ML17229B088
| ML17229B088 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/31/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229B087 | List: |
| References | |
| 50-335-98-14-01, 50-335-98-14-1, EA-98-513, NUDOCS 9904150220 | |
| Download: ML17229B088 (90) | |
Text
i Florida Power & Light Company St. Lucie Nuclear Plant NOTICE OF VIOLATION Docket No. 50-335 License No. DPR-67 EA 98-513 During an NRC inspection conducted on October 10-23 and November 2-6, 1998, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Operating License DPR-67 (Unit 1) Condition 2.C (3) specifies that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR) for the facilities and as approved by various NRC Safety Evaluation Reports.
Unit 1, which was licensed to operate prior to January 1, 1979, is required by 10 CFR 50.48(b) to meet the requirements of Sections III.Lof Appendix R to 10 CFR Part 50.
Section III.L.3of Appendix R to 10 CFR Part 50 requires that the alternative shutdown capability be independent of the specific fire areas(s) and shall accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures shall be in effect to implement this capability.
Procedure 1-ONOP-100.02, "Control Room Inaccessibility," Revision 1, is the procedure that implemented the licensee's alternative shutdown capability.
Contrary to the above, as of April 3, 1998, Procedure 1-ONOP-100.02 was inadequate to implement the alternative shutdown capability. Specifically, the procedure failed to provide adequate guidance to ensure that heating, ventilation and air conditioning equipment to the 1B Electrical Equipment Room and the Hot Shutdown Control Panel Room would be properly operated in the event of a fire in the Control Room or in the Cable Spreading Room. (01013)
This is a Severity Level III violation (Supplement I).
The NRC has concluded that information regarding the reasons for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved has been adequately addressed on the docket as discussed in the letter transmitting this Notice of Violation (Notice), and in Inspection Report Nos. 50-335/98-14, 50-389/98-14.
However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.
In that case, or if you choose to respond, submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001 with a copy to the Regional Administrator, Region II, U.S. Nuclear Regulatory Commission, Atlanta Federal Center, 23T85, 61 Forsyth Street S.W.,
Atlanta, Georgia, 30303-3415 and a copy to the NRC Resident Inspector at the St. Lucie facility, within 30 days of the date of the letter transmitting this Notice.
9904i50220 9'7033K PDR ADOCK 05000335 8
PDR Enclosure 1
NOV 2
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
If you chose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days after receipt.
Dated this 3i day of March 1999
LIST OF ATTENDEES Nuclear Re ulato Commission L. Reyes, Regional Administrator V. McCree, Deputy Director, Division of Reactor Safety (DRS)
C. Casto, Deputy Director, Division of Reactor Projects (DRP)
A. Boland, Enforcement Officer, Enforcement and Investigations Coordination Staff (EICS)
S. Sparks, Senior Enforcement Specialist, EICS C. Evans, Regional Counsel L. Wert, Branch Chief, DRP G. Belisle, Maintenance Branch Chief, DRS T. Morrissey, Project Engineer, DRP W. Rogers, Senior Reactor Analyst, DRS M. Parker, Senior Reactor Analyst, Region III W. Gleaves, Project Manager, Office of Nuclear Reactor Regulation (NRR) (video conference)
P. Madden, Fire Protection Engineering Section, Plant Systems Branch, NRR T. Reis, Senior Enforcement Coordinator, Office of Enforcement (video conference)
S. West, Chief, Fire Protection Engineering Section, Plant Systems Branch, NRR (video
'onference)
S. Newberry, Deputy Director, Division of Systems Safety and Analysis, NRR (video conference)
K. Clark, Office of Public Affairs
~ M. Tschiltz, Regional Coordinator, Office of the Executive Director for Operations (video conference)
Florida Power and Li ht Com an T. Plunkett, President, Nuclear Division A. Stall, Vice President, St. Lucie R. Kundalkar, Vice President, Nuclear Engineering Guey, Supervisor, Reliability and Risk Assessment V. Rubano, Safe Shutdown Analysis Review Team Leader J. Hoffman, Fire Protection Project Engineer E. Weinkam, Licensing Manager, St. Lucie C. Fisher, Fire Protection M. Ross, Attorney
OPEN PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA ST. LUCIE NUCLEAR STATION JANUARY 7, 1999, 1:00 P.M.
