdown. This is in recognition that these areas may warrant continuous manning in response to potential postulated events, such as fire or loss of offsite power. It is prudent to retain the current emergency lighting strategy for these areas in an effort to promote human factoring, since there are many indications and controls in these areas that require Operator attention. Additionally, the emergency lighting unit illuminating the Operation's hard hat rack just outside the Control Room will be credited as an 8-hour emergency light to ensure illuminated access/egress for Control Room personal to obtain their hard hats, containing the Fenix HM65R headlamp.

Post-Fire Safe Shutdown Operator Manual Actions Page E-27 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.9.2 Fixed Emergency Lights That Are Being Downgraded With limited exception, the fixed emergency lighting (excluding Table E.2.5-1) that was previously credited for illuminating operator manual actions will remain installed within the plant. The E-1L8900 identified head lamp aiming positions will be retained. However, this fixed emergency lighting, which will be treated comparable to life safety emergency lighting from a battery life (1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) and preventive maintenance perspective, is considered supplemental to portable lighting. This lighting and the remaining 1.5-hour fixed emergency lighting will support firefighting efforts and life safety access/aggress.

E.9.3 OFN RP-017, Control Room Evacuation This procedure provides the Operator actions for evacuating the Control Room due to fire. OFN RP-017 contains steps for each Operator implementing the procedure to obtain a spare set of CR123 / CR123A batteries strategically located in field emergency lockers discussed in Section E.8.3 of this Attachment. A step has also been included at the completion of OFN RP-017 Attachment D for the Operator performing the Auxiliary Building actions to obtain spare Fenix HM65R headlamps and CR123 / CR123A batteries as necessary from the available locations discussed in Section E.8.3 to distribute to the Operations team. This will allow future refresh of portable lighting if necessary.

E.9.4 Photoluminescent Labels All OMAs outside the Control Room that are required for PFSSD are provided with a photoluminescent label as shown in Figures E.9.4-1 and E.9.4-2. The purpose of the labels is to improve the identification and response time for locating PFSSD equipment/components during potential plant fire scenarios when normal lighting has failed. Change package 012523 approved the use of the labels for identification of PFSSD components. The change package also conducted performance testing of the labels to assess their illumination capability. The change package concluded that the labels will be an aid to Operators in locating PFSSD equipment, especially in a low light situation.

Post-Fire Safe Shutdown Operator Manual Actions Page E-28 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 OF -017 U L ACTI L H -7 FP07O 2 Figure E.9.4-1, Photoluminescent Label Figure E.9.4-2, Photoluminescent Label (Normal Lighting) (Normal Lighting Off)

E.10 Feasibility and Reliability Analysis E.10.1 Operator Manual Actions in Response to Fire NUREG-1852 defines feasible action as:

An action that is analyzed and demonstrated as being able to be performed within an available time so as to avoid a defined undesirable outcome. As compared to a reliable action (see definition), an action is considered feasible if it is shown that it is possible to be performed within the available time (considering relevant uncertainties in estimating the time available); but it does not necessarily demonstrate that the action is reliable. For instance, performing an action successfully one time out of three attempts within the available time shows that the action is feasible, but not necessarily reliable.

NREG-1852 defines reliable action as:

A feasible action that is analyzed and demonstrated as being dependably repeatable within an available time, so as to avoid a defined adverse consequence, while considering varying conditions that could affect the available time and/or the time to perform the action. As compared to an action that is only feasible (see definition), an action is considered to be reliable as well if it is shown that it can be dependably and repeatably performed within the available time, by different crews, under somewhat varying

Post-Fire Safe Shutdown Operator Manual Actions Page E-29 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 conditions that typify uncertainties in the available time and the time to perform the action, with a high success rate. All reliable actions need to be feasible, but not all feasible actions will be reliable.

Lighting is an environmental factor that could negatively impact the ability to perform operator actions, as such it needs be considered when assessing the acceptability of manual actions.

E-1F9900 (approved via License Amendment 191) documents the feasibility and reliability of operator manual actions, considering NUREG-1852, for a fire outside the Control Room. The evaluation identifies six distinct operator actions. These actions are implemented by OFN KC-016, Fire Response. The use of hard hat mounted portable lighting as the credited primary means for illuminating safe shutdown implementing procedures, equipment, and the respective access egress routes to the equipment does not adversely affect OMA implementation, uncertainty, or resulting time margin based on the bulleted items below.

Portable lighting is attached to a hard hat, which is mandatory personal safety gear required to be worn within the industrial areas of the plant.

This includes areas where safe shutdown equipment is located.

Operations personnel responsible for OMA implementation will either already have a hard hat with portable lighting donned, will obtain a spare hard hat from the Control Room, or will obtain their hard hat from the hard hat storage rack outside the Control Room. The hard hat storage rack and Control Room is illuminated by Appendix R credited 8-hour fixed emergency lighting. The action to ensure a hard hat is donned prior to commencing travel for OMA implementation is the same as that required prior to the hard hat being provided with credited portable emergency lighting.

