ML17229A628

LER 98-004-00:on 980121,emergency Lighting Outside App R Design Bases Occurred.Caused by Congnitive Personnel Error During Translation of App R Section Iii.Procedures Onop 1 & 2 ONP-100.01 Were Issued for Use on 980206.W/980219 Ltr

ML17229A628
Person / Time
Site:	Saint Lucie
Issue date:	02/19/1998
From:	Frehafer K, Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-98-051, L-98-51, LER-98-004, LER-98-4, NUDOCS 9802250239
Download: ML17229A628 (14)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRXBUTION SYSTEM (RIDS)

II Q~ ~'ACCESSION NBR':9802250239 DOC.'DATE "98/02/19 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power &, Light Co. 05000335 AUTH.NAME AUTHOR AFFILIATION FREHAFER,K.W. Florida Power & Light Co.

STALL,J.A. 'lori;da'ower & Light Co;-

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 98-004-00:on 980121,emergency lighting outside App R design bases occurred;"Caused'by congnitive personnel error during translation of App R section III.Procedures ONOP 1 &

2 ONP-100.01 were issued for use on 980206.W/980219 ltr.

DISTRIBDTION!CODE: IE22T" COPIES RECEIVED:LTR 1'SIZE:.

TITLE:-'0.73/50.9 -Licensee Event '-Report (LER), QIncident Rpt, etc.

ENCL

~ l II NOTES:

RECIPIENT . COPIES ' RECIPIENT COPIES ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL PD2-3 PD 1 1 GLEAVES,W '1 1 INTERNAL: ACRS 1 AEOD/SPJ)g 2. 2 AEOD/SPD/RRAB 1 1 F ER 1 1 NRR/DE/ECGB 1 1 NRR/DE/EELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1' NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 -

1 NRR/DSSA/SRXB 1 1 RES/DET/EIB 1 1 RGN2 FILE 01 1 1 EXTERNAL. L ST LOBBY WARD 1 1 LITCO BRYCE,J H 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1

( (

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LIST'R REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROI DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR ENCL

0 Florida Power & Light Company,6351 S. Ocean Drive, Jensen Beach, FL34957 February 19, 1998 FPL L-98-051 10 CFR 50.73

-U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Reportable Event: 98-004 Date of Event: January 21, 1998 Emergency Lighting Outside t'A endixRDesi n Bases The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/EJW/KWF Attachment cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant 9802250239 9802i9 PDR ADQCK 05000335 S PDR llllllrrlrrilr rllllgliellllllI an FPL Group company ~~

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMS No. 316041104 (4-96) EXPBIES 04/30/0 S ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATOR INFORMATION COLLECTION REOUESTr 60J) HRS. REPORTED LESSON LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND F BACK To BIOUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMAT LICENSEE EVENT REPORT (LER) TO THE INFORMATION AND RECORDS MANAGEMENTBRANCH IT% F33)

US. NUCLEAR REGIAATORY COMMISSION, WASHINGTON, OC 206664001 ANO To THE PAPERWORK REDUCTION PROJECT (316 F104); OFRCE 0 (See reverse for required number of MANAGEMENTANO BUDGET, WASHINGTON, OC 20603.

digits/characters for each bIockl FAcIUTY NAME UI DOCKET NIW4BER 121 PAGE 13)

ST LUCIE UNIT 1 05000335 1 OF7 TITLE IBI Emergency Lighting Outside Appendix R Design Bases FACIUTY NAME DOCKET NUMBER DAY YEAR SEOUENTIAL, REVISION NUMBER NUMBER DAY ST LUCIE UNIT 2 05000389 21 98 98 004 ,0 19 98 FACILITYNAME DOCKETNUMBER 05000 OPERATING MODE (6) 20.2201(b) 20.2203(a) (2)(v) 50.73(a) (2) (i) 50.73(a)(2)(viii)

POWER LEVEL l10) 100 20.2203(a) (2) (i) 20.2203 (a) (3) (ii) 50.73(s) l2) liii) 73.71 OTHER 20.2203(a) (2)(iii) 50.36(c)(1) 50.73(a) (2) (v) Specify In Abstract below or In NRC Form 366A 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2) (vii)

NAME TELEPHONE NUMBER enerude Area Code)

K. W. Frehafer I561) 468%284 CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER REPORTAGE To NPROS To NPRDS A FH LF N/A N/A F,H LF N/A N/A MONTH OAY YEAR EXPECTED YES SUBMISSION llf yes, complete EXPECTED SUBMISSION DATE). X No DATE (15)

ABSTRACT (Umit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) l16)

On January 21, 1998, Units 1 and 2 were in Mode 1 at 100 percent reactor power. While utility personnel were performing an extensive plant fire protection compliance analysis, FPL determined that eight-hour battery backed emergency lighting units required for Appendix R alternate shutdown were not provided for selected alternate shutdown manual action areas, and a one hour ENS phone call was made.

