ML17229A673
| ML17229A673 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/26/1998 |
| From: | Frehafer K, Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-98-077, L-98-77, LER-98-002-01, LER-98-2-1, NUDOCS 9804020418 | |
| Download: ML17229A673 (40) | |
Text
~ CATEGORY REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9804020418 DOC.DATE: 98/03/26 NOTARIZED: NO DOCKET ¹ FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power S Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION FREMFER;K.W. Florida Power & Light Co.
STALL,J.A. Florida Power & Light Co.
RECIP.NAME , RECIPIENT AFFILIATION
SUBJECT:
LER 98-002-00:on 980224,radiation monitor surveillance inadequacies led to operating of facility prohibited by TSs.
Caused by congnitive personnel error. Permanent procedure changes were implemented.W/980326 ltr.
DISTRIBUTION CODE: ZE22T COPIES RECEIVED:LTR ENCL SIZE:
TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 GLEAVES,W 1 1 INTERNAL: 1 1 SOD/NPD/RAB 2 2 ACRS'EOD/SPD/RRAB 1 1 FILE CENTER' 1 1 NRR/DE/ECGB 1 1 EELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 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 D 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 N
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Florida Power St Light Company,6351 S. Ocean Drive, Jensen Beach, FL34957 March 26. 1998 L-98-077 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Reportable Event: 98-002 Date of Event: February 24, 1998 Radiation Monitor Surveillance Inadequacies Led to 0 eration ofFacilit Prohibited b Technical S ecifications The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73.
Very truly yours, Vice President St. Lucie Plant JAS/EJW/KWF Attachment
'c: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant 9804020418 980326 PDR ADQCK 05000389 8 PDR an FPL Group company
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 31600104 (4-96) EXFUIES 04)30/Qs ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATO INFORMATION CO!LECTION REQUEST: 60.0 HRS. REPORTED LESSON LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND FE BACK TO BIDUS(RY. FORWARD COMMENTS REGARDING BURDEN ESTIMAT LZCEHSEE EVENT REPORT (LER) TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T 0 F33)
U.S. NUC(EAR REGULATORY COMMISSION. WASHINGTON, DC 206664)00(
AND TO THE PAPERWORK REDUCTION PROJECT (3(600(04), OFFICE 0 (See reverse for required number of MANAGEMENTAND BUDGET, WASHINGTON, DC 20603.
digits/characters for each block)
FACIUTY NAME (1), DOCKET N(2%4SER (2) PAGE t3)
ST LUCIE UNIT 2 05000389 1 OF8 TITLE (4)
Radiation Monitor Surveillance Inadequacies Led to Operation of Facility Prohibited by Technical Specifications FACIUTY NAME DOCKET NUMBER MONTH DAY YEAR SEQUENT)AL REVISION NUMBER NUMBER MONTH DAY YEAR n/a FACIUTY NAME DOCKET NUMBER 24 98 98 002 0 3 26 98 n/a OPERATING MODE (9) 20.2201(b) 20.2203(a)(2)(v) 50.73(a) (2) (i) 50.73(a) (2)(vnr)
POWER LEVEL (10) 100 20.2203(a) (2)(i) 20.2203(a) (3) (ii) 50.73(a)(2)(iii) 73.71 OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a) (2) (v) Specify fn Abstract ba(ow or in NRC Form 388A 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a) (2) (vii)
NAME TE(EPHONE NUMSOI Boolude Area Code)
K. W. Frehafer, Licensing Engineer l561) 468-4284 cAUBE SYSTEM COMPONENT REPORTABLE MANUFACTURER TO NPRDS SYSTEM COMPONENT MANUFACTURER TO NPRDS IL n/a n/a n/a D IL n/a n/a n/a MONTH DAY YEAR EXPECTED YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15)
ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewiitten lines) (16)
On February 24, 1998, St. Lucia Unit 2 was in Mode 1 at 100 percent power. The system engineer discovered the first of two surveillance procedure deficiencies concerning the control room outside air intake (CROAI) radiation monitors. The monthly functional test did not verify the CROAI radiation monitor alarm and trip setpoints. The second surveillance procedure deficiency was discovered on March 5, 1998, when it was concluded that the channel calibration test did not verify operation of the CROAI radiation monitor output contacts.
The cause of the procedure deficiencies was cognitive personnel error during development of the surveillance procedures.
Corrective actions included declarinEI the CROAI radiation monitors out of service and entering the appropriate Technical Specification ACTION statement requirements at the time of discovery.
Permanent procedure changes were implemented, and testing was completed on the CROAI radiation monitors to declare them back in service.
NRC FORM 388 (4 96)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO I4.95I LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 2 05000389 2 OF 8 98 002 0 TEXT (If more space is rertuired, use additional copies of NRC Farm 366A/ I17)
On February 24, 1998, St. Lucie Unit 2 was in Mode 1 at 100 percent power. The system engineer discovered that the monthly functional surveillance procedure, 2-1220054, "Functional Testing of the Unit 2 Area Radiation Monitoring Systems," for the control room outside air intake (CROAI) radiation monitors did not specify an acceptance limit for the alarm setpoint (EIIS:IL:RA).
Technical Specification table 3.3-6 requires that the control room isolation monitor alarm/trip setpoints be less than or equal to two times background. The procedure was revised in 1994 such that the alarm/trip setpoint for the CROAI radiation monitors was permanently set to a value of 125 counts per minute (CPM). This revision also removed the requirement to verify, recalculate, or review the CROAI radiation monitor alarm/trip setpoints to confirm that they remained consistent with current background levels. An alarm/trip setpoint of 125 CPIVI was non-conservative relative to actual measured background.
