ML24085A273

Comments for March 25, 2024 Meeting on Portable Lighting Revised SE

ML24085A273
Person / Time
Site:	Wolf Creek
Issue date:	03/21/2024
From:	Samson Lee Plant Licensing Branch IV
To:	Reasoner C Wolf Creek
Lee S, 301-415-3168
References
EPID L-2023-LRL-0002
Download: ML24085A273 (1)

Text

Wolf Creek Comments on NRC Presentation: Revisions to Safety Evaluation Relate to Amendment 237, Request for Deviation from Fire Protection Requirements [ML24071A210]

Comment A (Addresses NRC Comment Response to 1.0, 2.0, and 8.0, and 10.0 )

Without reviewing the entirety of the proposed revision to the safety evaluation (SE), it is difficult to assess if the NRC comment response adequately satisfies the issues identified in the request for correction letter dated October 19, 2023 (ML23292A357). It is not clear that the SE revisions identified by the Power Point presentation approve/allow the use of portable lighting as the primary emergency lighting means for more than just the operator manual actions (OMAs) associated with Table 1. For example, there, is no direct mention within the presentation of revising the Section 3.2 NRC Staff Conclusion, which limits the use of portable lighting to the OMAs for Table 1.

As identified in the license amendment request (ML22215A000) and the referenced request for correction letter, the scope of the request is for all OMAs supporting the performance of 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

Only the emergency lights identified in Table 2 will be retained as 10 CFR 50 Appendix R credited 8 -hour emergency lights.

Comment B (Addresses NRC Comment Response to Comment 3.0)

The proposed change does not address the original comment. Wolf Creek is not requesting the use of portable lighting as the primary emergency lighting means for situations where the installation or maintenance of fixed 8-hour emergency lighting is not achievable or feasible. The LAR provides a technical basis for utilizing portable lighting as the primary emergency lighting strategy, except for the locations identified in Table 2.

Comment C (Addresses NRC Comment Response to Comment 4.0)

The comment response does not address the original comment. The SE is incomplete in that it is silent regarding the proposed change to downgrade all the original 10 CFR 50 Appendix R credited 8-hour emergency lights to 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> life safety units, with the exception the Table 2 emergency lighting units.

This is a significant emergency lighting strategy change that warrants discussion within the SE.

Comment D (Addresses NRC Comment Response to Comment 6.0)

The proposed change is inaccurate. For a fire outside the control room, Wolf Creek has completed a reliability and feasibility analysis, per NUREG-1852. This addresses the OMAs associated with fires in Table 1 locations. For a control room fire ( alternate shutdown per 10 CFR 50 Appendix R III.G.3 and III.L ), operator action timing is evaluated in E-1F9915, Design Basis Document for OFN RP-017, Control Room Evacuation, with emergency lighting aiming requirements identified in E-1L8900, Lighting Notes, Symbols and Details. There is no distinct reliability and feasibility analysis for the Table 2 emergency lighting.