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Nuclear Energy m oneN-teuPow sino.,

Nortbeut Nuclear Energy CornpanyP.O. Ikia 128Waterford, CT 06'E0128(860) 447 1791Fan (860) 444 4277

ne Northeast Utih6c Systern

NOV 2 81997Docket No. 50-423

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U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555

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Millstone Nuclear Power Station, Unit No. 3Safety Evaluation Report (NUREG 1031)

The purpose of this letter is to advise the NRC Staff of a clarification to the MillstoneUnit No. 3 Safety Evaluation Report (NUREG 1031) that was identified during ourConfiguration Management Program review, In Section 9.5.3.3, page 9-63, the NRC3

Staff review of the emergency lighting system concluded that the system was notacceptable. One of the open issues was a requirement to verify every 18 months that;

; the plant lighting systems are operable and provide rated illumination.1

On page 9-1 of Millstone Unit No. 3 Safety Evaluation Report, Supplement No. 3(NUREG 1031), the NRC Staff notes that Northeast Nuclear Energy Company(NNECO) letter, dated July 18,1985, provided information to address the open issue.The letter identified that NNECO would comply with the Illuminating Engineers Society(lES) Handbook regarding desian of the emergency lighting system. NNECO, however,does not use illumination level testing every 18 months to verify the plant lighting

'system is operable.

NNECO conducted a photometric survey of access / egress routes, slight /high hazardareas, and manned work stations during initial plant testing. Operability of the fM,emergency lighting has been confirmed every eighteen months by maintenanceprocedure, including a voltage drop test of batteries. The lighting system is nowverified by Surveillance Procedure to ensure that emergency light heads are pointedproperly in addition to encompassing all testing previously performed in the )

. maintenance procedure. These methods are standard practice in the industry in lieu ofperforming a blackout test and photometric surveys in the Control Room and in otherareas of the plant.

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U".S. Nucl: r Regul tory Commission*'

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B16741\Page 2,

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Should you havo v.ny questions regarding this matter, please contact Mr. D. A. Smith at(860)437-5840.

Very truly yours,

NORTHEAST NUCLEAR ENERGY COMPANY

Al} k WM. H. Brothers TVice President - Millstone Unit No. 3

cc: H. J. Miller, Region | AdministratorJ. W. Andersen, NRC Project Manager, Millstone Unit No. 3A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3W. D. Travers, Ph.D., Director, Special Projects Office

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Docket No. 50-423E1EZd.1

Attachment 1

Millstone Nuclear Power Station, Unit No. 3

Commitments1

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iNovember 1997

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B16741%ttachment 1\Page i*

EnclosureList of Regulatory Commitments

The following table identifies those actions committed to by NNECO in this document.Please notify the Manager - Regulatory Compliance at the Millstone Nuclear PowerStation Unit No. 3 of any questions regarding this document or any associatedregulatory commitments.

Commitment Committed DateNone