E As a conservative measure, at 12:35, on February 24, 1998, both trains of CROAI radiation monitors were declared out of service. At 13:00 the control room was placed in the recirculation mode as allowed by Technical Specification table 3.3-6, ACTION statement 26. The CROAI radiation monitor background was established, the new setpoints were implemented, and three out of the four CROAI radiation monitors were declared back in service at 19:30 on February 25, 1998 (RIM-26-66 remained out of service for an unrelated equipment problem).
During investigation of the CROAI radiation monitor twice background issue, another surveillance discrepancy was identifed on March 5, 1998. Technical Specification table 4.3-3 requires that a channel calibration for the CROAI radiation monitors be performed on a refueling interval periodicity. The channel calibration surveillance requirement includes testing the actuation logic.
Procedure 2-1400069, "Calibration of the PSL-2 Control Room Outside Air Intake Monitors (CROAI's)," is intended to satisfy the channel calibration test requirement. However, this procedure did not fully satisfy the surveillance requirements since the CROAI radiation monitor contact output to the control room emergency cleanup system (CRECS) actuation logic was not verified. FPL determined that past actuation of CROAI radiation monitors RIM-26-65 and 66 established operability of those monitors'utput contacts.
Based on the above, CROAI radiation monitors RIM-26-61 and 62 were declared inoperable at 14:40 on March 5, 1998, and the surveillance requirements of Technical Specification 4.0.3 were exercised. The surveillance testing was completed satisfactorily, and Operations declared CROAI radiation monitors back'in service at 17:15 on March 5, 1998.
The cause of these events was determined to be cognitive personnel error during the development of the CROAI radiation monitor surveillance procedures. Per Technical Specification Table 3.3-6, control room isolation monitor alarm/trip setpoints shall be less than or equal to two times background. CROAI monitor alarm/trip setpoints were routinely verified to be within two NRC FORM 388A (4.95)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO I4-65l LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 2 05000389 3 OF 8 98 002 .
0 TEXT (ifmore spaceis required, use additional copies of fVRC Form M84/ I17I times background levels during monthly functional testing via procedure 2-1220054. A 1994 procedure revision erroneously removed these steps from the procedure. Since that time, the alert/trip setpoints were not recalculated or reviewed to confirm that they remained consistent with current background levels. In addition, procedure 2-.1400069 failed to properly test the CRECS actuation function of the CROAI radiation monitor output contacts. These errors led to procedural inadequacies.
Both conditions described in this report are reportable under 10 CFR 50.73(a)(2)(i)(B) as any operation or condition prohibited by the plant's Technical Specifications.
Technical Specification table 3.3-6 specifies that the CROAI radiation monitor setpoint shall be less than or equal to twice background. Technical Specification table 4.3-3 requires a monthly channel functional test. A channel functional test is required to verify operability of the alarm and/or trip function. Contrary to Technical Specification surveillance requirements, the CROAI radiation monitor alarm/trip setpoints were not verified as part of the channel functional test.
Additionally, Technical Specification table 4.3-3 requires a CROAI radiation monitor channel calibration on a refueling interval basis. Channel calibrations shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to the known values of the parameter which the channel monitors. Channel calibrations shall encompass the entire channel including the sensor and alarm and/or trip functions, and may be performed by any seiies of sequential, overlapping, or total channel steps such that the entire channel is calibrated. Contrary to Technical Specification surveillance requirements, the CROAI radiation monitor alarm/trip output contacts were not adequately tested as part of the channel calibration activities.
The function of the CROAI radiation monitors is to actuate CRECS when high radiation levels are detected from the outside air intake ducts. The analysis states that following a loss of coolant accident, the total exposure from airborne activity within the control room are within the limits set forth in 10 CFR 50, Appendix A, General Design Criterion (GDC) 19. These monitors are also used a's control room habitability instrumentation to enable the operator to evaluate habitability NAC FOAM 366A I4-95I
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO (4-95I LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEOUENTIAL REVISION ST LUCIE UNIT 2 05000389 4 OF 8 98 002 0 TEXT iifmore spece is required, use edditionel copies of NRC Ferm 3SGAJ I17) conditions. By comparing the readings from the two air intakes, the operator can determine which side of the plant has the lower airborne radiation level and allow outside air with the lower airborne radiation to be drawn in.
Unit 2 is equipped with four safety related CROAI radiation monitors (RIM-26-61, 62, 65 5 66).
Two redundant trains monitor each of the two control room air intake ducts. Each CROAI monitor uses two detectors. The first detector is a scintillation detector which is sensitive to both beta particles and gamma rays. The second detector is identical to the first except an aluminum beta shield is installed over the scintillation detector. Therefore, the second detector is sensitive only to gamma rays. The monitor subtracts the gamma-only signal from the combined beta and gamma signal with a result that represents only the beta contribution. The beta activity is displayed by the monitor as a third detector channel. The beta activity, which is representative of the actual contamination contribution to the background activity level, is the process signal used to develop the CROAI radiation monitor alarm and trip function. This arrangement provides a discriminating background that is not sen'sitiye to changes in the gamma ray background. Upon detection of high beta radiation activity by the monitors, a signal is developed to isolate the control room and initiate the CRECS fans.
The design of the monitor utilizes the beta shielded detector to establish background because all beta radiation is considered contamination for the purpose of these monitors. Since ambient beta levels in the atmosphere are considered negligible, defining them as contamination is conservative and reasonable. Background radiation is not a singular value, but is defined as a range of normal activity levels. This range was defined as two standard deviations from the average background level taken over a defined time period. This means that contamination activity levels would have to increase to twice average background activity levels to cause an alarm/trip, and satisfies the requirements of the Technical Specifications. This setpoint methodology also avoids undesired nuisance alarms and unnecessary control room recirculation actuations due to electronic noise or beta background fluctuations.