The apparent cause of this event was cognitive personnel error during the translation of Appendix R Section III.J requirements into the St. Lucie emergency lighting design and procedures.

Interim corrective actions include the use of existing emergency diesel generator backed lighting fixtures that were evaluated to provide adequate lighting, and the proceduralized use of battery powered lights staged in selected areas of the site. Long term corrective actions include review and update of the safe shutdown analyses for manual actions and emergency lighting enhancements, and providing the deficient areas identified with emergency lighting that meets the requirements of Appendix R,Section III.J.

NRC FORM 366 (4-96)

NRC FORM 3BBA U.S. NUCLEAR REGULATORY COMMISSIO I4.95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 2 OF 7 98 004 0 TEXT (Ifmore spaceis required, use edditionel copies of NRC &rm 388AJ I17)

On January 21, 1998; Units 1 and;2 were in Mode 1 at 100 percent reactor power. Utility personnel were performing an extensive plant Fire Protection compliance analysis. 'While reviewing. the Unit 1 and 2 Off-Normal Operating Procedures (ONOPs) for Control Room .

Inaccessibility,'ONOP 1 and 2-0030135, "Control Room Inaccessibility,".FPL determined that eight-'hour battery backed emergency lighting units [EIIS:FH:LF] required foi Appendix R alternate shutdown were not provided for selected alternate shutdown manual action's. The subject proce'dures provide the operating instructions to safely shut down the affected unit in'h'e event of a control room or cable spreading room fire (i.e., alternate shutdown) ~

As stated in both the Unit 1 and Unit 2 FSARs, Appendix 9.5A, permanently installed eight-hour emergency lighting is to be provided in areas needed for manual operation of alternate and safe shutdown (hot standby) equipment and the access/egress rout'es thereto. Appendix R Section III.J requirements are less stringent, and do not preclude the use of portable eight-hour emergency lighting. However, contrary to Appendix R Section III.J requirements, FPL identified some manual actions areas and access/egress routes thereto that are not provided with either permanent or portable eight-hour emergency lighting. The NRC ENS notification required by 10 CFR 50.72 was completed on January 21, 1998.

In accordance with Section III.L of Appendix R, procedures shall be in effect to implement this capability. Specific discrepancies identified from the procedure reviews are as follows:

Appendix D, Steps 1 and 2, requires that the normal/isolate switches for Power Operated Relief Valve (PORV) V1402 and V1404 be placed in the 'ISOLATE'osition.

These manual actions take place in the A and B electrical penetration rooms. However, there are no installed eight-hour battery powered lighting units in either room, 'or the proceduralized use of portable eight-hour emergency lighting, as required by Section III.J.

2) There are several outdoor manual actions identified in the procedure that do not have Appendix R emergency lighting. For example, Appendix B, Step 1, requires manual actions at the turbine front standard. Appendix J requires local manual operation of the atmospheric dump valves which are located on the mezzanine level of the A and B steam trestles.

gl NRC FORM 366A'4-96)

U.S. NUCLEAR REGULATORY COMMISSIO LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 3 OF 7 98 004 0 TEXT ilfmore space is required, use edditionel copies of IVRC Form 3MA/ I17I k

There are several outdoor manual actions identified in the procedure that do n'ot have Appendix R emergency lighting. For example, Steps 7.2.11, 7.2.12 and 7.2.~13 require manual actions in the steam trestle and Appendix B, Step 1, requires manual actions at the turbine front standard.

FPL determined that existing emergency lighting fixtures located within the affected areas are powered from A and B train emergency diesel generators, and provide adequate lighting for the performance of the manual actions. Additional battery powered lights are staged at the entrance to affected areas as compensatory measures, and no operability concern exists for continued plant operation.

The cause of this event was cognitive personnel error during the translation of Appendix R Section III.J requirements into the St. Lucie emergency lighting design and procedures. Areas in which manual operation of alternate and safe shutdown (hot standby) equipment is required, and the access/egress routes thereto, are required to have emergency lighting backed by an eight-hour battery power supply. However, some manual action areas or access/egress routes were not provided with either fixed eight-hour battery backed emergency lights, or the proceduralized use of portable eight-hour battery backed emergency lights. A contributing factor to this event was that the St. Lucie Safe Shutdown Analysis (SSA), which analyzed the effect of postulated fires on the ability to safely shutdown the unit, was deficient in that compensatory manual actions were not clearly described in the document.