As demonstrated in Section E.7 and Attachment E.4, the portable lighting is brighter and has a wider and longer illumination distance than the fixed emergency lighting. With the portable lighting being attached to the hard hat worn by the Operator, the illumination path will follow the head movements of the individual, ensuring that eyes on travel path will be consistently illuminated. This will result in prompt identification and avoidance of obstructions and tripping hazards, allowing safe transit.

Table E.7.1-7 reveals that the hard hat mounted portable lighting provides significant improvement in the illumination of implementing procedure in hand when compared to fixed emergency lighting. This ensures prompt identification of procedure steps as well as a higher confidence in maintaining proper place keeping within the procedure.

Tables E.7.1-2 and E.7.1-8 reveal that the hard hat mounted portable lighting provides significant illumination improvement of the component to be manipulated when the Operator is positioned in front of the component

Post-Fire Safe Shutdown Operator Manual Actions Page E-30 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 in preparation for OMA implementation. This aids the Operator in confirming that the correct component has been identified for manipulation.

Operations personnel implementing the OMAs are familiar with the layout of the plant and are trained on safe shutdown component location, including that the majority of fixed emergency lighting will no longer be credited for safe shutdown and may not be available during a safe shutdown event. With the credited emergency lighting being on person, there is no restriction on specific travel path, allowing the Operator to focus on immediate actions without the need for a lookahead to the next fixed emergency light location. To improve Operator recognition of elevation location within stairwells, work order 21-468651-008 will install a readily identifiable label identifying Building and Elevation on the stairwell interior side at each egress door. Location confusion at corridors and intersections is not anticipated, as each is unique and with their plant knowledge and aid of the portable lighting, an Operator will be able to scan the area rapidly to confirm their location.

Fixed emergency lighting is not being removed. It will be downgraded to a life safety designation for access/egress. This emergency lighting will continue to be maintained and periodically tested, providing reasonable assurance that the majority of the fixed emergency lighting will be available for illumination for at least 90 minutes following loss of charging power to the respective units.

An in plant demonstration of OMAs was not conducted with portable lighting as it was not readily feasible to blackout the majority of the plant to assess the practical application of portable emergency lighting. However, the multi-hour performance testing documented in Section E.7 and Attachment E.4 provides ample demonstration that the portable lighting provides superior illumination and flexibility for use when compared to the fixed emergency lighting. This, coupled with the bulleted items above supports a reasonable assurance conclusion that OMA time margins will not be adversely affected by the use of hard hat mounted portable lighting as the primary emergency lighting means. The human centered uncertainty time limitations established in Section 8 of E-1F9900 remain bounding.

Fire Area A-16 has the longest, bounding manual action timeline.

Considering time allotments for fire indicated, diagnosis, performance of manual action, and uncertainty, the analyzed timeline for OMA performance is 67 minutes with 27 minutes required for the actual field performance of the operator actions. Applying the full OMA assigned uncertainty time of 26 minutes results in 53 minutes that emergency lighting would be required to illuminate the egress path, procedure, and safe shutdown equipment.

E-1F9915 (approved via License Amendment 214) documents the step by step analysis of operator manual actions, considering 10 CFR 50 Appendix R, for a Control Room fire. This analysis provides the timing bases demonstrating that the PFSSD functions (Reactivity Control, Reactor Coolant Makeup and Inventory

Post-Fire Safe Shutdown Operator Manual Actions Page E-31 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Control, Decay Heat Removal, Process Monitoring and Support) are satisfied prior to reaching unrecoverable conditions. These steps are implemented by OFN RP-017, Control Room Evacuation. The procedure is divided into attachments with different Operator's having the responsibility of completing their assigned attachment. The Attachments supporting post-fire safe shutdown are coordinated during implementation. Required action time limits are 67 minutes or less, with the exception of isolating the RWST to the safety injection test header, which has a 71 hour8.217593e-4 days 0.0197 hours 1.173942e-4 weeks 2.70155e-5 months time limit.

Periodic performance timing of the manual actions required to achieve and maintain PFSSD per OFN KC-016 and OFN RP-017 is performed by Operations personnel in accordance with AI 21-017, Timed Fire Protection Actions Validation.

This timing validation by multiple personnel demonstrates overall manual action feasibility and reliability from a performance perspective. The portable lighting supports acceptable feasibility based on the following:

The illumination tests document in Section E.7 reflect that the Fenix HM65R headlamp provides superior lighting, when compared to Teledyne Big Beam, for illumination of procedure, safe shutdown equipment, and egress pathways.

Performance demonstrations per AI 21-017 reflect that the manual actions supporting OFN KC-016 or OFN RP-017 implementation are accomplished in under an hour which is well within the battery capacity of the portable lighting.

The photoluminescent component labels discussed in Section E.9.4 aid in Operator identification of post-fire safe shutdown equipment. This minimizes time required to locate equipment for manipulation.