Although the previous CROAI radiation monitor setpoint of 125 CPM was non-conservative relative to the derived background as described above, this condition had no safety significance.
The function of the CROAI radiation monitors during accident conditions is to provide a signaI to initiate CRECS to prevent the dose to the control room operators from exceeding GDC 19 criteria. Specifying a CRECS actuation setpoint at twice background is extremely conservative relative to the safety function being performed. The following comparisons support this assertion.
NRC FORM 366A I4 9SI
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSI I4-95I LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 2 05000389 5 OF 8 98 002 0 TEXT llfmore speceis required, use edditionel copies of NRC Form 3M4/ I17I Engineering reviewed the Unit 1 CROAI radiation monitor requirements, and although there are no Unit 1 Technical Specification requirements for the Unit 1 CROAI monitors, the Unit 1 updated final safety analysis report (UFSAR) states that the CROAI radiation monitor trip setpoints are approximately 320 CPM. Additionally, the Standard Technical Specifications (STS) setpoint for the control room isolation signal is a nominal value of 6 X 10'PM above normal background. The as-found Unit 2 CROAI radiation monitor setpoint of 125 CPM is bounded by both the Unit 1 CROAI radiation monitor setpoints and the STS setpoint requirements for control room isolation. Therefore, FPL concludes that the post accident control room operator dose would be bounded by GDC 19 criteria.
The CROAI radiation monitor channel calibration procedure 2-1400069 did not fully satisfy the surveillance requirements because the CROAI radiation monitor contact output to the CRECS actuation logic was not verified. Procedure 2-1400069 installed a jumper across the output contacts of the monitor under test, thus preventing the de-energization of relay 3A(3B) (which would actuate CRECS) during the radiation monitor test (see Figure 1). The control room isolation function of relay 3A(3B) is verified during the Unit 1 and 2 Integrated Safeguards procedures by generating a containment isolation actuation signal (CIAS). However, neither the Safeguards nor the channel calibration surveillance procedures verified CRECS actuation via the CROAI radiation monitor output contacts.
The operation and maintenance history for the past 18 months was reviewed to determine if operation of the CROAI radiation monitor contacts could be demonstrated in some other manner.
Two related events were found as follows:
A spurious actuation of the control room emergency ventilation system occurred on November 8, 1997. The spurious actuation was definitively determined to have been caused by radiation monitor RIM-26-65. This event demonstrates the operation of the output contacts of this monitor.
- 2. A spurious actuation of the control room emergency ventilation system recently occurred on March 3, 1998 The spurious actuation was definitively determined to
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have been caused by radiation monitor RIM-26-66 This event demonstrates the
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operation of the output contacts of this monitor.
The operation of the two remaining radiation monitors was verified on March 5, 1998. Based on the above, FPL concludes that reasonable assurance was provided that the past capability of the CROAI radiation monitors control room isolation function was not affected by the inadequate surveillances.
NRC FORM 366A (4-95)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO I4.9SI LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 2 05000389 6 OF 8 98 002 0 TEXT (Ifmore space is required, use additional copies of hfRC porm 366Ai (17)
Based on the discussions above, both conditions were not safety significant and the public health and safety were not adversely affected.
~
1 The CROAI radiation monitors RIM-25-61, -62, -65, and -66 were declared out of service and Unit 2 entered Technical Specification Table 3.3-6 Action 26 on February 24, 1998. The CROAI radiation monitor background was established, and the new setpoints entered into the monitors on February 25, 1998, at which time three of the CROAI radiation monitors were placed back in service (RIM-26-66 remained out of service for an unrelated equipment problem).
The CROAI radiation monitors RIM-25-61 and 62 were declared out of service and
,Technical Specification 4.0.3 was exercised on March 5, 1998. Work Order 98005359 verified the trip function operability of RIM-26-61 and 62, and the CROAI radiation monitors were placed back in service the same day.
Changes to the CROAI channel calibration surveillance procedure 2-1400069, "Calibration of the PSL-2 Control Room Outside Air Intake Monitors (CROAI's)," were implemented that requires that the monitor setpoints be recalculated as part of the surveillance and to also verify the operability of the trip actuation relay contacts.
- 4. Changes to the CROAI monthly functional surveillance procedure, 2-1220054, "Functional Testing of the Unit 2 Area Radiation Monitoring Systems," were implemented that requires review of the monitor setpoints as part of the surveillance.
- 5. The total equipment data base (TEDB) for RIM-26-61, -62, -65,.and -66 will be updated to reflect the correct setpoint methodology for the CROAI radiation monitors.
- 6. Radiation monitor setpoints are under review as part of an on-going Offsite Dose Calculation Manual review.
NRC FORM 389A (4.95I
0 NRC FORM 366A U.S. NUCLEAR REGUlATORY COMMISSIO I4.95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEOUENTIAL REVISION ST LUCIE UNIT 2 05000389 7 OF 8 98 002 0 TEXT llfmore space is required, use eddiuonel copies of NAC Form 3MA/ (17I None LER 50-335, 389/97-006, "Operation Prohibited by Technical Specifications Due to Inadequately Tested Degraded Voltage System."
LER 50-389/97-008, "Inadequate Control Room Ventilation Procedure Results in Condition Prohibited by Technical Specifications."
LER 50-389/97-006, "Operation Prohibited by Technical Specifications Due to Inadequate Surveillance Testing of ESF Subgroup Relays."