This condition has been determined to be reportable under 10 CFR 50.73(a)(2)(ii), as a condition resulting in the nuclear power plant being operated outside its Appendix R design basis. As stated in both the Unit 1 and Unit 2 FSARs, Appendix 9.5A, permanently installed eight-hour emergency lighting is to be provided in areas needed for manual operation of alternate and safe shutdown (hot standby) equipment and the access/egress routes thereto. Appendix R requirements are less stringent, and do not preclude the use of portable eight-hour emergency lighting. However, contrary to Appendix R Section iii.J requirements, FPL identified some manual actions areas and access/egress routes thereto that are not provided with either permanent or portable eight-hour emergency lighting.

li E

NRC FORM 386A U.S. NUCLEAR REGULATORY COMMISSIO I4-96)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 4 OF 7 98 004 0 TEXT iifmore speceis required, use edditionel copies of NRC Form 366t4J I17I Item III.J of Appendix'R. (Emergency Lighting) requires th'at emer'gency lighting units with at least an eight-hour battery power supply be provided in all areas needed for operation of-safe shutdown equipment and in access and egress routes thereto. For Unit 1, FSAR Appendix 9.5A delineates specific conformance to Appendix R. Table 2'.5 indicates that conformance to Item-III.J has been met with the use of permanently installed emergency lighting fixtures.. The. table also indicates that dedicated portable emergency lighting is available for containment access and for selected cold shutdown operations. Section 3.7 of the Unit 1 FSAR is consistent with Table 2.5. However, Section 3.7 also states that lighting is provided in areas needed for manual operation of alternate and safe shutdown (hot standby) equipment. For Unit 2, FSAR Appendix 9.5A delineates specific conformance to Appendix R. Table 2.5 indicates that conformance to Item III.J has been met with the use of permanently installed emergency lighting fixtures. The table also indicates that dedicated portable emergency lighting is available for containment access and for selected cold shutdown operations. Section 3.7 of the Unit 2 FSAR is consistent with Table 2.5, similar to Unit 1.

The Unit 1 and 2 cable spreading rooms are currently under a pre-existing compensatory 30 minute roving fire watch. In addition, both cable spreading rooms are equipped with automatic fire detection and fire suppression systems. The enhanced roving fire watches and the fire protection features minimize the potential for a fire that would develop beyond the incipient stages before detection and require alternate shutdown. Based on the plant design and compensatory actions currently in place, the potential for a control room or cable spreading room fire are considered significantly small and would not affect alternate shutdown capability.

In the unlikely event a fire did occur in the control room or cable spreading room, a review of the Unit 1 and 2 control room inaccessibility procedures was performed to determine what the effect would be with the lack of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery backed emergency lighting. A comparison of the required manual actions versus available emergency lighting was performed to determine operability. The following summary of each procedure is provided below.

0 NRC FORM SSSA U.S. NUCLEAR REGULATORY COMMISSIO I4-99)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 5 OF 7 98 004 0 TEXT (ifmoie space is rettuired, trse edditionel copies of NRC Form 368Ai I17I Upon completion of an initial review of the subject procedure, the manual actions which require a review for Appendix R emergency lighting can be grouped into either indoor actions (i.e. Reactor Auxiliary Building (RAB)) or outdoor actions (i.e. turbine building, steam trestles, RAB roof, etc.).

For the indoor areas, in addition to the dedicated Appendix R emergency lights, 4 Emergency Portable Lantern Storage lockers (EPLS), each containing 4 portable lanterns, are available on each elevation (-0.5, 19.5 and 43') of the RAB. As shown on plant drawings, these lights can be utilized for access/egress and the performance of manual actions within the indoor areas.

Also, as stated in Section 9.5.3 of the FSAR, normal/emergency (N/E) AC lighting is available for indoor and outdoor areas. The N/E lighting consists of 2 redundant and physically separate (A and B train) lighting systems which are backed'by the emergency diesel generators.

The critical indoor manual action lacking 'dedicated emergency lighting is the Appendix D, Steps 1 and 2, action of placing the PORV isolate switches in the 'ISOLATE'osition. Isolating the

'PORV switches is required to prevent spurious. opening of the PORVs for fires in the control room or cable spreading room. The manual actions are taken in the A and B electrical penetration rooms which are located in the RAB 19.5'evel. The required manual action is a simple action of operating a switch. No special access or tools are required. Diesel backed N/E lighting from both the A and B trains is available in each room. Also, there are 4 portable emergency lanterns in locker ¹3 (EPLS-Locker ¹3) located in the AB switchgear room for use in the fire areas associated with the isolate switches (Fire Areas A and C). An additional portable lantern locker

~

is also available at the entrance to containment (EPLS-Locker ¹1) This locker is approximately

~

20'rom the entrance to the electrical penetration rooms. Emergency lighting for access and egress within the RAB to these lockers is provided. Although portable lighting is available, this condition is not considered optimal as there is currently no procedural guidance for the specific action to obtain the portable lights. In addition, having to go to the AB switchgear room to

~

obtain the portable lights does not yield the most direct route to the electrical penetration rooms for the PORV manual action.