There are no other environmental factors (radiation, temperature, humidity, smoke, toxic gas, or noise) that negatively impact the ability to perform operator manual actions at Wolf Creek, as Operators will not have to traverse through the event area to perform OMAs. Additionally, the Fenix HM65R headlamp is IP68 rated (dust-proof and waterproof - fully submersible to 6.5 feet for 30 minutes) per ANSI/IEC 60529. This ensures protection of the headlamp during normal daily use.

Reliability of the emergency portable lighting is ensured by the periodic maintenance activities discussed in Section E.8 coupled with the spare portable lighting and batteries available at multiple emergency equipment locker locations.

This ensures that sufficient portable lighting will be available for more than 8-hours following the onset of a fire event that renders normal lighting and standby lighting unavailable.

Post-Fire Safe Shutdown Operator Manual Actions Page E-32 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.10.2 Operator Manual Actions in Response to a Non-Fire Event The previously discussed Fenix HM65R headlamp being used for OMAs in response to fire conditions is also adequate as the primary emergency lighting option for non-fire event conditions warranting Operator action outside the Control Room.

E.11 Future Evaluation of Equivalent Portable Lighting It is recognized that obsolescence challenges and future advancements in portable lighting and batteries may result in a desire to utilize equivalent replacement portable lighting and/or batteries in lieu of the models discussed in this Attachment. The portable lighting and batteries identified in this Attachment are considered tools. Typically, a tool is not controlled by design configuration. However, considering the importance of this portable lighting in the support of safe shutdown, a hybrid approach will be used to control the use of equivalent replacement portable lighting models and batteries. The evaluation of equivalent replacement portable lighting and batteries may be conducted without revision to this Attachment provided the review is documented in a work order (or equivalent) and addresses the following attributes:

Post-Fire Safe Shutdown Operator Manual Actions Page E-33 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Headlamp The headlamp shall satisfy the following:

Attach to the hard hat via non-slip strap, elastic strap with helmet clips, or an adhesive headlamp attachment

Dual LED light (both spot and flood) with Low Medium and High light outputs

Adjustable tilt head

Minimum illumination rating on High Spotlight - 400 Lumens

Minimum illumination rating on High Floodlight - 400 Lumens

Minimum run time rating on High Spotlight - 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months

Minimum run time rating on High Floodlight - 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months

Maximum Weight (excluding battery)- 8 ounces

Minimum Ingress Protection (IP) rated IP68 per ANSI/IEC 60529

Conforms to ANSI/PLATO FL 1 or UL S8001 Battery The battery requirements for the Fenix HM65R headlamp are per Table E.11-1.

Table E.11-1, Battery Requirements Item # Parameter Rechargeable 18650 CR123 / CR123A 1 Type Lithium-ion or Lithium or Alkaline equivalent with: (Two required)

1) protection circuitry to prevent short circuit, over charge, over discharge, and overheating

2) Pressure relief venting 2 Nominal Voltage 3.6 volts 3.0 volts 3 Capacity 3400 mAh or greate r 1500 mAH or greater 4 Charging Cycles 500 or more at up to N/A 75% capacity 5 Independent Testing Conforms to UN38.3 N/A (Reference E.15.44) or equivalent Batteries for the Fenix HM65R headlamp shall satisfy the requirements of Table E.11-1.

For an alternate headlamp to the Fenix HM65R, rechargeable batteries shall be compatible with the headlamp assembly of choice, provide the circuit protection, pressure relief venting, charging cycles, and independent testing required for Items 1 and 5 respectively from Table E.11-1.

In the event the criteria above are not met for the proposed alternative replacement portable light or battery, it shall either be rejected, or this Attachment revised to address the

Post-Fire Safe Shutdown Operator Manual Actions Page E-34 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 acceptability of the differences associate with the alternative portable lighting and/or battery.

E.12 Maintenance Rule Application As previously identified, the fixed emergency lighting identified in Table E.2.5-1, will continue to be credited for illumination of safe shutdown operator actions. Considering this, these emergency lighting units will also continue to be scoped within the 10 CFR 50.65 Maintenance Rule Program implemented by Wolf Creek per procedure AP 23M-001. The fixed emergency lighting that is being downgraded will no longer be scoped within the Maintenance Rule, as it is no longer relied upon to mitigate an accident or transient described in the USAR, nor is it used in the emergency response procedures to provide accident mitigation. The portable lighting credited as the primary emergency lighting means for illuminating safe shutdown operator actions will not be included in Maintenance Rule scope considering that this lighting is considered a tool and is readily replaceable, and the preventive maintenance strategy is a simplistic approach comprised of periodic inventory checks, lighting checks, and battery replacement. The Fenix HM65R headlamp is credited as the compensatory measure for Table E.2.5-1 fixed emergency lighting when it is deficient or nonfunctional.