NRC REGION II OFFICE, ATLANTA,GEORGIA I.
OPENING REMARKS AND INTRODUCTIONS L. Reyes, Regional Administrator II.
SUIVIMARYOF THE ISSUES L. Reyes, Regional Administrator III.
NRC ENFORCEIVIENT POLICY A. Boland, Director Enforcement and Investigations Coordination Staff IV.
STATEMENTS OF CONCERNS / APPARENT VIOLATIONS V. McCree, Deputy Director Division of Reactor Safety V.
LICENSEE PRESENTATION Vl.
BREAK / NRC CAUCUS V
Vll.
NRC FOLLOWUP QUESTIONS Vill. CLOSING REMARKS L. Reyes, Regional Administrator Enclosure 3
I S ESTOBEDI ED A.
10 CFR 50.48 requires that all operating nuclear power plants have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50.
'perating License DPR -67 (Unit 1) Condition 2.C (3) specifies that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR for the facilities and as approved by various NRC SERs.
Unit 1, which was licensed to operate prior to January 1, 1979, is required by 10 CFR 50.48(b) to meet the requirements of Section III.Lof Appendix R to 10 CFR Part 50.
'ections III.L.2.e and III.L.3of Appendix R to 10 CFR Part 50, require that supporting functions shall be capable of providing the process cooling necessary to permit the operation of the equipment used for safe-shutdown functions, and that alternative shutdown capability shall accommodate postfire conditions where off-site power is or is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Support functions were not capable of providing the process cooling necessary to permit the operation of the equipment used for safe-shutdown functions, under certain predicted conditions.
- Specifically, for fires in the control room or in the cable spreading room, the normal HVAC could be lost due to a loss of offsite power (LOOP) ~ This would result in a loss of HVACto the Electrical Equipment Room 1B 'and the hot shutdown control panel room, which, in turn would cause heat and smoke from a cable spreading room fire to. affect the habitability of the hot shutdown control panel (HSCP) room such that operation of the equipment from the HSCP room w'ould be precluded.
Note: The apparent violations'discussed in this PREDECISIONAL enforcement conference are subject to further review and are subject to change prior to any.'resulting enforcement action.
)
10 CFR 50.48.requires'that all operating.,nuclear power plants have a fire I
protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part.50.
Operating License DPR-67 (Unit 1) Condition 2.C (3) specifies that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR.
The UFSAR, Volume 9.5, Section 4N, Exemption N1 states that conduits carrying cables for charging pump (CP) 1A in Fire Zone 38 will be provided with a minimum 1-hour rated protection.
The 1-hour rated fire protection for CP 1A was not installed as described in the UFSAR.
9 Note: The apparent violations discussed in this PREDECISIONAL enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
1 I 0
C.
10 CFR 50.48 requires that all operating nuclear power plants have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50.
Operating License DPR -67 (Unit 1) Condition 2.C (3) specifies that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR.
Section III.G.1 of Appendix R to 10 CFR Part 50 requires that fire protection features limitfire damage so that one train of system necessary to achieve hot or cold-shutdown are free from fire damage, or can be
. repaired.
Off-normal Operating Procedure 1-ONOP-100.01, "Response to Fire" identified the use of Train A equipment including the 1A low pressure safety injection (LPSI) pump, to maintain safe-shutdown conditions in the event of a fire in Fire Area J.
Fire Area J contained unprotected cables associated with Train A of shutdown cooling equipment, including the 1A LPSI pump. Since this pump was required for safe shutdown of the plant in the event of a fire, the licensee did not meet the requirements of the fire protection program, UFSAR, or Appendix R.
Note: The apparent violations discussed in this PREDECISIONAL enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
D.
10 CFR 50.48 requires that all operating nuclear power plants have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50.
Unit 1 which was licensed to operate prior to January 1, 1979, is required by 10 CFR 50.48(b) to meet the requirements of Sections III.G, III.L, III.J, and III.O.
10 CRF 50, Appendix R,Section III.G.1.a requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or the emergency control station(s) is free of fire damage.
In 10 CFR Part 50, Appendix R, Section lll.L.7requires that the safe
'shutdown equipment and systems for each fire area shall be known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits or shorts to ground in the associated circuits willnot prevent operation of the safe shutdown equipment.
