Information Notice No. 95-36: Potential Problem with Post-Fire Emergency Lighting
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
August 29, 1995
NRC INFORMATION NOTICE 95-36: POTENTIAL PROBLEMS WITH POST-FIRE EMERGENCY
LIGHTING
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice (IN) to alert addressees to potential problems regarding emergency
lighting for plant areas needed for operation of post-fire safe shutdown
equipment and in access and egress routes thereto. It is expected that
recipients will review the information for applicability to their facilities
and consider actions as appropriate. However, suggestions contained in this
information notice are not NRC requirements; therefore, no specific action or
written response is required.
Description of Circumstances
Several licensees have reported problems regarding post-fire emergency
lighting. The most recent example is herein described. Additional examples
are described in Attachment 1. In Licensee Event Report (LER) 94-034, dated
December 12, 1994, and Revision 1, dated February 8, 1995, Nebraska Public
Power District, the licensee for Cooper Nuclear Station, reported problems
with the batteries, lamps, and battery charger circuit boards associated with
emergency lights that were installed to satisfy the technical requirements of
Section III.J, "Emergency Lighting," of Appendix R to Part 50 of Title 10 of
the Code of Federal Regulations (10 CFR Part 50). Specifically, the licensee
reported that (1) it did not consider the effect of temperature in the
performance or in the life of the batteries, (2) the existing maintenance
program did not ensure that the lamps had a minimum of 8 hours of life
remaining after completion of the functionality test, and (3) the circuit
control boards for trickle charging may be undercharging or overcharging the
batteries. As a result of these conditions, the licensee determined that the
emergency lighting, as designed and maintained, would not fully satisfy design
requirements. The licensee attributed these deficiencies to inadequate
administrative controls on design and preventive maintenance practices. The
licensee initiated corrective actions that included a review of the design
basis for the emergency lighting system and replacement of batteries, lamps,
and charger circuit cards, where required. The licensee also conducted a test
to ensure that emergency lighting was adequate to support operator actions for
plant shutdown in the event of fire. As a result of the test, the licensee
9508220302. IN 95-36
August 29, 1995
Page 2 of 3
added emergency lights in 14 areas and upgraded 21 other lights in order to
comply with Appendix R requirements. The licensee stated it would also revise
its plant procedures as needed to prevent recurrence.
In addition to the deficiencies reported by licensees, NRC inspections have
also uncovered emergency lighting deficiencies. For example, at South Texas
Project, Units 1 and 2, an inspector found inoperable indicating lights on
battery packs. This deficiency led the licensee to perform a comprehensive
walkdown inspection of the emergency lighting system, which uncovered a large
number of deficiencies. This inspection is documented in NRC Inspection
Report 50-498, 499/94-27, dated September 9, 1994.
Discussion
This notice alerts addressees to potential problems regarding emergency
lighting for plant areas needed for operation of post-fire safe shutdown
equipment and in access and egress routes thereto.
NRC requirements and guidelines for emergency lighting in the event of a fire
are contained in various documents including Appendix R, "Fire Protection
Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to
10 CFR Part 50; Appendix A to Branch Technical Position Auxiliary Power
Conversion Systems Branch, "Guidelines for Fire Protection for Nuclear Power
Plants Docketed Prior to July 1, 1976"; and NUREG-0800, "Standard Review
Plan." The extent to which these requirements or guidelines are applicable to
a specific nuclear power plant depends on plant age, commitments established
by the licensee in developing its fire protection plan, the staff safety
evaluation reports and supplements, and the license conditions pertaining to
the fire protection plan.
The objective of these requirements and guidelines for emergency lighting is
to ensure that in the event of a fire, plant personnel can access and operate
equipment and components that must be manually operated to effect safe plant
shutdown. Because such activities may extend over a considerable period of
time both during and after the fire, 8-hour battery emergency lighting
capability is specified to allow sufficient time for normal lighting to be
restored, with a margin for unanticipated events.
Related Generic Communications
The NRC issued IN 90-69, "Adequacy of Emergency and Essential Lighting," dated
October 31, 1990, to alert addressees to a possible problem concerning the
adequacy of emergency and essential lighting at commercial power reactor
facilities. IN 90-69 described how the failure of emergency lighting delayed
recovery from a reactor trip at Palo Verde Nuclear Generating Station, Unit 3.
IN 90-69 also discussed deficiencies in the maintenance and testing of
emergency lighting and emphasized the importance of adequate lighting
conditions.