NRC FORM 368A I4 95I
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO (4.95I LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 2 05000389 8 OF 8 98 002 0 TEXT (ifmore space is required, use additional copies of IVRC Ferm MGA/ I17I Contacts Normally Closed Contacts Open on Actuation RIM-26-61 Output Contact RIM-26-62 Output Contact RIM-26-65 Output Contact RIM-26-66 Output Contact U1 CIAS Contact-U2 CIAS Contact-3A Relay De-energize to Initiate 3B Relay Control Room Isolation and Recirculation, Train SA Train SB Fans and Dampers Fans and Dampers Figure 1 GROAI Radiation Monitor CRECS Actuation NRC FORM 368A I4.95l
Distri70.txt
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RidsRgn...MailCenter 1 Not Found RidsResDraaOerab 1 OK RidsResDetErab 1 OK RidsNrrDssaSplb 1 OK RidsNrrDripRexb 1 OK RidsNrrDipmIolb 1 OK RidsManager 1 OK RGN 2 .FILE 01 1 Not Found RES/DRAA/OERAB 1 Not Found RES/DET/ERAB 1 Not Found NRR/DSSA/SPLB 1 Not Found NRR/DRIP/REXB 1 Not Found RR/~DMSO 1 Not Found F-IEE CENTE 1 Not Found ACRS 1 Not Found External Recipients:
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Item: 'ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003677070
Subject:
LER 99-008-00 regarding improper return of RPS channel back in service which resulted in operation prohibited by TS on 12/14/99. With lette r dated 1/12/00.
Body:
Page 1
Distri70.txt Docket: 05000389, Notes: N/A Page 2
Florida Power 5 Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 January 12, 2000 FPL L-2000-013 10 CFR $ 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Reportable Event: 1999-008-00 Date of Event: December 14, 1999 Improper Return of RPS Channel Back in Service Results in 0 eration Prohibited b TS The attached Licensee Event Report 1999-008 is being submitted pursuant to the requirements of 10 CFR $ 50.73 to provide notification of the subject event.
Very truly yours, J. A. Stall Vice President St. Lucie Nuclear Plant JAS/EJW/KWF Attachment cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Nuclear Plant an FPL Group company GQ p6 r ~ C)7 C~>
NRC FORM 366 U.S. N R REGULATORY COMMISSION APPROVED B B NO. 3150-0104 EXPIRES 06/30/2001 (6-'I 998)
Estimated burdon per response lo comply with this mandatory information collection request: 50 hrs. Reported lessons learned are incorporated into the licensing procoss and fed back to tndustry. Fonvard comments regarding LICENSEE EVENT REPORT (LER) burden estimato to the Records Management Branch (TW F33), U.S. Nuclear Renulatory Commission, Washington, DC 2055&4001 and to the Paperwork
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Reduction Project (31504104), Office of Management and 8udget, (See reverse for required number of Washington, DC 20503. If an information collection does not display a currently valid OMB control number, lhe NRC may nol conduct, or sponsor, digits/characters for each block) and a person is not required to respond lo,!he Information collection.
FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)
St. Lucie Unit 2 05000389 Page 1 of 4 TITLE (4)
Improper Return of RPS Channel Back in Service Results in Operation Prohibited by TS EVENT DATE (5) LER NUMBER (6 REPORT DATE (7 OTHER FACILITIES INVOLVED 6)
SEQUENTIAL REVISION FACIUTV NAME OOCKET NVMSER MONTH DAY YEAR YEAR MONTH DAY NUMBER NUMBER FACILITY NAME OOCKET NUMBER 12 14 1999 1999 008 00 01 12 2000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQ UIREMENTS OF 10 CFR g: (Check one or more) l11)
MODE (9) 20.2201(b) 20.2203(a) (2)(v) 50.73(a)(2) (i) 50.73la) (2)(viii)
POWER 20.2203(a) (1) 20. 2203 (a) (3) (i) 50.73(a) l2)(ii) 50.73(a)(2)(x)
LEVEL (10) 100 20.2203(a)(2) (i) 20.2203(a)(3) (ii) 50.73(a)(2)(iii) 73.71 20.2203 (a) (2) (ii) 20.2203(a)(4) 50.73(a) (2)(iv) OTHER 20.2203(a) (2) (iii) '0.36(c)(1) 50.73(a) (2) (v) Specify ln Abstract below or 20.2203(a) (2) (iv) 50.36(c)(2) 50.73(a) (2) (vii) in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONE NUMBER Saetude Area Codet Kenneth W. Frehafer (561) 467 - 7748 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 I CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE REPORTABLE To Eplx CAUSE SYSTEM COMPONENT MANUFACTURER To EPIX NA NA NO SUPPLEMENTAL REPORT EXPECTED (14I MONTH DAY EXPECTED YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15)
ABSTRACT (Limit to 1400speces, i.e., approximately 15 single-spaced typewrr'tten lines/.{16)
On December 14, 1999, St. Lucie Unit 2 was in Mode 1 operation at 100 percent reactor power. On December 14, 1999, FPL determined that channel "D" of the reactor protection system steam generator low level trip was placed back in service without the post maintenance testing required by a temporary change to procedure 2-OSP-62.02, "RPS Logic Matrix Test."
cause for this event was human error. Proper oversight was not maintained
'he following the decision to perform the logic matrix test using a temporary change to the logic matrix test procedure.
Upon discovery, FPL performed the required post maintenance testing. Operations personnel were informed of the incident to prevent recurrence.
NAC FORM 386 (8-1998)
NRC FORM 366A .S. NUCLEAR REGULATORY COMMISSION 16-1999)
LICENSEE EVENT REPORT (LERj TEXT CONTINUATION DQGKET LER NUMBER (6) PAGE (3)
FACILITYNAME (1) NUMBER 2 SEQUENTIAL REVISION NUMBER NUMBER St. Lucie Unit 2 05000389 008 Page 2 of 4 1999 00 TEXT Iifmore spaceis required, use edditionel copies of NRC Form 366AI (17)
Description of the Event On December 14, 1999, St. Lucie Unit 2 was in Mode 1 operation at 100 percent reactor power. On December 14, .1999, FPL determined that channel "D" of the reactor protection system IEIIS:JE] (RPS) steam generator (SG) low level trips was placed back in service (BIS) without having performed the post maintenance testing (PMT) required by temporary change (TC)99-163 to procedure 2-OSP-62.02, "RPS Logic Matrix Test."
