ML25338A265

Draft Wolf Creek Portable Lighting SE for Licensee Comment - 12-4-2025

ML25338A265
Person / Time
Site:	Wolf Creek
Issue date:	12/04/2025
From:	Samson Lee Plant Licensing Branch IV
To:	Lee N, Suter J, Joseph Turner Wolf Creek
Lee S, 301-415-3168
References
EPID L-2025-LLA-0051
Download: ML25338A265 (0)

Text

From:

Samson Lee To:

Nathan Lee; Jeffrey Suter; ext_Joshua_Turner

Subject:

Wolf Creek portable lighting draft safety evaluation (EPID: L-2025-LLA-0051)

Date:

Thursday, December 4, 2025 1:14:00 PM Attachments:

draft Wolf Creek portable lighting SE for licensee comment 12-4-2025.docx By letter dated March 18, 2025 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML25077A312), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for the Wolf Creek Generating Station, Unit 1, in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.90, Application for amendment of license, construction permit, or early site permit. The LAR proposes changes to Fire Protection License Condition 2.C.(5),

specifically Section 9.5.1 of the Safety Evaluation Report (SER) and Section 9.5.1.8 of Supplement to the SER #5. The amendment requests a deviation from the requirements of 10 CFR Part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979. Specifically, the licensee seeks to deviate from the Wolf Creek Updated Safety Analysis Report (USAR) Appendix 9.5E, 10 CFR Part 50, Appendix R Comparison (ML22151A150), by allowing the use of hard hat-mounted portable lights, with limited exceptions, for operator manual actions (OMAs) that support post-fire safe shutdown. These lights would be used to illuminate safe shutdown equipment and access/egress routes, in lieu of the emergency lighting requirements in Section III.J of Appendix R.

Previously, in Amendment No. 237 dated August 31, 2023 (ML23165A250), the U.S.

Nuclear Regulatory Commission (NRC) approved the use of hard hat-mounted portable lights as the primary emergency lighting for OMAs and for illuminating safe shutdown equipment and associated access/egress routes in certain fire areas, as detailed in Table 1 of the safety evaluation (SE) for Amendment No. 237. The NRC staff concluded that OMAs remained feasible and reliable with the use of these lights.

However, by letter dated October 19, 2023 (ML23292A357), the licensee requested correction of the SE for Amendment No. 237, citing significant deviations from its original LAR. The licensee stated that the SE contained information inconsistent with its August 2, 2022, LAR (ML22215A000) and could not be implemented as written. Subsequently, on May 9, 2024 (ML23345A160), the NRC staff reissued the SE with revisions to accurately reflect the LAR and staff review. After a public meeting on July 23, 2024 (ML24212A037) to discuss licensing options, the licensee submitted the March 18, 2025, LAR. On August 20, 2025 (ML25239B590), the NRC staff held a public meeting to discuss the status of the review.

Given the extensive review history, the licensee requested that the NRC staff share the draft SE for factual verification prior to issuance, to ensure consistency with the LAR. In accordance with NRC Management Directive 3.4, Release of Information to the Public (ML080310417), the Director of the Office of Nuclear Reactor Regulation (NRR) has authorized the release of draft or pre-decisional information in this case. As requested by the licensee, the NRC staff is sharing the attached draft SE for accuracy and completeness review. The licensee may provide comments regarding significant factual discrepancies from the LAR for NRC staff consideration. Consistent with Office of Executive Director for Operations (OEDO) Procedure-0235, Revision 0, Driving Regulatory Decisions Through More Effective Communications (ML25167A039), the NRC staff will make this email and the licensees response publicly available in ADAMS.

If you have any questions, please contact me.

Samson Lee Plant Licensing Branch 4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-3168

Docket No. 50-482 DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 245 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482

1.0 INTRODUCTION

By letter dated March 18, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25077A312), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for the Wolf Creek Generating Station, Unit 1 (Wolf Creek), in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.90, Application for amendment of license, construction permit, or early site permit, requesting changes to the fire protection License Condition 2.C.(5), Fire Protection (Section 9.5.1, SER [Safety Evaluation Report], Section 9.5.1.8, SSER [Supplement to SER]

1. 5). The LAR proposed a deviation from the requirements of 10 CFR Part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.

Specifically, the licensee proposed a deviation from Wolf Creek Updated Safety Analysis Report (USAR), appendix 9.5E, 10 CFR Part 50, Appendix R Comparison (ML22151A150), to allow the use of hard hat mounted portable lights, with limited exceptions, for the performance of operator manual actions (OMAs) that support post-fire safe shutdown and for illuminating safe shutdown equipment, and access and egress routes to the equipment in lieu of meeting the requirements of 10 CFR Part 50, Appendix R, Section III.J, Emergency lighting.

