ML25342A156
| ML25342A156 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/08/2025 |
| From: | Joseph Turner Evergy, Wolf Creek |
| To: | Samson Lee NRC/NRR/DORL/LPL4 |
| Lee S, 301-415-3168 | |
| References | |
| EPID L-2025-LLA-0051 | |
| Download: ML25342A156 (0) | |
Text
From:
Joshua Turner To:
Samson Lee Cc:
Tyson Marcotte; Don Garbe; Nathan Lee; Jeffrey Suter
Subject:
[External_Sender] WCGS Comments - DRAFT SER for Portable Lighting Date:
Monday, December 8, 2025 10:43:07 AM Attachments:
Wolf Creek Comments Draft SE for LA 245.docx Internal Use Only Hi Sam,
I hope you're doing well. I believe Nathan is out of the office today traveling. Our team has reviewed the NRCs draft Safety Evaluation for License Amendment 245. Please see the attached document which provides Wolf Creeks comments on the draft SE for LA 245.
- Thanks,
Josh Turner Manager of Regulatory Affairs Evergy
Josh.Turner@evergy.com
O:620-364-8831x8261 M: 785-248-1108
From: Jeffrey Suter <Jeff.Suter@evergy.com>
Sent: Monday, December 8, 2025 9:04 AM To: Joshua Turner <Josh.Turner@evergy.com>
Cc: Tyson Marcotte <Tyson.Marcotte@evergy.com>; Don Garbe <Don.Garbe@evergy.com>; Nathan Lee <Nathan.Lee@evergy.com>
Subject:
Comments - DRAFT SER for Portable Lighting
Internal Use Only
- Josh,
See attached for Fire Protection comments on the DRAFT Safety Evaluation for License Amendment 245.
We committed to have comments to Sam by the end of today (12/8/2025). I can send on the comments to Sam if youd prefer, just le me know.
Thanks
Jeff Suter Evergy - Wolf Creek Engineering Manager Office: (620) 364-8831 x 8268 Cell: (620) 203-8718 Jeff.Suter@evergy.com
Page 1 of 2 Wolf Creek Comments - Draft Safety Evaluation for License Amendment 245
- 1) Section 1.0 Paragraph 2 and Section 3.1 Paragraph 2 (both repeated below) infer that hard hat mounted portable lighting is not allowed for the Table 1 areas identi"ed in the LAR. Portable hard hat mounted lighting will be utilized for these areas in conjunction with the "xed emergency lighting that remains 8-hour rated.
Section 1.0 Paragraph 2 Current Wording The areas where hard hat mounted lights will not be used for post-"re safe shutdown (i.e., the limited exceptions mentioned above) are areas of the plant where the "xed emergency light "xtures with 8-hour battery backup will be retained and credited for post-"re 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.
Recommended Change The areas where hard hat mounted lights will not be used credited as the primary emergency lighting means for post-"re safe shutdown (i.e., the limited exceptions mentioned above) are areas of the plant where the "xed emergency light "xtures with 8-hour battery backup will be retained and credited for post-"re 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.
Section 3.1 Paragraph 2 Current Wording 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 "re 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 "xed emergency light "xtures.
Recommended Change The licensees proposed change would allow the licensee to use credit hard hat mounted portable lights as the primary emergency lighting means in all locations, with the exception of locations listed in table 1 of the LAR, in conjunction with the other installed "re 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 "xed emergency light "xtures.
Page 2 of 2
- 2) Section 3.0 Last Paragraph - The quote referenced from the LAR is incorrect. The Safety Evaluation states:
In the LAR the licensee stated that: All of the locations crediting portable lighting will have the 8-hour "xed battery units downgraded to 1.5-hour "xed battery units for "re"ghting activities, life safety access and egress, and supplementary lighting to "xed battery units, and that the newly established 1.5-hour "xed battery units will remain in the facility as installed. The NRC sta 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.
"xed battery units highlighted in yellow above should be portable lighting as re"ected in Section 2.0 Detailed Description of the LAR, repeated below:
All of the locations crediting portable lighting will have the 8-hour "xed battery units downgraded to 1.5-hour "xed battery units for "re"ghting activities, life safety access and egress, and supplementary lighting to portable lighting.