On December 7, 1999r RPS SG 2A and 2B level trip bypass channel D were placed in bypass due to the level transmitter for 1A SG level [EIIS:JE:SG:LT], LT-9013D, failing high. On December 8, 1999, a one-time TC to 2-OSP-62.02, "RPS Logic Matrix Test," was written to allow for RPS testing with this channel bypassed. Notes were added to the procedure to allow proceeding with the remainder of the RPS system and that PMT for the channel "D" RPS SG 2A and 2B low level trips would be required prior to placing those channels BIS. On December 9, 1999, the logic matrix test was completed satisfactorily. On December 13, 1999, LT-9013D, was declared back in service and the RPS channels associated with LT-9013D were 'taken from the bypass position and placed to normal. On December 14, 1999, FPL determined that the required PMT was not performed. The required portions of the logic matrix test were completed upon discovery of the deficiency and a Condition Report was initiated.
Cause of the Event The cause for this event was human error. Proper oversight was not maintained following the decision to perform the logic matrix test using a TC to the logic matrix test procedure. On-shift Operations management requested that the TC be drafted and the paperwork for the change was approved by an assisant nuclear plant supervisor (ANPS) and a nuclear plant supervisor (NPS).
On December 9, 1999, upon completion of the RPS logic matrix test, barriers such as the EOOS Log, Data Sheet 29 for deferred surveillance, NPS turnover sheet, etc.
should have been used to ensure that the proper PMT was performed prior to declaring the instrument back in service and placing the bypass switch back to normal. Shift supervision actually discussed the use of Data Sheet 29 of OP-2-0010125A, "Deferred Surveillance," to track the surveillance requirements of channel "D" prior to returning it to service. However, this was not done. Failure to use available administrative tools led to this event.
Analysis of the Event This event is reportable under 10 CFR 50.73 (a)(2)(i)(B) as "... any operation or condition prohibited by the plant's Technical Specifications. The applicable Technical Specification 3/4.3.1, "Reactor Protective Devices," action statement was:
"With the number of channels OPERABLE one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may continue provided the inoperable channel is placed in the bypassed or tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."
Contrary to this requirement, LT-9013D was removed from the bypassed condition and "
placed to normal on December 13. The logic matrix test for this channel had not been completed and the grace period for this surveillance had expired on December 9, 1999.
Therefore, RPS channel "D" was not in compliance with the requirements of Technical Specifications.
NRC FORM 3BBA <6-1999)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6.1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION DOCKET LER NUMBER (6) PAGE (3)
FACILITYNAME (1) NUMBER (2 SEQUENTIAL REVISION NUMBER NUMBER St. Lucie Unit 05000389 Page 3 of 4 2
1999 008 " 00 TEXT llfmore space is required, use additional copies of iVRC Form 366A J (17)
Analysis of Safety Significance The reactor protective system (RPS) consists of sensors, calculators, logic, and other equipment necessary to monitor selected nuclear steam supply system (NSSS) conditions and to effect reliable and rapid reactor shutdown (reactor trip) if any or settings.
a combination of the monitored conditions approach specified safety system The RPS functions are to assure that reactor coolant pressure boundary (RCPB) and fuel performance, guidelines are not exceeded during moderate frequency eventscertain and infrequent events and also to provide assistance in limiting conditions for limiting faults. A reactor trip initiated by the RPS causes the input (CEDMCS) motive power to be removed from the control element drive mechanism control system by the trip switchgear, which in turn causes all control element assemblies to be inserted by gravity. The low steam generator water level trip is provided to trip the reactor when the lower of the measured steam generator water levels for the two steam generators falls to a low preset value.
The system is designed such that the single failure criterion and performance requirements are met with three channels in service. A coincidence of any two like trip signals generates a reactor trip signal. However, four measurement channels with electrical and physical separation are provided for each parameter. To enhance plant availability, a fourth channel is provided as a spare and allows bypassing of one channel while maintaining the requisite two-out-of-three logic.
The benefit of a system that includes four independent and redundant channels is that the system can be operated, if need be, with up to two channels out of service (one still meet the single failure criterion. The bypassed and another tripped) and system logic must be restored to at least a three operating channel condition prior to removing another channel for maintenance.
The subsequent surveillance of the RPS "D" channels proved that the RPS channe'1 "D" 2A and 2B SG level trips were operable during the time interval between December 13 and December 14, 1999. However, even ifthis the channel "D" RPS SG 2A and 2B SG level condition would not affect the requisite trips were postulated to be inoperable, two-out-of-three RPS initiating logic for a SG level trip because no other SG level RPS channels were in bypass or trip during this time period. Therefore, this event had no impact on'he health and safety of the public.
Corrective Actions
- 1. The RPS logic matrix test was performed for channel "D" on December 14, 1999, immediately upon discovery the required PMT was not performed.
- 2. A memo was sent to all Operations management personnel describing this scenario and event. This will allow for the sharing of lessons learned and heighten personnel awareness to this type of attention to detail issue.
- 3. Training will develop and incorporate this event into the next re-qualification cycle as an in-house industry event.