The areas where hard hat mounted lights will not be used for post-fire safe shutdown (i.e., the limited exceptions mentioned above) are areas of the plant where the fixed emergency light fixtures with 8-hour battery backup will be retained and credited for post-fire safe shutdown.

These areas include the control room, the auxiliary shutdown panel, the emergency diesel generator control panel, and the operations hard hat rack just outside the control room. For additional details, see table 1 in section 1, Summary Description, of attachment I to the LAR (or table 1 of the LAR).

2.0 REGULATORY EVALUATION

2.1 Program Description and Regulatory Requirements The regulations in 10 CFR 50.48(a), require that each operating nuclear power plant have a fire protection plan which satisfies Criterion 3, Fire protection, of Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants. Specific fire protection features deemed necessary to ensure this capability are delineated in Appendix R to 10 CFR Part 50. Criterion 3 of Appendix A to 10 CFR Part 50, requires, in part, that [s]tructures, systems, and components

[SSCs] important to safety shall be designed and located to minimize, the probability and effect of fire and explosions. It further requires that the [f]irefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the capability of these structures, systems, and components.

The regulations in 10 CFR Part 50, Appendix R establish fire protection features required to satisfy Criterion 3 of Appendix A to 10 CFR Part 50 with respect to certain generic issues for nuclear power plants licensed to operate prior to January 1, 1979. One of the principal objectives of the commercial nuclear power plant fire protection program is to ensure that the risk of fire-induced radiological hazards to the public, environment and plant personnel is minimized. To meet this objective, 10 CFR 50.48, Fire protection, requires each operating nuclear power plant to have the means to limit fire damage to SSCs important to safety so that the capability to shut down the plant safely is ensured. The objective of safe shutdown of the plant is to assure that at least one means of achieving and maintaining safe shutdown capability is available during and after any postulated fire.

Appendix R to 10 CFR Part 50, Section III.J, states that, 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. The objective of this requirement is that in the event of a fire, adequate lighting will be available to assure that the plant can be safely shut down. Wolf Creek was licensed to operate on June 4, 1985, and thus, is not subject to Appendix R to 10 CFR Part 50. However, the requirements of Appendix R to 10 CFR Part 50, Section III.J, to provide emergency lighting to assure that safe shutdown capability is maintained during and after a fire, are addressed in appendix 9.5E, 10 CFR Part 50 Appendix R Comparison, of the Wolf Creek USAR. Appendix 9.5E and section 9.5.3.2.3 confirm that emergency lighting units with 8-hour batteries are located in all plant areas for operation of safe shutdown equipment and also those areas necessary for access and egress.

The Wolf Creek operating license includes a fire protection license condition requiring the implementation of an approved fire protection program. License Condition 2.C.(5) allows the licensee to make changes to an approved fire protection program without prior NRC staff approval only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. All changes to the fire protection program must ensure that compliance is maintained with the requirements of 10 CFR 50.48(a).

2.2 Licensees Proposed Changes The licensees proposed changes would revise paragraph 2.C.(5)(a) of Renewed Facility Operating License NPF-42 and the fire protection program as described in the USAR for Wolf Creek.

The licensee proposes to revise License Condition 2.C.(5) by adding this current license amendment, as approved, to state (changes shown in bold):

(a)

The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment 189, Amendment No. 191, Amendment No. 193, Amendment No. 205, and Amendment No. 214, Amendment No. 237, and Amendment No. 245, subject to provisions b and c below.

Specifically, the licensee requested the use of hard hat mounted portable lights as the primary emergency lighting means, with limited exceptions (with the exception of locations listed in table 1 of the LAR), for illuminating implementing procedures as described in attachment I to the LAR, safe shutdown equipment, and the respective access and egress routes to the equipment in support of post-fire safe shutdown. The licensees proposed change would replace the requirement for the 8-hour fixed emergency lighting referenced in appendix 9.5E of the Wolf Creek USAR.

3.0 TECHNICAL EVALUATION

In Amendment No. 237 (ML23165A250), the NRC approved the use of the hard hat mounted portable lights as the primary emergency lighting means for OMAs and for illuminating safe shutdown equipment, and access and egress routes to the equipment in support of post-fire safe shutdown in certain fire areas as listed in table 1 of the Safety Evaluation that accompanied Amendment 237. The NRC staff concluded that the licensee had demonstrated that the OMAs remain feasible and reliable with the use of hard hat mounted portable lights.

In the LAR dated March 18, 2025, the licensee requested to use hard hat mounted portable lights as the main emergency lighting strategy in all areas (with the exception of locations listed in table 1 of the LAR) where OMAs are performed to achieve and maintain post-fire safe shutdown, and to be the primary illumination means for utilizing the related implementing procedures as described in attachment I to the LAR, safe shutdown equipment, and the respective access and egress routes to the equipment in support of post-fire shutdown. The request supports the use of portable lighting beyond the locations approved in Amendment No. 237. This request includes additional OMAs that were not explicitly included in Amendment No. 237 and OMAs for a fire in the control room requiring control room evacuation. For additional details regarding these OMAs, see the enclosures to the licensees March 18, 2025, LAR.