. IN 95-36
August 29, 1995
Page 3 of 3
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
one of the technical contacts listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.
original signed by
Dennis M. Crutchfield, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: D. Oudinot, NRR
(301) 415-3731
Neal K. Hunemuller, NRR
(301) 415-1152
Attachments:
1. Additional Examples of Licensee Reported Problems
Regarding Post-Fire Emergency Lighting
2. List of Recently Issued NRC Information Notices
. Attachment 1
IN 95-36
August 29, 1995
Page 1 of 2
Vermont Yankee Nuclear Power Station (Vermont Yankee)
In LER 94-011, dated October 5, 1994, Vermont Yankee Nuclear Power
Corporation, the licensee for Vermont Yankee, reported that 8-hour battery-
powered emergency lighting units required by Section III.J of Appendix R to
10 CFR Part 50 were not installed in several areas. The licensee attributed
this condition to its failure to properly identify all areas requiring post-
fire safe shutdown lighting units. The licensee had not considered areas for
fire scenarios that do not require control room evacuation. Subsequently, in
LER 95-003, dated February 17, 1995, the licensee reported that while
reviewing procedures to ensure operator actions in response to cable vault or
control room fires, it discovered that the existing emergency lighting in the
intake structure did not meet the technical requirements of Section III.J of
Appendix R to 10 CFR Part 50. The licensee attributed this condition to a
lack of comprehensive review of an emergent issue and a lack of comprehensive
documentation of its Appendix R program. The corrective actions include (1) a
comprehensive walkdown inspection to ensure that appropriate emergency
lighting was provided; (2) the addition of emergency lighting units in the
areas in which, during a fire, shutdown would require manual action;
(3) review and evaluation of its processes to ensure that when new issues are
identified, they receive a comprehensive review to identify all areas and
programs to which they apply. The licensee also requested an exemption for
certain areas from the technical requirements of Section III.J on the basis
that existing security lighting satisfies the underlying safety objective.
The NRC staff will evaluate the exemption request.
Indian Point Nuclear Generating Unit No. 3 (IP3)
In LER 93-007, dated February 8, 1993, New York Power Authority, the licensee
for IP3, determined that two operator egress pathways did not have the 8-hour
battery-powered emergency lighting units required by Section III.J of
Appendix R to 10 CFR Part 50. The licensee reported that it made erroneous
assumptions about operator pathways out of the control room in the event of a
fire and overlooked these two egress routes. The licensee revised the
modification procedures to include an assessment of Appendix R requirements
and revised its Appendix R operating procedures so that an assessment of
emergency lighting will be performed after procedure revisions and during
biannual reviews. Another event was reported by the licensee in LER 93-055,
dated January 26, 1994 and Revision 1, dated July 21, 1994. The licensee
found that 1-1/2-hour emergency lights were installed in three areas in which
Appendix R requires at least an 8-hour battery power supply. The licensee
identified this error during an emergency lighting blackout test. According
to the licensee, the error occurred during installation of the lights and its
modification closeout process failed to recognize the deficiency. The
licensee changed the insufficient emergency lights to 8-hour emergency lights.
Other licensee actions included (1) a blackout test for fire scenarios that
require alternate shutdown, (2) a blackout test for fire scenarios that do not
require control room evacuation, and (3) a revision of the Modification
Control Manual Program to ensure that modifications comply with Appendix R
requirements.. Attachment 1
IN 95-36
August 29, 1995
Page 2 of 2
Washington Public Power Supply System Nuclear Project No. 2 (WNP-2)
In LER 92-018, dated May 28, 1992, Washington Public Power Supply System, the
licensee for WNP-2, reported that 8-hour battery-powered emergency lighting
units required by Appendix R to 10 CFR Part 50 were not installed in six areas
that would require manual operator actions for fire scenarios not requiring
control room evacuation. In addition, the licensee reported that it had
failed to incorporate into its procedures the operator actions that were
identified during followup reviews. The licensee attributed this oversight to
inadequate design and lack of interdepartmental communication. For corrective
actions, the licensee (1) added emergency lighting units in the six deficient
areas, (2) reviewed procedures to ensure that all operator actions required by
the plant shutdown analysis were addressed, and (3) evaluated the process by
which design information is incorporated into plant procedures.
Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon)
In LER 2-92-001-01, dated October 29, 1992, Pacific Gas and Electric Company,
the licensee for Diablo Canyon, reported that it found a number of emergency
lighting deficiencies during its Appendix R Design-Basis Documentation
Enhancement Project and a self-assessment of the Diablo Canyon fire hazards
safe shutdown analysis. Later, in submittals of March 15, 1994, and
May 25, 1994, the licensee stated that it would install permanent emergency
lighting units in certain areas and requested an exemption from the technical
requirements of Section III.J of Appendix R for other areas. (Diablo Canyon
is not an Appendix R plant; therefore, the NRC staff treated the exemption
request as a deviation from a commitment to meet the requirements of
Section III.J of Appendix R.) On the basis of its evaluation of the
deviation, which included reviews of the licensee's submittals and walkdown
inspections during a site visit, the NRC staff concluded that the licensee did
not provide an adequate technical justification for the proposed deviation.
The staff also concluded that the alternative proposed by the licensee (the
use of hand-held flashlights rather than fixed emergency lighting units) did
not provide a level of safety equivalent to that provided by Section III.J of
Appendix R to 10 CFR Part 50. The NRC staff transmitted its denial of the
deviation request and its safety evaluation to the licensee in a letter dated
May 5, 1995. By letter dated May 9, 1995, the licensee committed to install
battery-operated lights where required.
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