The actions to be performed outside the control room in outdoor areas'are either contingency actions (Step 7.1.2 and Appendix B Step 1 - tripping the turbine at the front standard, Step 7.1.6 - closing manual steam generator blowdown isolation valves, Step 7.2.11 - locally closing the Main Steam Isolation Valves (MSIVs) or a longer term manual action required for plant cooldown (Appendix J - local Atmospheric Dump Valve (ADV) operation)). For these outdoor manual actions, emergency power backed N/E lighting is available to general access/egress walkways. Tripping the turbine at the front standard and isolation of blowdown on the RAB MOP cllAkl %RAh td.Orl

NRC FORM 3BBA U.S. NUCLEAR REGULATORY COMMISSIO I4-96)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 6 OF 7 98 004 0 TEXT /iimare speceis required, use eddi tionel copies oi NRC Form 366Ai I 17) roof are relatively-simple contingency actions that likely could be accommodated with the current available'level of N/E lighting. Access/egress is also provided by N/E lights. N/E lights are also available for access/egress to the steam trestle and redundant N/E lights are available in the steam trestles themselves. Portable emergency lanterns could be utilized in the steam trestles to perform local isolation of the MSIVs and the longer term action of locally operating the ADVs to accommodate plant cooldown.

Upon completion of an initial review of the subject procedure, the manual actions which require a review for Appendix R emergency lighting outside the control room are performed in outdoor areas. As stated in Section 9.5.3 of the FSAR;.normal/emergency (N/E) AC lighting is available for indoor and outdoor areas. The N/E lighting consists of 2 redundant and physically separate (A and B train) systems which are backed by the emergency diesel generators.

The actions to be performed outside the control room are contingency actions (Step 7.1.2 and Appendix B Step 1 - tripping the turbine at the front standard, Step 7.1.6 - closing manual steam generator blowdown isolation valves, Step 7.2.11 - locally closing the MSIVs). For these outdoor manual actions, emergency power backed N/E lighting is available to illuminate access/egress walkways. Tripping the turbine at the front standard and isolation of blowdown on the RAB roof are relatively simple contingency actions that likely could be accommodated with the current available level of N/E lighting. Access/egress is also provided by N/E lights. N/E lights are also available for access/egress to the steam trestle and redundant N/E lights are available in the steam trestles themselves. Portable emergency lanterns could be utilized in the steam trestles to perform the action of locally isolating the MSIVs.

As discussed above, the available lighting is considered adequate for the performance of the necessary manual actions, and both St. Lucie Units 1 and 2 are considered operable. To further enhance operability, several short term compensatory'actions were implemented as discussed below.

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO I4-99)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 7 OF 7 98 004 0 TEXT Pf more space ls required, use additional copies of NRC Form 366AJ I17)

1. 's an iriterim measure,.portable. battery backed lights have been positioned at locations to support manual actions in areas:where no fixed lights are located and portable light Iockers are not located nearby. Procedures ONOP 1 and 2-0030135, "Control Room Inaccessibility," and procedures 1 and 2 ONP-100.01, ".Response to Fire," were revised to specify the existence, location, and,use of the portable lights. in areas where no fixed battery backed emergency lighting is provided. Procedures ONOP 1 and 2-0030135 were issued for use on January 30, 1998. Procedures 1 and 2 ONP-100.01 were issued

-for use on February 6, 1998.

2. FPL will complete a detailed line-by-line evaluation of the current plant control room inaccessibility and general response to-fire procedures to identify any SSA manual actions which require enhanced Appendix R emergency lighting. Upon, completion of the SSA reviews for manual action clarifications, the emergency. light requirement evaluation will be finalized.

3. The deficient areas identified are to be supplemented by emergency lighting that meets the requirements of Appendix R,Section III.J.

None LER 50-335, 389/97-007, "RCP Oil Collection System Outside Appendix R Design Bases."

Describes event where initial design was inadequate to meet Appendix R requirements.

LER 50-389/97-004, "Incorrect Original Cable Tray Fire Stop Assemblies Outside Appendix R Design Bases." Describes event where initial design was inadequate to meet Appendix R requirements.

NRC FORM 3Il8A (4 951