NRC FORM 366A (6.1988)
IVRC FORM 366A .S. NUCLEAR REGULATORY COMMISSION (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION DOCKET LER NUMBER (6) PAGE (3)
FACILITYNAME (1) NUMBER 2)
SEQUENTIAL REVISION NUMBER NUMBER St. Lucie Unit 2 05000389 008 Page 4 of 4 1999 00 TEXT iifmore specs is required, use edditionel copies of NRC Form 366AJ (17)
Additional Znfoxmation Failed Com onents Identified None Similar Events None NRC FORM 366A (6-1998)
I f,
l,
Distri47.txt ii/W8l Distribution Sheet Priority: Normal From: Elaine Walker Action Recipients: Copies:
NRR/DLPM/LPD2-2 1 Not Found K Jabbour Not Found Internal Recipients:
RGN FILE 01 1 Not Found RES/DRAA/OERAB Not Found RES/DET/ERAB 1 Not Found NRR/DSSA/SPLB 1 Not Found, NRR/DRIP/REXB Not Found NRR/Dl M/IOLB 1 Not Found FILE CENTER~ 1 Not Found ACRS Not Found External Recipients:
NRC PDR Not Found NOAC QUEENER,DS Not Found NOAC POORE,W. Not Found L ST LOBBY WARD Not Found internet: smittw@inel.gov Not Found INEEL Marshall Not Found Total Copies: 16 Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 993400404
Subject:
LER 99-006-01, "Sub-Critical Reactor Trip Due to Inadvertent MSIV Opening." With 9911 24 Letter.
Body:
PDR ADOCK 05000389 S Page 1
Distri47.txt Docket: 05000389, Notes: N/A Page 2
Florida Power 8 Light Company,6351 S. Ocean Drive, Jensen Beach, FL34957 November 24, 1999 FPL L-99-258 10 CFR $ 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Reportable Event: 1999-006-01 Date ofEvent: June 6, 1999 Sub-Critical Reactor Trip Due t Inadvertent MSIV 0 enin The attached revision to Licensee Event Report 1999-006 is being submitted pursuant to the requirements of 10 CFR g 50.73 to provide notification of the subject event.
This revision expands on the initial unsuccessful operator attempts to close the MSIVs.
Very truly yours, J. A. Stall Vice President St. Lucie Nuclear Plant JAS/EJW/KWF Attachment cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Nuclear Plant
EXPIRES 06I3012001 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150.0104 (8.1998) Estimated burden cer response to comply with this mandatory information requesl: 50 hrs. Reported lessons learned are 'ncorporaled into the 'ollection process and fed back to Industry. Forward comments regarding 'icensing buiden estimale lo the Records Management Branch {T4 F33). U.S. Nuclear LlCENSEE EVENT REPORT (LER) Regulatory Commission, Washington. DC 205554001, and to the Papenvork I Reduction prelect {31504IOSJ, Office ol Management and Budget, Washington, DC 20503. If an information collecbon does not display a (See reverse for required number of currently valid OMB control number, the NRC may not conduct or sponsor.
digits/characters for each block) and a person fs not required to respond to, the information collection.
DOCKET NUMBER (2) PAGE (3)
FACILITY NAME (1)
St. Lucie Unit 2 05000389 Page 1 of 4 TITLE (4)
Sub-Critical Reactor Trip Due to Inadvertent MSIV Opening EVENT DATE {5)
DAY YEAR YEAR "
NUMBER
~
LER NUMBER 6)
"~' "
NuhtBER REPORT DATE (7 MONTH DAY YEAR FACIUTY NAME OTHER FACILITIES INVOLVED 81 OOCKET NVMBEn oocKET NUMaot 06 06 1999 1999 006 - 01 11 24 FACIUTY NAME OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQ UIREMENTS OF 10 CFR 5: (Check one or mora) {11)
MODE (8) 20. 2201 (b) 20.2203(a)(2)(v) 50.73(a) (2)(i) 50.73(e) (2)(vnl) 20.2203(a) {1) 20.2203{a) l3) li) 50.73(a)(2)(ii) 50.73(a) (2) (x)
POWER 000 LEVEL {10) 20,2203(e){2)(i) 20.2203{a)(3) {ii) 50.73(a) (2) (iii) 73.71 20.2203{a) (2) (ii) 20. 2203 (a) (4) 50.73(a) (2)(iv) OTHER 20.2203{a)(2) liii) 50.36(c) l1) 50 73{a)(2)lv) Specrfy in Abstract below or In NAC Form 366A 20.2203{a) (2) liv) 50.36(c) (2) 50.73 (a) (2) (vii)
UCENSEE CONTACT FOR THIS LER 12)
HAME TELEFIIONF. NUMBER andueo Ares Code)
Kenneth N. Fzehafer (561) 467 7748 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX To EPIX
.SB V NO SUPPLEMENTAL REPORT EXPECTED l14) MONTH DAY EXPECTED YES SUBMISSION No DATE (15) llf yea, complete EXPECTED SUBMISSION DATE).
ABSTRACT /limit to 1400 spaces, i e., epproximetely 15 single.spaced typewritten lines/ ll6)
On June 6, 1999, St. Lucie Unit 2 was stable in Mode 3 with all control element assemblies fully inserted foz troubleshooting of the Unit 2 control element assembly motion control system. The main steam isolation valves were closed in accordance with an equipment clearance order. During the release of the equipment clearance order following completion of maintenance, the 2B main steam isolation valve, HCV-08-1B, unexpectedly opened to approximately 90 percent of full open. Due to the resulting pressure differential between the 2A and 2B steam generators, a reactor trip signal was generated and all trip circuit breakers opened. Subsequently, the 2B main steam isolation valve was closed.
The event was caused due to personnel error when the clearance was released.
Procedural guidance on how to restore the main steam isolation valves was not followed.