E.13 Precedent There are plants (References E.15.37 and E.15.38 for example) who have transitioned to a NFPA 805 license bases and now credit portable lighting as the primary emergency lighting means for illuminating operator manual actions. Wolf Creek continues to maintain a deterministic fire protection license bases, with no plans to transition to NFPA 805. As discussed in E.3, the justification approach for the use of portable lighting as a primary means for illuminating safe shutdown equipment is similar for both the deterministic and risk informed fire protection license bases in that feasibility and reliability are the key elements that warrant methodical assessment. Additionally, Table E.13-1 identifies instances where the NRC has approved previous requests for alternative emergency lighting approaches (flashlights) in lieu of direct compliance with 10 CFR 50 Appendix R Section III.J.

Post-Fire Safe Shutdown Operator Manual Actions Page E-35 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Table E.13-1, NRC Approved Exemption Requests Crediting Portable Lighting Accession No. Date Subject Discussion ML013460187 11/06/1986 North Anna, Units 1 & 2, Approved the use of portable lighting in Seal Exemption, Relating to Water Filter Areas and transition through Letters Requesting outside areas Thirty-Four Exemptions from Appendix R to 10 CFR Part 50 ML003765204 12/30/1986 Three Mile Island, Unit Approved the use of portable lighting in 1, Exemption Regarding Containment Fire Protection ML020290207 12/30/1986 Brunswick Units 1 &2 Approved the use of portable lighting for Exemption from transition through the East Yard and reading Requirements of gauges Appendix R to 10 CFR 50, Section III.G and J ML091310132 07/27/1987 Beaver Valley Power Approved use of portable lighting to enhance Station, Unit No. 1 - permanently installed 8-hour emergency Transmittal of Appendix lighting for the following: Intake Structure, R Technical Exemption Turbine Deck, Primary Auxiliary Building, Regarding Emergency Service Building Roof Top to Feedwater Lighting Regulating Valve Room, Normal 4-kv Switchgear Room, AE and DF Emergency Switchgear Rooms, Process Rack Room ML020530077 07/30/1987 HB Robinson Unit 2, Approved use of portable lighting for certain Exemptions from Certain paths to Charging Pump Room, Component Requirements of 10 Cooling Water Heat Exchanger Room, DC CFR 50, Appendix R, Distribution Panels in the Battery Room and Section III.J Safety Injection Pump Room ML012670091 02/25/1988 Approval of Technical Approved the use of portable lighting in Exemption Requests Containment and transition through outside from Appendix R, 10 areas CFR Part 50 for Surry Power Station

Post-Fire Safe Shutdown Operator Manual Actions Page E-36 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.14 Conclusion Considering the superior illumination levels provided by the Fenix HM65R headlamp in comparison to the Teledyne Big Beam emergency lighting unit, the procedure implementation duration, the battery life of the portable emergency lighting, the strategy for ensuring battery charge level at the beginning of a shift, and the strategic location of spare headlamps and disposable CR123 / CR123A batteries in the plant, adequate illumination will be provided by the Fenix HM65R headlamp for the performance of OMAs in support of safe shutdown from either a fire or an event resulting in the loss of all AC power. The portable lighting described in this evaluation is acceptable as the primary emergency lighting methodology for a diverse emergency lighting strategy that includes the following:

8-hour fixed battery units for the locations that may require long term attendance in support of safe shutdown.

Portable (hard hat mounted) lighting for illuminating safe shutdown implementing procedures, equipment, and the access egress routes to the equipment.

1.5-hour fixed battery units for firefighting activities, life safety access/egress, and supplementary lighting to portable lighting.

Post-Fire Safe Shutdown Operator Manual Actions Page E-37 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.15 References E.15.1 E-1F9900, Post-Fire Safe Shutdown Operator Manual Actions, Rev. 10 E.15.2 OFN KC-016, Fire Response, Rev. 51 E.15.3 Correspondence 10-00711, Wolf Creek Generating Station -Issuance of Amendment Re: Deviation From Fire Protection Program Requirements [License Amendment 191 for E-1F9900], dated December 16, 2010 E.15.4 E-1F9915, Design Basis Document for OFN RP-017, Control Room Evacuation, Rev. 14 E.15.5 OFN RP-017, Control Room Evacuation, Rev. 54 E.15.6 Correspondence 15-00793, Wolf Creek Generating Station - Issuance of Amendment Re: Revise The Fire Protection Program Related to Alternative Shutdown Capability [License Amendment 214 for E-1F9915], dated September 11, 2015 E.15.7 USAR Section 9.5.3.2.3, Emergency Lighting System, Rev. 27 E.15.8 USAR Section 7.4, Systems Required for Safe Shutdown, Rev. 14 E.15.9 NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition E.15.10 EPRI TR-106826, Battery Performance Monitoring by Internal Ohmic Measurements - Emergency Lighting Unit Batteries, dated December 1996 E.15.11 10 CFR 50 Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 E.15.12 Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Rev. 4 E.15.13 NUREG-0800, Standard Review Plan Section 9.5.3, Lighting Systems, Revision 3 E.15.14 NUREG-0700, Human-System Interface Design Review Guidelines, Rev. 3 E.15.15 NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire, publish dated October 2007 E.15.16 NFPA 101, Life Safety Code, 2021 Edition E.15.17 Change Package 20283, Portable Lighting for Operator Manual Actions, Rev. 0 E.15.18 Work Order 21-468651-000, Portable Lighting Performance Test E.15.19 AP 21-001, Conduct of Operations, Rev. 86 E.15.20 STN GP-009, Emergency Equipment Verification, Rev. 81B E.15.21 Change package 012523, PFSSD Label Enhancement Project, Rev. 0 E.15.22 E-1L8900, Lighting Notes, Symbols and Details, Rev. 89 E.15.23 AP 23M-001, WCGS Maintenance Rule Program, Rev. 13