The requirements of Appendix R, Sections III.G.1.a and III.L.7were not being met as evidenced by the following specific deficiencies:
(1) an analysis methodology, which assumed only one spurious operation to occur as a result of fire in any area without any further consideration of the number, type, or specific location of potentially affected cables and circuits; (2) potential for fire to cause a breach of pressurizer power operated relief valve (PORV) and reactor coolant system gas vent system (RCSGV) high/low pressure interface boundaries; and, (3) inadequate evaluation of the potential for fire to cause damage to motor operated valves (MOVs) relied on to accomplish post-fire safe-shutdown functions.
Note: The apparent violations discussed in this PREDECISIONAL enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
@or
~hurtle V~
NRC Inspection Report Nos. 50-335, 389/98-14 Pre-Decisional Enforcement Conference January 7, 1999 Atlanta, Ga.
Agenda Introduction R. S. Kundalkar, Vice President, Nuclear Engineering Discussion J. R. Hoffman, Fire Protection Project Engineer, St. Lucie Plant Concluding Remarks J. A. Stall; Vice President, St. Lucie Plant
'i t 1 I
'I
Introduction
Background
St. Lucie Pilot FPFI Performed March/April, 1998 FPFI Inspection Report Issued July 9, 1998 FPL Provided Corrective Action Status on August 4, 1998 NRC Follow-Up Inspections October 19 and November 2, 1998 NRC Inspection Report 98-14 Issued December 4, 1998 Reason for Visit Update Status of Completed or In-Progress Corrective Actions Confirm NRC's Understanding of Two Level IV Violations Provide FPL's Assessment on Four Apparent Violations
1 I
0
Corrective Action Status 1998 Fire Protection Activities Completed Comprehensive Self Assessment Performed (> 20,000 NlHrs)
Established Compensatory Measures Completed Safe Shutdown Analysis (SSA) Validation Revised Unit 1 and 2 Fire Response Procedures implemented SSA Circuit Modifications Completed Unit 1 Non-Outage Thermo-Lag Corrective Actions
r
+ ~ '
(~
UC/(i.+
O ftp((Q gs.~
Corrective Action Status Planned Major Corrective Actions Complete Outage Related Unit 1 Thermo-Lag Modification Implement Remaining.SSA Circuit Modifications Required Hose Station'Modifications Required Emergency Lighting Modifications Perform Penetration Seal Repairs
I l
'I 0
Level IVViolations Violation A - Failure to Follow Combustible Controls Program Violation 8 - Fire Fighting Strategies Did Not Address HVACfor Equipment Cooling or Include Detailed Smoke Removal Instructions Corrective Action Summary Provided on August 4, 1998 FPL Agrees That Corrective Actions Properly Characterized in Inspection Report Nos. 50-335, 389/98-3 4
Apparent Violations Four Apparent Violations Identified 1.
Hot Shutdown Control Panel (HSCP) Habitability Could Not Be Demonstrated for Compliance With Appendix R 2.
Charging Pump 1A Fire Barriers Not in Compliance With Original Appendix R Exemption 3.
Incorrect Protected Safe Shutdown Method Specified for Fire Area J 4.
Fire Induced Spurious Operation Analysis and Protection Methods Do Not Satisfy Appendix R Requirements
~ Three Issues
'I
Summary IVlajorityof the Fire Protection Deficiencies identified by FPL Self Assessment Activities Safe Shutdown Analysis Deficiencies Associated with Apparent
. Violations Have Low or No Safety Significance FPL Corrective Action Plan Continues to Resolve Fire Protection Deficiencies in a Timely. Manner Fire Safety at St. Lucie Continues to Be Maintained
Apparent Violations Four Apparent Violations Identified HSCP Habitability Could Not Be Demonstrated for Compliance VYith Appendix R 2.
Charging Pump 1A Fire Barriers Not in Compliance With Original Appendix R Exemption 3.
Incorrect Protected Safe Shutdown Method Specified for Fire Area J 4.