Corrective actions included Operation supervision instruction to the operating crews, stand down meetings, operator aids, and training.
This revision expands on the initial unsuccessful operator attempts to close the MSIVs .
NAC FOAM 366 i6-1998)
AIRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1996)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION DOCKET LER NUMBER (6) PAGE (3)
FACILITYNAME (1) NUMBER 2 SEQUENTIAL REVISION NUMBER NUMBER St. Lucie Unit 2 05000389 Page 2 of 4 1999 006 01 TEXT (lf more space is required, use additional copies of NRC Form 366A) (17)
Description of the Event On June 6, 1999, St. Lucie Unit 2 was stable in Mode 3 with all control element assemblies fully inserted for troubleshooting of the Unit 2 control element assembly (CEA) motion control system [EZIS:AA). Both steam generators (SGs) were at normal no-load pressures of 900 psia, with heat removal being accomplished using the atmospheric dump valves (ADVs) . The main steam isolation valves (MSIVs) [EZIS: SB:V) were closed in accordance with equipment clearance order (ECO) 2-99-06-011S in order to maintain the main steam header vented for personnel safety during an i'nspection inside the main generator. Following completion of the generator inspection, the ECO was signed off and was being released. During the release of the ECO, the 2B MSIV, HCV-08-1B, unexpectedly opened to approximately 90% of full open. The 2B SG pressure rapidly dropped to approximately 740 psia due to the immediate pressurization of the main steam header. The 2B SG pressure slowly recovered towards normal no-load pressure as pressure between the 2B SG and the main steam header equalized.
Due to the resulting pressure differential between the 2A and 2B SGs, a reactor trip signal was generated on asymmetric steam generator transient atapproximately 1859 hours0.0215 days <br />0.516 hours <br />0.00307 weeks <br />7.073495e-4 months <br />. The reactor protection system (RPS) trip logic was made up and all trip circuit breakers (TCBs) [EIZS: JC:BKR] opened, although no rod motion occurred as all CEAs were already fully inserted prior to the trip. Due to the cooldown resulting from the MSZV opening, pressurizer level began to'ecrease and the control room crew isolated the letdown system to conserve reactor coolant system (RCS) inventory.
Attempts to close the 2B MSIV from the control room were unsuccessful, and the crew entered emergency operating procedure, EOP-5, "Excess Steam Demand," at 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br /> to verify plant safety functions. As the main steam header was intact at the time of the event, the steam demand effectively ceased once pressures between the 2B SG and main steam header equalized. Initial attempts to locally close the 2B MSZV locally using Appendix I, "MSIV Local Closure", of EOP-99, "Appendixes/Figures/Tables", were unsuccessful, but the 2B MSZV was finally closed at 1953 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.431165e-4 months <br />.
Cause of the Event The cause of the event was personnel error in the failure to utilize operating procedure (OP) 2-0810020, "Main Steam System Initial Valve Alignment," during the release of ECO 2-99-06-011S. Contributing factors include an inadequate pre-job brief by the licensed operator, the assistant nuclear plant supervisor (ANPS), and inadequate operator knowledge of the MSZV air system.
The Unit 2 MSZVs have a complex hydraulic and pneumatic control system and are designed to fail open on a loss of DC control power. Because of this, a specific sequence must be followed to restore air and power in order to prevent inadvertent opening of the valve. The basic sequence, as discussed in OP 2-0810020, is to restore DC control power to the valve first, and then hold the control switch in the CLOSE position while a total of eight aiz isolation valves aze opened, During the release of the ECO, air was being restored to the valve prior to the control power fuses being re-installed, and the control switch was not being held in the CLOSE position.
In order to close the MSZVs, the crew determined that they needed to implement procedure OP 2-0810020, "Main Steam Sys Initial Valve Alignment," Step 8.10, Returning the 2B MSIV (HCV-08-1B) to service, which states in part:
- 1. Station a nuclear plant operator (NPO) at the MSIV with a radio. Ensure all air valves are fully closed.
NRc FORM 366A I6 1996)
0 VRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION 6-1998) j LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION DOCKET LER NUMBER (6) PAGE (3)
FACILITYNAME (1) NUMBER 2 SEQUENTIAl REVISION NUMBER NUMBER St. Lucie Unit 2 05000389 Page 3 of 4 1999 006 01 TEXT (If more spece is reqoired, use edditionel copies of NRC Form 366A) (17)
Cause of the Event (cont'd)
- 3. Take HCV-08-1B handswitch at the RTGB to CLOSE position and hold it there.
P.
However, an oversight on the part of the ANPS who was working through the procedure caused step number two to be missed. contributing to this oversight was the fact that the MSIV indicating lights were lit (these lights aze not dependent on control power) which led the crew to erroneously believe control power was available.
Therefore, the 2B MSIV continued to open during this attempt to close the MSIVs.
Therefore the initial attempts to remotely close the valve from the control zoom were .
unsuccessful. Additionally, the 2B MSIV air system had not been fully restored and was not in a proper configuration to support local operation of the valve.
Therefore, initial attempts to locally close the 2B MSIV, by disconnecting pressure switch fitti.ngs in accordance with Appendix I of EOP-99 to allow the air to vent, were also unsuccessful'ater, the proper configuration of the air system and Appendix I was successful in closing the valve. was'chieved Analysis of the Event This event is reportable under 10 CFR 50.73(a)(2)(iv) as "any event or condition that resulted in a manual or automatic actuation of any Engineered Safety Feature (ESF),
including the Reactor Protection System (RPS)." Although the RPS safety function had been already been completed before the event, the event is still reportable as a valid trip signal was generated in response to actual plant parameters.