Post-Fire Safe Shutdown Operator Manual Actions Page E-38 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.15.24 ANSI/IEC 60529, Degrees of Protection Provided by Enclosures (IP Code) 2020 Edition E.15.25 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants E.15.26 NRC Accession No. ML013460187, North Anna, Units 1 & 2, Exemption, Relating to Letters Requesting Thirty-Four Exemptions from Appendix R to 10 CFR Part 50, dated 11/06/1986 E.15.27 NRC Accession No. ML003765204, Three Mile Island, Unit 1, Exemption Regarding Fire Protection, dated 12/30/1986 E.15.28 NCR Accession No. ML020290207, Brunswick Units 1 &2 Exemption from Requirements of Appendix R to 10 CFR 50, Section III.G and J, Pertaining to Fire Protection of Safe Shutdown Capability and Emergency Lighting for Safe Shutdown Capability, dated 12/30/1986 E.15.29 NRC Accession No. ML091310132, Beaver Valley Power Station, Unit No. 1 -

Transmittal of Appendix R Technical Exemption Regarding Emergency Lighting, dated 07/27/1987 E.15.30 NRC Accession No. ML020530077, HB Robinson Unit 2, Exemptions from Certain Requirements of 10 CFR 50, Appendix R, Section III.J, dated 07/30/1987 E.15.31 NRC Accession No. ML012670091, Approval of Technical Exemption Requests from Appendix R, 10 CFR Part 50 for Surry Power Station dated 02/25/1988 E.15.32 Wolf Creek Fire Protection Program Regulatory Bases, Rev. 4 E.15.33 LER 95-005, Failure To Develop Adequate Fire Protection Program Emergency Lighting, dated 10/05/1995 E.15.34 EMG C-0, Loss of All AC Power, Rev. 45A E.15.35 OFN NB-034, Loss of All AC Power - Shutdown Conditions, Rev. 33 E.15.36 NUREG 0881 Vol. 1 - Safety Evaluation Report Related to The Operation of Wolf Creek Generating Station Unit No. 1 E.15.37 Correspondence 22-00015, Cooper NFPA 805 Portable Lighting Information, dated 09/21/2022 E.15.38 Correspondence 22-00016, Callaway NFPA 805 Portable Lighting Information, dated 01/12/2022 E.15.39 Correspondence 22-00042, Fenix Lighting for Extremes Vendor Data, dated 02/08/2022 E.15.40 Correspondence 22-00045, Fenix Lighting Email - USB Charging Port for HM65R Headlamp, dated 02/11/2022 E.15.41 ANSI/PLATO FL 1, Flashlight Basic Performance Standard, 2019 Edition E.15.42 Correspondence 22-00067, UN38.3 Test Report for Fenix Lighting Battery ARB-L18-3500, dated 02/26/2015

Post-Fire Safe Shutdown Operator Manual Actions Page E-39 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 E.15.43 Correspondence 22-00071, UN38.3 Test Report for Fenix Lighting Battery ARB-L18-3400, dated 03/28/2016 E.15.44 Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, [United Nations document], Sixth Edition E.15.45 NRC Accession No. ML22011A086, Summary of January 10, 2022, Pre-Submittal Teleconference with Wolf Creek Nuclear Operating Corporation Regarding a License Amendment Request to Use Portable Lighting for Wolf Creek Generating Station, Unit 1 (EPID L-2021-LRM-0118), dated 01/11/2022 E.15.46 NRC Accession No. ML22361A005, Request for Additional Information: Wolf Creek Request for Deviation from Fire Protection Program Requirements (EPID:

L-2022-LLA-0107), dated 12/27/2022 E.15.47 Work Order 21-468651-008, Label Stairwell Egress Points

Post-Fire Safe Shutdown Operator Manual Actions Page E-40 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 1 of 7) o.......~,.,..,. ....... _.,..,.,..,,

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Post-Fire Safe Shutdown Operator Manual Actions Page E-41 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 2 of 7)