Fire Induced Spurious Operation Analysis and Protection Methods Do Not Satisfy Appendix R Requirements
~ Three Issues
I V
e
Apparent Violation 1 Issue - Original Unit 1 SSA and Alternate Shutdown Procedure Did Not Adequately Address HSCP Habitability Cause - Original SSA Deficiency Corrective Actions
+ Immediately Revised Alternate Shutdown Procedure to Include HVAC Manual Actions
+ Added HSCP Fans to Essential Equipment List
+ Modifications Planned for HSCP Fan Circuits (1999}
+ Continuous Fire Watch Remains in Place (Cameras)
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Unit 1 Electrical Equipment Room Layout Baltory Room 1B Ballory Room 1A Exhaust Fan Cable Spreading Room 1A Swltchgaar Room PB HSCP 0
18 Swltchgoar Room Exhausl Fan (19.800 CFM)
HSCP HSCP Supply Exhaust Fan Fan (1000 CFM) (1800 CFM)
Supply Fan (29,300 CFM)
J 1
0
Apparent Violation 1 Issue - Original Unit1 SSA and Alternate Shutdown Procedure Did Not Adequately Address HSCP Habitability VVithinScope of In-Progress SSA Revalidation - Credit for Self Identification Vlarranted Safety Significance - Lovr
+ HVAC Analyses Demonstrate Up to Three Hours Available to Restore Ventilation to Ensure Habitability
+ Existing Emergency Operating Procedure Includes Appropriate HVAC Manual Actions
+ Increase in Core Damage Frequency (CDF) < 1.0E-7/Yr
J
Apparent Violation 2 Issue - Self Assessment Identified That Charging Pump 1A Circuits Not Protected as Required by Original Exemption Documented Prior to FPFI in CR 98-0188 and LER 98-005 Cause - Inadequate Implementation of an Original Fire Protection Exemption Corrective Actions
+ Completed Control Circuit'Reroute (10/98)
+ 1A Charging Pump Power Cable Protection in Progress-Complete by 3/99
+ Continuous Fire Watch Remains in Place (Cameras}
C
gb "alai Unit 1 Charging Pump Cubicle Layout Fire Zone 76 Charging Pump 1A Fire Zone 36A Fire Zone 75 Charging Pump 1B Charging Pump Hallway Fire Zone 38 Charging Pump 1C Charging Pump 1A Conduits 14
Apparent Violation 2 Issue - Self Assessment Identified That Charging Pump 1A Circuits Not Protected as Required by Original Exemption Safety Significance - Low
+ Available Alternate Reactor Coolant System (RCS) Makeup Source Via High Pressure Safety Injection (HPSI) Pumps
+ EOPs in Place to Use HPSI Pumps
+ Increase in CDF < 1.0E-7/Yr
Apparent Violation 3 Issue - Self Assessment Identified That Original SSA Incorrectly Assumed, A Train Protected but 1A Low Pressure Safety Injection (LPSI) Pump Control Circuit Unprotected Documented Prior to FPFI in CR 98-0407 Cause - Original SSA Deficiency Corrective Actions o Immediately Revised Response to Fire Procedure to Reflect B Train Protected
+ SSA Validation Effort Corrected Protected Train Designation 16
Apparent Violation 3 Issue - Self Assessment Identified That Original SSA Incorrectly Assumed A Train Protected but 1A Low Pressure Safety Injection (LPSi} Pump Control Circuit Unprotected Safety Significance - None
+ Appendix R Section III.G Always Met for Fire Area J
+ Use of LPSI Pumps a Long-Term Cold Shutdown Action
+ No CDF Impact
J I
Apparent Violation 4 issue 1 - Original SSA Methodology Assumed Only One Spurious Equipment Operation Original SSA Assumed Any and All Spurious Equipment Operations One at a Time in Accordance With.NRC GL 86-10
+ Concurrent Multiple Spurious Assumed for High/Low Pressure Interfaces (HLPi)
Unit 1 and 2 SSA Validation Effort Considers Multiple Concurrent Spurious Equipment Operation Safety Significance - Low
-+ Three High Risk Fire Zones Evaluated
+ CDF increase Estimated at 2.0E-7/Yr
0
Issue 2 - Inadequate Implementation of HLPI Protection First Example - Potential for Fire Induced Spurious Operation of Unit1 Power Operated Relief Valves
+ Self Assessment Identified That a Small Portion of PORV Circuits Not Protected Documented Prior to FPFI in CR 98-0189 and LER 98-005 Cause - Inadequate SSA Implementation 19
r
Apparent Violation 4 issue 2 - inadequate Implementation of HLPI Protection - First Example Corrective Actions