Appendix R to 10 CFR Part 50, Section III.G.2 fire areas are areas where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located in the same fire area outside of primary containment. The OMAs are actions conducted outside the affected fire area that are needed to ensure that safe shutdown can be accomplished for a fire in the affected area.

Fixed emergency lighting units with 8-hour battery capacity will continue to be credited as the primary emergency lighting system for the locations listed in table 1 of the LAR.

In the March 18, 2025, LAR, the licensee stated that Wolf Creek continues to maintain a deterministic fire protection licensing basis, with no plans to transition to a risk-informed, performance-based fire protection licensing basis (i.e., National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, or 10 CFR 50.48(c), (NFPA-805)). The licensee maintains a deterministic fire protection licensing basis and the analysis in this LAR was performed fully within that licensing basis. Therefore, the NRC staff did not consider the information provided by the licensee with respect to NFPA 805 in its decision-making.

The NRC staff noted that while the licensee did mention NFPA 805 in its submittal, it incorrectly stated that pertinent sections from NFPA 805 include section 1.5.3(2) and section B.5.2(3).

NFPA 805, section 1.5.3(2) which pertains to Life Safety Criteria is not applicable because 10 CFR 50.48(c)(2)(i), states in part that The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed. NFPA 805 section B.5.2(3), which pertains to methodology success path resolution considerations is not applicable because NFPA 805 itself states in regard to appendix B, that, This appendix is not a part of the requirements of this NFPA document but is included for informational purposes only.

In the LAR the licensee stated that: All of the locations crediting portable lighting will have the 8-hour fixed battery units downgraded to 1.5-hour fixed battery units for firefighting activities, life safety access and egress, and supplementary lighting to fixed battery units, and that the newly established 1.5-hour fixed battery units will remain in the facility as installed. The NRC staff notes that NRC does not regulate emergency lighting for life safety and did not consider the information the licensee provided related to this downgrade in its decision-making.

3.1

NRC Staff Evaluation

The underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J, is to ensure that adequate lighting is available to aid the operator for an extended period of time during plant fire emergencies. In plant areas, where installation or maintenance of 8-hour battery backup supplied lighting is not achievable or feasible, the hard hat mounted portable lights accomplish the purpose of achieving adequate emergency lighting because they will ensure that adequate lighting is available to aid the operator for an extended period of time during plant fire emergencies.

The licensees proposed change would allow the licensee to use hard hat mounted portable lights in all locations, with the exception of locations listed in table 1 of the LAR, in conjunction with the other installed fire protection features, to ensure the proper illumination of implementing procedures, safe shutdown equipment, and access and egress routes to the equipment, in lieu of meeting the requirements of 10 CFR Part 50, Appendix R, Section III.J, for 8-hour fixed emergency light fixtures.

Defense-in-depth elements are maintained (e.g., control of transient combustible materials),

through various means, including: the implementation of administrative procedures; automatic fire detection and fire suppression systems provided as required by the fire hazard analysis; portable fire extinguishers and fire hose stations provided throughout the plant for manual firefighting; and passive fire barrier features (walls, floors/ceilings, fire dampers, doors, penetration seals, fire wrap, and structural steel fireproofing) to separate redundant post-fire safe-shutdown components installed in accordance with industry standards and fire tested assemblies. Therefore, a level of safety is being provided that results in the unlikely occurrence of fires; rapid detection, control, and extinguishment of fires that do occur; and the protection of SSCs important to safety.

Further, the licensee has provided preventative and protective measures in addition to feasible and reliable OMAs that together demonstrate the licensees ability to preserve or maintain safe shutdown capability at Wolf Creek in the event of a fire. An OMA 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). An OMA is considered to be reliable as well if it is shown that it can be dependably and repeatedly performed within the available time, by different crews, under somewhat varying conditions.

Based on its review of the information provided by the licensee, the NRC staff concluded that, in the event of a fire, the use of hard hat mounted portable lights for performance of OMAs that support post-fire safe shutdown, will provide sufficient illumination to enable safe shutdown of the plant because the licensee has demonstrated that the actions remain feasible and reliable with the use of the hard hat mounted portable lights.

3.2 NRC Staff Conclusion

On the basis of its evaluation, the NRC staff concludes that the licensees proposed use of hard hat mounted portable lights in lieu of 8-hour battery supplied emergency light fixtures for performance of OMAs that support fire safe shutdown, satisfies the underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J, to provide sufficient illumination to the areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Kansas State official was notified of the proposed issuance of the amendment on July 21, 2025. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the Federal Register on May 14, 2025 (90 FR 20520), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Robinson, NRR C. Moulton, NRR Date: X