Fe SEE WHAT MATTERS'" www.fenixlighting.com NEW PRODUCT ANNOUNCEMENT SKU : HM65RL28K HMSSR EAN:6942870306629 1400WMENS The Fenix HM65R headlamp features b oth an independently controlled spotlight and Spotlight Mode a fl oodlight for a combined maximum 1400 ANSI/FSC lum ens of neutral white light. Powered by the Low Med High Turbo included 3500m Ah battery, this headlamp is USB-C rechargeable and includes a battery 0 UTPUTLUMENS 50 130 400 1000 130 400 level indicator. It is made of a magnesium alloy for better strength , impact resistant to 2 meters RUNTIME 97h 48h 22h 2h 300h 50h 21h (6.6ft), and less weight. Perfect for work or outdoor adventures, and those needing the 12111 18711 331 ft 53511 2011 9811 18011 DISTANCE (37m) (57m) (101m) (163m) (6m) (30m) (55m) brightest hands-free li ghting and long runtim es in a small, light-weight package . INTENSITY 350cd 833cd 2600cd 6677cd 9cd 220cd 762cd IMPACT 2m

Max 1400 lumen output from an included 18650 RESISTANCE rechargeable Li-ion battery or two CR123A WATERPROOF/

DUSTPROOF IP68. dustproof/waterproof underwater to 2m batteries Seven modes including four spotlight levels and SIZE Length 3.2 ** (80.5mm) Width: 2.2" (55mm) Height 1.6" (40mm) three floodlight levels WEIGHT 3.4 oz. (97g) excluding battery

USB-C rechargeable with battery level indicator ARB-L 18-3500 rechargeable Ii-ion battery, headband, top headband, headband

Built with a magnesium alloy for lighter weight INCLUDED mount, spare 0-ring, charging cable Limik:d Lifetime Guarantee from Fenix Lighting USA " The runtime of turbo is the cumulative time when overheat protection actNe.

Post-Fire Safe Shutdown Operator Manual Actions Page E-42 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 3 of 7) n hour:s so ho,urs 4B hO\JfS 16.3 meters lOl meter:s Jl'mmrs 30,neters 6 mete<,;

&677 candelas 2600 can delas 350 candelas 22-0 cariaelas 9 carid'elas 2memrs

Post-Fire Safe Shutdown Operator Manual Actions Page E-43 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 4 of 7)

Fe SEE WHAT MATTERS'" www.fenixlighting.com NEW PRODUCT ANNOUNCEMENT ALG-03 HEADLAMP HELMET MOUNT Model : ALG-03 EAN : 6942870304 717 Quickly attach and detach the HL55 or HL60R headlamp to any outdoor or work helmet Size Length: 6.14" (156mm)

Width 4.53" (115mm)

Allows for adjustment of the lighting angle Height 0. 79" (20mm)

Attach the mount easily with included 3M adhesive tape (white) or TESA adhesive tape (blue) Weight 2.12 oz. (60g)

Durable nylon cons true ti on Included One 3M adhesive tape (white), one TESA adhesive tape (blue)

Limited Lifetime Guarantee from Fenix Lighting U.S.

All pricing and specilications subject to change without notice .

Post-Fire Safe Shutdown Operator Manual Actions Page E-44 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 5 of 7)

FeJ x. SEE WHAT MATTERS' ' www.fenixlighting.com NEW PRODUCT ANNOUNCEMENT ARB-L'IB-3500 SKU : AR B- L1 8-3500 EAN : 6942870303505 ARB-L 18-3500 is a high capactty 18650 Li-ion rechargeable Model ARB-L1 8-3500 wtth a protection circutt in the anode to help prevent short circutts, over charge/discharge and over heat ing. The Capacity 3500mAh battery also includes pressure relief ven ts which expel Voltage 3.6V waste gas in the rare case of an internal short circutt Charging Current Recommended 1A. maximum 2A preventing an explosion.

Weight 1.8 ounces (50g)

Size Lenglh: 2.7' (69mm)

3500mAh high capacity Diameter. 0.7' (18.6mm)

Protection circuitry to prevent short circuits Warranty Period 12 month from date of purchase

Pressure vents to prevent explosions

500 charge cycles I

~~ ~ -

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Post-Fire Safe Shutdown Operator Manual Actions Page E-45 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 6 of 7)

FeJ-x SEE WHAT MATTrns* www.fenixlighting.com NEW PRODUCT ANNOUNCEMENT ARB-L'IB-3400 Model: ARB-L 18-3400 EAN: 6942870303888 ARB-L 18-3400 is a high capacity 18650 Li-ion rechargeable Model ARB-L 18-3400 with a protection ci rcuit in the anode t o help prevent short circuits , over charge/discharge and over heating . The Capacity 3400mAh b attery als o includes pressure relief vents which expel Voltage 3.6V waste gas in the rare case of an intern al short circuit Charging Current Recommended 1A, maximum 2A p reventing an explosion .