+ PQRY Circuit Modifications Planned for 1999 Unit 1 Outage
+ Continuous Fire Watch Remains in Piace (Cameras)
Safety Significance - Low
+ Only Small Portion of PORY Circuit Unprotected
+ CDF Increase (1.0E-7/Yr 20
t>>'
Apparent Violation 4 Issue 2-Inadequate Implementation of HLPI Protection Second Example - Potential for Fire Induced Spurious Operation of Unit 1 and 2 Reactor Coolant Gas Vent System (RCGVS) Valves
+ Self Assessment Identified That Original SSA Lacked Detail for RCGVS Spurious Operation Documented Prior to FPFI in CR 98-0403 Cause
- Original SSA Documentation Inadequate 21
Unit 1 Reactor Coolant Gas Vent System Reactor Vessel Head PZR 0.25" Orifice 0.25" Orifice (A Train)
V1463 (B Train) ps V1460 (B Train) gpt)g (A Train)
V1464 (8 Train) gPRg (A Train)
V1466 (B Train)
Vent Vent Vent
Apparent Violation 4 Issue 2 - Inadequate Implementation of HLPI Protection - Second Example Corrective Actions
+ Immediately Developed Procedural Actions for Both Units to Mitigate Spurious RCGVS Operation
+ Modified Unit 2 RCGVS Circuits During Outage (12/98)
+ Unit 1 RCGVS Circuits to Be Modified in 1999 Outage Safety Significance - Low
+ RCS Inventory Loss Within Charging Pump Capacity
+ Increase in CDF < 1.0E-8/Yr 23
0
Apparent Violation 4 Issue 2 - Inadequate Implementation of HLPI Protection Third Example - Inadequate Evaluation of Unit 2 Shutdown.
Cooling System (SDC) Motor Operated Valves (MOVs)
+ Self Assessment Identified That HLPI Protection Removed by Previous Plant Modification Documented Prior to FPFI in CR 98-0225 and LER 98-001 Cause - Inadequate Consideration of Existing Fire Protection Requirements During Modifications to Meet GL 95-07 Requirements 24
-~e, NUc(e dq, gb br(le%~
Unit 2 Shutdown Cooling System RCS Hot Leg 2A V3480 (B Train) gaag (AB Train)
(A Train)
Shutdown Cooling Loop 2A RCS Hot Leg 2B
~V@
'2 (A Train)
V3651 (B Train)
Shutdown Cooling Loop 2B 25
J
Apparent Violation 4 Issue 2-Inadequate Implementation of HLPI Protection - Third Example Corrective Actions
+ Implemented Modification to Protect SDC System Valves During Unit 2 Outage (12/98)
Safety Significance - Low
+ Failure Mode Not Credible
~ All Valves Normally Deenergized
~ Two MOV Failures Required
~ Correct Polarity 480V 3-Phase Cable Faults Required
+ CDF Increase <-1.0E-7/Yr 26
Apparent Violation 4 Issue 3 - Inadequate Implementation of IN 92-18 IN 92-18 Describes Fire Induced Faults in MOV Control Circuits Original St. Lucie IN 92-18 Response Evaluated MOV Control Circuit Faults for Control Room Fire Scenarios SSA Validation Effort Identified Need to Evaluate IN 92-18 Faults for All Fire Areas MOV Evaluation Scheduled for 1999 Per PMAI 98-07-006 Compensatory Measures in Place Recommend Issue Remain Open Pending Completion of MOV Evaluation 27
Issue Summary Self Identified 1A Charging Pump Protection Issue - Low Safety Significance 1A LPSI Pump Protection Issue - No Safety Significance And No Violation Occurred PORV HLPI Issue - Low Safety Significance RCGVS HLPI Issue - Low Safety Significance SDC HLP I Issue - Low Safety Significance IN 92-18 Issue - Recommend Item Remain Open NRC Identified HSCP Habitability Issue - Low Safety Significance And Credit for Self Identification Warranted Multiple Spurious Equipment Operation Issue - Low Safety Significance And Original Regulatory Requirements Met 28
t
'V 0
Concluding Remarks Majority of the Fire Protection Deficiencies Identified by FPL During Self Assessment Apparent Violations Have Low or No Safety Significance Effective Interim Compensatory Measures in Place Aggressive Corrective Action Plan Developed to Correct Deficiencies 30
I
'g, N Use V
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Fire PSA Results for Multiple Spurious Actuations Apparent Violation 4 Issue 1
Fire Induced Hot-Short Probability was determined (NUREGICR-2258) 6.8E-2 per cable Sensitivity Analysis Results for Spurious Actuation Fire Zone Ignit. Freq.