Analysis of. Safety Significance The cooldown transient resulting from the opening of the 2B MSIV resulted in the following changes in RCS parameters:
~ Pressurizer pressure decreased from 2250 psia to 2150 psi.a.
~ Pressurizer level decreased from 33 percent to 25 percent.
~ RCS temperature decreased from 532 degrees to approximately 517 degrees.
I Once the"2B S/G and main steam header pressures equalized, the RCS parameters began trending back toward their initial'values due to the influence of core decay heat and reactor coolant pump heat. At the time of the event, all CEAs were fully inserted and boron concentration was conservatively elevated to support CEA testing and a planned future reactor start up. Adequate shutdown margin was maintained at all times .
Although the reactor trip signal was incidental to the event, a review of the sequence of events recorder (SOER) printout indicates that RPS responded properly to the event. The correct trip signal was genezated on all four RPS channels and all eight TCBs opened within 0.040 seconds of completing the trip logic.
Based on the above, this event had no adverse impact on the health and safety of the public.
Corrective Actions
- 1. Operations supervision immediately provided short term reinforcement by memorandum to all Operations personnel that ECOs need to be referenced against plant NRC FORM 366A (6 1998)
6IC FORM 366A UA. NUCLEAR REGULATORY COMMISSION 6 1998I J
LlCENSEE EVENT REPORT (LER)
KXT CONTINUATION FACILITYNAME I1) LER NUMBER I6) PAGE I3)
NUMBER I2I SEQUENTIAL REVISION NUMBER NUMBER St. Lucie Vnit 2 05000389 006 Page 4 of 4 1999 01 I more spece ks reqkkkred, kkse edCkeorkel copkes o IVRC orm 36&V procedures. This instruction dictated that if a plant procedure provided instructions for removing equipment from service or returning equipment to service, then the evolution is to be conducted in accordance with the procedure and the ECO modified as necessary to ensure compliance with the procedure.
- 2. The operators involved were temporarily removed from licensed activities in order to develop the zoot cause and corrective actions for this event. They participated in the stand down meetings of corrective action 3 below. The operators were returned to licensed duties after de-briefing the plant general manager on their findings.
- 3. Operations management issued a night order and conducted several stand down meetings concerning the use of procedures to restore systems to their in service condition as well as the use of check sheet 9 of procedure AP 0010120, "Conduct of Operations," an aid that provide items to consider when planning evolutions, during the performance of pre-evolution briefs.
- 4. Operations has installed placards at each MSIV cautioning against manipulating components prior to enabling/disabling MSIV without consulting OP 2-0810020, "Main
. Steam System Initial Valve Alignment."
- 5. Training will cover this'vent/MSIV design in licensed operator zequalification training (industry events).
Additional Information Failed Com onents Identified None Similar Events None NRC ORM 3BBA IB-1898)
Distri99.txt Distribution Sheet Priority: Normal From: Kim Brown Action Recipients: Copies:
W Gleaves Not Found NRR/DLPM/LPD2-2 1 Not Found Internal Recipients:
RGN 2.FILE 01 Not Found RES/DRAA/OERAB 1 Not Found RES/DET/ERAB 1 Not Found
~
NRR/DSSA/SPLB Not Found
, NRR/DRIP/REXB 1 Not Found NRR/DIP M/IOLB 1 Not Found ILE CE E 1 Not Found ACRS Not Found External Recipients:
NRC PDR Not Found NOAC QUEENER,DS Not Found NOAC POORE,W. .1 Not Found L ST LOBBY WARD 1 Not Found internet: smittw@inel.gov 1 Not Found INEEL Marshall Not Found Total Copies: 16 Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 993280004
Subject:
St. Lucie Unit 2 Docket No 50-389 LER Number 98-009 Not Used Body:
PDR ADOCK 05000389 S Docket: 05000389, Notes: N/A Page 1
Distri99.txt Page-2
0 F(orida Power 8c Light Company,6351 S. Ocean Drive, Jensen Beach, FL 34957 November 15, 1999 L-99-213 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 2.
Docket No. 50-389 LER Number 98-009 Not Used Please be advised that LER number 98-009 will not be used for St. Lucie Unit 2, docket number 50-389.
Please contact us should there be any questions regarding this information.
Very tnily yours, J. A. Stall Vice President St. Lucie Plant JAS/KWF cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant
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an FPL Group company
Distri99.txt Distribution Sheet Priority: Normal From: Kim Brown Action Recipients: Copies:
W Gleaves Not Found NRR/DLPM/LPD2-2 Not Found Internal Recipients:
RGN 2.FILE 01 Not Found RES/DRAA/OERAB Not Found RES/DET/ERAB I Not Found NRR/DSSA/SPLB 1 Not Found
'RR/DRIP/REXB 1 Not Found.
NRR/DIPM/IOLB 1 Not Found FILE CENTER 1 Not Found ACRS Not Found External Recipients:
NRC PDR Not Found NOA,C QUEEN DS Not Found e~OAC POX?,RE, .
'1 Not Found L ST LOBBY WARD Not Found internet: smittw@inel.gov 1 Not Found INEEL Marshall Not Found Total Copies: 16 Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID:,993280004
Subject:
St. Lucie Unit 2 Docket No 50-389 LER Number 98-009 Not Used Body:
PDR ADOCK 05000389 S Docket: 05000389, Notes: N/A Page 1
r C
Distri99.txt Page 2
Fiorida Power & Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 November 15, 1999 L-99-213 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 2 Docket No. 50-389 LER Number 98-009 Not Used Please be advised that LER number 98-009 gill not be used for St. Lucie Unit 2, docket number 50-389.
Please contact us should there be any questions regarding this information.
Very tnily yours, J. A. Stall Vice President St. Lucie Plant JAS/KWF cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant g>> ~guns'(
I an FPL Group company
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