Weight 1 .8 ounces (50g)

Size Length 2.7" (69mm)

3400mAh high capacity Diameter: 07" (18.6mm)

Protection circuitry to prevent short circuits Warranty Period 12 month from date of purchase

Pressure vents to prevent explosions

500 charge cycles I

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.---~M1,.. ©Fenix Flashlights all nghts reserved Pnc1ng effective 3/21 /1 6 All pricing and spec1hcat1ons subject to change without notice

Post-Fire Safe Shutdown Operator Manual Actions Page E-46 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.1, Fenix HM65R Headlamp Product Data (Page 7 of 7)

Post-Fire Safe Shutdown Operator Manual Actions Page E-47 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.2, Light Meter Information (Page 1 of 3)

SD card real time da,t alogger

+ Type K/J thermometer LIGHT METER Model:: LX-1128,SD

~ '

~ ~ lln11 SD OIi r,t Daui IAgO&r LIGHT METER Tv11t1 l({J Tham,oma 11r L7!"iwtrm LX*112BSD

Post-Fire Safe Shutdown Operator Manual Actions Page E-48 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.2, Light Meter Information (Page 2 of 3)

ILii-ght meter Measur,e mer Rain ge

!M ax.. l 1 n1-1range Display 2,000 LUX 0- 1,999 LUX LUX 20.,000 LUX lr800 - 19,990 LUX

@auto ran,qe 100,000 LUX 18',r 000 - 99., 900 IJUX 200 Ft-cd 0- 186.0 Ft-cd Feet-candle 2,000 Ft-,cd 167.0 - 1,860.0 Ft-ad

@auto range 10,000 Ft-cd 1,.670.0 - 9,290.,7 Ft-ad Rang1e Resolution A.ccu1racv 2,000 LUX 1 iLUX 20,000 LUX 10 LUX +/- (4 %+2 dgt) 100,000 LUX 100 LUX 200 Ft-cd 0.1 Ft-cd 2,.000 Ft-cd 1 Ft-cd 1

+/- (4 % +2 Ft-cd) 10.000 Ft-cd 10 Ft-cd +/- (4 °/o+2:0 Ft-cd)

Note : Accuracy tested by a .standard parallel light tunosten lamo of 2856 K.dearee .temperature.

Post-Fire Safe Shutdown Operator Manual Actions Page E-49 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.2, Light Meter Information (Page 3 of 3)

CALIBRATION CERTIFICATE NO. 0600318 CUSTOMER; EVERGY- WOLF Cl'tBEK EQUIPMENT : Ltn'RON BURLINGTON, KS 66839 DESCRIPTION: Light ~eter LX-1128SD SERIAL NO .~ '1',0 1,5 275 CALIBRATION D.ATE: 03/17/2021 TEST CONDlTlON ;

70°F, 48% REI RECEIVED COlIDI TION : NEW ORK Pl:lRFOl':U-IEP : Validated Calibration to Manufaat;urer's Specifications .

STANPAru>S USED: Wa.v l.ength of aourc: : Standard light t1:1ngsten lmqp of 2856 Deg . K Tempe;r:ature .

St:anda.:i;d CaJ.:i.bration Data Calibrated Source Model No. LX-112BSD Accur&Sl S/N 169'4C- 102 S/N T0J.627 5 000 000 100 96 200 196 5 00 488 +/- (5% + 2 dgt) 1000 973 TECHNICIAN : _ _ _(,_;c[....

We hereby certify that the a.suring device-5 used have been cco~danc with our standard work.ing :i:iroeedtu:e, using IQE!asuring equ;l.pmen.t and cali.br&t ion standa:rda, which az,e NIST ~raceablE:!. There i s no way to determine how long calibr ti.on will be mai.nU.ined. Thi!!! i.ns: trumant oould b a.ff,e oted b y aging 1 t$mperaturae, ehoc.k nd COlltamina tion.

Post-Fire Safe Shutdown Operator Manual Actions Page E-50 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.3, Peer Plant Portable Light Information (Page 1 of 1)

I NOT APPROVED FOR USE AS PRIMARY EMERGENCY LIGHTING TO ILLUMINATE OPERATOR MANUAL ACTIONS AT WOLF CREEK I

LIAR HEn : n The 4AA Xenon FrontS!Mtch matches hiilh pertormance with a sleek, &ompactdesig11 ttiatcan be op!!rated with gloves, A xenon bulb prcwide.s vibrant aolor clarity. It is tile most reuable, -cosHffecfive tlasnlight yo11ll ever own.