Zone Factor Baseline Single Spurious Multiple Spurious "B" Pen. Rm 3.0E-04/Yr 1.00 6.7E-7/Yr 8.7E-07/Yr 1.0E-06/Yr "B" Cable Loft "B" SWGR 3.0E-03/Yr O. l 4.0E-03/Yr 0.05 6.7E-7/Yr 8.7E-07Nr 4.5E-7Nr 5.8E-07/Yr 1.0E-06/Yr 6.7E-07/Yr
VSAM~~itCW5Wt~X'~~c~&X%%NT4ÃPC~~~C~~~ ~:~
Example 2: From NRC (.one~pondence
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!')'o,'!!(l!tlL'pulIous natu-;)tion. ot ";.qui l: i!! ',nr, t.!e tel'1'ntends to utilize the l'ollowing guidelines:
-.!i(; 'nfe shutdown capabi]ity shou]d>>ot be aclverse]y affected by a>>y ~inc
~p<<eiOOS -..!C:I:Va!:i(>!1 r)r il,otllll ! !.Om
.. t'j!V in ani: plant <<rea; and I>. [!'>C>)('AUIXl~l9ll <.".lpHl>ili/V~I'..->u.'6 i7~>l ]i<-..-lr )
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I i:-!l'";-)'.'.i"(I hy a )'ire ln I
- u>y plant area whIch res!.! I(s in the f<.-..
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7 r ~j <~>>'7) Yi.
...lQoIC).f)Om-)hCCl)CUl!S lOCB!L'd ill LhC;ll'C;1 ill CA'1)!ll))CtL!I'")))4,')'())'punous actuation of signal resulting horn the l'ire: a>>cl
! h(.',')fe ';I7vfr')Auf>> !":lpll!'~I!I(v cl;.0-;.! I)'.I>> '>I h(; ll()v( rsc]y affected b'l)
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)<">>:~ll<'>>'l 'i) >Ill'jr~ilkllcIuation 'ol'll i)<<l>> ~ s 4
in hig.h-I!Ow pvessu> e ii>iI~i'See lhasa~
VNamPik". II: I.'llOm > 8('3)<~CIjmell>tstjon tt (iv:-);; ))c)teel Ih;!t the r4)e.=-;5.;1!))!I)ti(it')~ (i', ()5!c.;ii()n
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! tt"-.B'(';; I)1;i)j1! 'I'l)(.%'4",)))ill')Ii))ng are therefore cc)n.':i.,tet@ v~! (i~ the
(.'-.~l;.) hl (~h;-c) 'N'l<l<
review plactlce of 1cqulrlng I!c'.(
l l(. c'-.<' (;!'((,)li!i' i )1
- (ny and all spurious actuations or I';!iiL(r';" weber< ~io tvvo such spurio<ts actuations or failures occur si.mvl~t3meouskq'.-""
[ I::(()~'~l~:>" 1 h,c]cled]
S1 OPS DATE DOCT PROCEDURE DOCN 1-EOP-99 SYS COMP COMPLETED ITM 22 FLORIDA POWER & LIGHT ST. LUCIE PLANT UNIT NO. 1 1-EOP-99, REVISION 22 APPENDIXES/FIGURES/TABLES EMERGENCY OPERATING PROCEDURE REVISION 0
REVIEWED BY FRG ON 9/1 9/89 10/22/98 APPROVED BY G. J. Boiss Plant General Manager R. G. West Plant General Manager DATE 9/1 9/89 10/22/98 Responsible OPERATIONS Department:
TJB 11/5/98
REVISION NO.:
22 PROCEDURE NO.:
1-EOP-99 PROCEDURE TITLE:
APPENDIXES/FIGURES/TABLES EMERGENCY OPERATING PROCEDURE ST. LUCIE UNIT 1 PAGE:
2 of 120 1.0
2.0 TITLE
APPENDIXESIFIGURESITABLES PURPOSE:
This addendum contains the Appendixes, Figures, and Tables required to be used in conjunction with the Unit 1 Emergency Operating Procedures.
The following items are included:
APPENDIXES B
Alternate DC Power Supply C
Diesel Generator Local Start D
Power Restoration Loss of Offsite Power E
Power Restoration Station Blackout F
Alternate Method of Crosstying U-2 Diesel or S/U Xfmrto U-1 FIGURES 1
RCS Press. Temp.
2 Sl Flow Vs. RCS Press.
3 Time Until S/D Cooling Req.
Vs. Cond. AvaiL 4 Cond. Required for Cooldown 5
RWT Level Vs. Cntmt. Sump Level TABLES 1
RAS 5 MSIS Local Operation of the 'O'uxiliary Feedwater Pump H
Operation of the 1A & 1B Inst. Air Comp ressors I
MSIV Local Closure J
Restoration of Component Cooling Water to RCPs K
RCS Fill & Drain Method of Void.
Elimination L
Placing H, Analyzer in Service M Operation of the H Recombiners N
H Purge System Operation 0
Hot & Cold Leg Injection P
Restoration of Components Actuated by SIAS and CIAS Q
Restoration of Electrical Equipment Room Ventilation R
Steam Generator Isolation S
Safety Injection Throttling and Restoration T
Alternate Charging Flow Path to RCS Through Aux. HPSI Header U
Local Operation of Unit 1 ADVs V SBO Ciosstie from Unit 2 to Unit 1 W Supplying Unit 2 With AC Power Using SBO Crosstie X
NPO Secondary Plant Post Trip Actions N/A N/A N/A N/A N/A N/A N/A N/A 6 Vital Power Breaker Configuration (LOOP) 7 Vital Power Breaker Configuration (SBO) 8 Emerg. Diesel Gen.
Loading (LOOP) 9 125 VDC Equip. Which May Be Deenergized to Extend Battery Life 10 Non-essential MCC Loads 11 Emerg. Diesel Generator Loading (SBO)
N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
REVISION NO.:
22 PROCEDURE NO.:
1-EOP-99 PROCEDURE TITLE:
APPENDIXES/FIGURES/TABLES EMERGENCY OPERATING PROCEDURE ST. LUCIE UNIT 1 PAGE:
67 of 120 APPENDIX Q RESTORATION OF ELECTRICAL EQUIPMENT ROOM VENTILATION (Page 1 of 1)
The following instructions provide guidance for the restoration of forced ventilation to the Reactor Auxiliary Building Electrical Equipment Rooms, following a Loss of Offsite Power (LOOP). This lineup addresses diesel generator fuel conservation and ensures that electrical equipment room temperatures remain within the designed range.
1.
If the diesel generators are supplying power to the vital buses, Then stop HVA-4, "Cable Spreading Room Air Conditioning" by opening breakers 1-41341 and 1-41349 on 1A6 MCC.
2.
If a Loss of Offsite Power (LOOP) has occurred, Then ensure the following
~
ventilation equipment is operating:
A.
Ensure the start switches for "Electrical Equipment Room Supply Fans",
HVS-5A and HVS-5B are in the ON position.
B.
Ensure started or locally start "Exhaust Fans", HVE-11 and HVE-12.
- 1. HVE-11 control push button is located in the cable spreading room near the N.W. exit, alarm door 152.
- 2. HVE-12 control push button is located in the 'B'lectrical Switchgear room near the S.W. exit, alarm door 151.
C.
Ensure started or locally start RV3 and RV4, "Roof Ventilators."
- 1. RV3 and RV4 control push buttons are located-in the 1A Electrical Switchgear room.
(RV3 on north column outside 1A Battery room and RV4 on column south of 1A Battery room.)
D.
Ensure RV1 and RV2, "Roof Ventilators" are operating.
- 1. RV2 control switch is located outside the 1A Battery room.
(On same column as RV3.)
2.
RV1 control switch is located in the 1B Battery room.
END OF APPENDIX Q
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Ng g 'o L
Q D
S 1
OPS DATE DOCT PROCEDURE DOCN 1-EOP-15 SYS COMP COMPLETED ITM 15 FLORIDA POWER & LIGHT ST. LUCIE Pl ANT UNIT NO. 5 1-EOP-<5 REVISION 15 FUNCTIONALRECOVERY FR EMERGENCY OPERATING PROCEDURE REVISION 15 REVIEWED BY FRG ON 9/1 9/89 9/28/98 APPROVED BY G. J. Boiss Plant General Manager R. G. West Plant General Manager DATE 9/19/89 9/28/98 De artment Responsible HCB 9/28/98
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REVISION No.:
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FuNCTIONAL RECOVERY EMERGENCY OPERATING PROCEDURE ST. LUCIE UNIT 1 PAGE:
7 of 202 INSTRUCTIONS 5.1 FUNCTIONALOVERVIEW (continued)
CONTINGENCY ACTIONS 0+
9.