FEATURES SPECIFICATIONS

2.1 wall high biig EcSS J<ell<<l fllled Lamp

Rulibe, she alh molded.,.,..,. be,el ID ,Btbilco Jla,a and irnpra'l<I 1mr

ct cUI Llhlll CL I, DIV 2, GP A, B, C, D, Cl. U, DIV 2 GP G, CL Ill, DIV 2 T2A

..,,;i,,ia,11:1, fl,ass&Sc lJL311 Ft drap 1D ron,cratB las1l

PuiliJrut1Dn 11\umb ~..-.:itd,

*P,*fbcussd higl, i'11ltnsly Sjlal ll<lam

ew * * *Y li:iarling drop-m ~-rv ~r,mp.anmanl. for qoiol raload ol hat!Bne-,;

H;dro_gBAscruhbu ,:at,,[y.t, polwed batta,ycamt.acts and ~psi wlll:

rni<rimize* ""l'lm ri,Urom lea

g batiaries

~::~r~*,*11m1@

Brightness 38 l ume r,s

iough, QDIHmic&lg ABli,rnd jKJfo,,:arbon.ite p!3slic oon!ilrulllllln Burn Time 4-5 hrs Baam Distance 31 1 ft I 95 m lamp Xenon e.tt..ries 4 AA Alkaline; LR6 Size 6.1 >< 1.6 :x 1 .4 in I 15.5 x4.1 >< 3.fi cm-Weight 5;5 oz I 15UI g Mrnun ttJ,3nyhard h.t:

wit/, UK~alm a! d"rps Ava~al,Je m Front and t,i/

nwik ean/rgo11iiia1>6 I

!IQ 30 20 10 D

0

~""11111 1

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PART NUMBERS/ ACCESSORIES

'51411'1!1 UK4AA-A-S2 Xenon (CLI Div 2~ Fmrtt S\liitnh, lllaol:

51410:1 llK4M -.AS2lenon CLI lliv2lFr0111S..itch,Oram~*

514120 UJ:4AA-AS2J(eru:m CLI Il[,, 2~froniSwitch, Sa etyYellow 514877 51481ti Trnffi~ Oii:sctor WFOJd Nylon Bob'. P'oum, 4ANZAA 2M<4AA/Njj&x Pra REV: !!119

Post-Fire Safe Shutdown Operator Manual Actions Page E-51 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test General Area Lighting Photo E.4.A-1, Normal Lighting On Photo E.4.A-2, No Lighting

Post-Fire Safe Shutdown Operator Manual Actions Page E-52 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Teledyne Big Beam Emergency Light E.4.B-1, Teledyne Big Beam Emergency Light E.4.B-2, Target at 10 ft. and Battery Charged E.4.B-3, Target at 10 ft. and Battery Discharged 8-Hours

Post-Fire Safe Shutdown Operator Manual Actions Page E-53 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Fenix HM65R Headlamp Mounting E.4.C-1, Front View E.4.C-2, Closeup Front View E.4.C-3, Side View

Post-Fire Safe Shutdown Operator Manual Actions Page E-54 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Fenix HM65R Headlamp with Rechargeable Battery E.4.D-1, Target at 10 ft. High Spotlight Mode E.4.D-2, Target at 10 ft. High Floodlight Mode E.4.D-3, Target at 10 ft. High Spotlight Mode & Battery E.4.D-4, Target at 10 ft. High Floodlight Mode & Battery Discharged 1.5-Hours on High Spotlight Discharged 1.5-Hours on High Spotlight

Post-Fire Safe Shutdown Operator Manual Actions Page E-55 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Fenix HM65R Headlamp with Rechargeable Battery (Cont'd)

E.4.D-5, Target at 10 ft. High Spotlight Mode & Battery E.4.D-6, Target at 10 ft. High Spotlight Mode & Battery Discharged 8-Hours on High Spotlight Discharged 16-Hours on High Spotlight

Post-Fire Safe Shutdown Operator Manual Actions Page E-56 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Fenix HM65R Headlamp with CR123 Batteries E.4.E-1, Target at 10 ft. High Spotlight Mode E.4.E-2, Target at 10 ft. High Floodlight Mode E.4.E-3, Target at 10 ft. High Spotlight Mode & Batteries E.4.E-4, Target at 10 ft. High Floodlight Mode & Batteries Discharged 1.5-Hours on High Spotlight Discharged 1.5-Hours on High Spotlight

Post-Fire Safe Shutdown Operator Manual Actions Page E-57 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Fenix HM65R Headlamp with CR123 Batteries (Cont'd)

E.4.E-5, Target at 10 ft. Low Floodlight Mode & Batteries Discharged 8-Hours on High Spotlight

Post-Fire Safe Shutdown Operator Manual Actions Page E-58 of E-58 Attachment E WIP-E-1F9900-010-A-1, Rev. 01 Attachment E.4, Photos from Lighting Performance Test Underwater Kinetics UK4AA-AS2 Flashlight E.4.F-1, Target at 10 ft. E.4.F-2, Target at 10 ft. & Batteries Discharged 1.5-Hours

v t e Letter Sequence Response to RAI
EPID:L-2022-LLA-0107, License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements (Open)
Initiation Request Acceptance Supplement Administration Questions 27 December 2022 Answers 26 January 2023 Results Approval Other:
MONTHYEAR2022-09-08 [Table View]

ET 23-0004, Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements

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ET 23-0004, Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements

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