If ALLsafety function acceptance criteria are satisfied by Success Path 1, Then exit this procedure and go to 1-EOP-02, "Reactor Trip Recovery."
9.
Perform ALLof the following in order:
A.
If any safety function acceptance criteria are NOT met, Then implement the recovery action steps for the success paths most
'ikely to meet that safety function.
B.
Implement the recovery action steps for all success paths in service which are NOT met by Success Path 1 in the order of Chart 3, "Functional Recovery Success Paths."
C.
Implement the recovery action steps for all success paths in service which are met by Success Path 1.
D.
Implement Long Term Action steps, Section 5.10.
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8 of 202 INSTRUCTIONS 5.1 FUNCTIONALOVERVIEW (continued)
CONTiNGENCY ACTIONS INDEX OF RECOVERY ACTION SECTIONS REACTIVITYCONTROL MAINTENANCEOF VITALAUXILIARIES RCS INVENTORYCONTROL RCS PRESSURE CONTROL RCS AND CORE HEAT REMOVAL CONTAINMENTISOLATION CONTAINMENTTEMPERATURE AND PRESSURE CONTROL CONTAINMENTCOMBUSTIBLE GAS CONTROL LONG TERM ACTIONS RECOVERY ACTION SECTION 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 END OF SECTION 5.1 FUNCTIONALOVERVIEW
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23 of 202 5.4 RCS INVENTORYCONTROL Success Path 1: Charging 8 Letdown INSTRUCTIONS 0
1.
Verifycharging and letdown are operating automatically to maintain or restore pressurizer
=
level 28% to 35%.
CONTINGENCY ACTIONS 1.
If pressurizer level is NOT being maintained, Then manually operate charging and letdown to maintain or restore pressurizer level 28% to 35%.
C~l 2.
Verify adequate suction sources exist to the charging pumps.
2.
Replenish sources or transfer charging pump suction to RWT as follows:
A.
Place control switch for V2504, "Refueling Water to Charging Pumps" to OPEN, and hold'open.
B.
Place control switch for V2501, "VCT Discharge Valve" to CLOSE, and hold closed.
C.
Locally (1B5 MCC) OPEN breaker 1-42018 (V2501),
"VCT Discharge Valve."
D.
Locally (1B5 MCC) OPEN breaker 1-42017 (V2504),
"Refueling Water to Charging Pumps."
E.
Release V2501 and V2504, control switches.
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24.of 202 5.4 RCS 'INVENTORYCONTROL (continued)
Success Path 1: Charging & Letdown INSTRUCTIONS CONTINGENCY ACTIONS 0
3.
If high pressurizer level condition appears to be caused by voiding, Then refer to Section 5.6, "RCS and Core Heat Removal" Success Path 2, "Natural Circulation With No SIAS", (Step 32) for void elimination.
CAUTION It may be necessary to take the pressurizer solid to maintain 20'F subcooling.
Actions to maintain subcooling take precedence over maintaining pressurizer level.
CI 4.
Verify RCS inventorycontrolby:
A. Pressurizer level 10% to 70% and being restored by charging and letdown to 28% to 35%
AND B. RCS greater than or equal to 20'F subcooled (during natural circulation use Representative CET, page 213, or during forced circulation use T-hot, page 211, QSPDS.)
AND (Continued on Next Page)
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25 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 1: Charging 8 Letdown INSTRUCTIONS CONTINGENCY ACTIONS 4.
(continued)
C. Reactor vessel level indicates core covered (sensors 7 and 8 covered, page 212, QSPDS).
Q 5.
If "RCS Inventory Control" is satisfied, Then go to the next safety function in jeopardy.
5.
If "RCS Inventory Control" is NOT satisfied, Then go to Success Path 2, "SIAS and Charging Pumps."
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26 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS 2
1.
If pressurizer pressure is less than 1600 psia or containment pressure greater than 5.0 psig, Then verify SIAS is actuated.
Q+
2.
Ensure maximum safety injection and charging flow to the RCS by:
A. Safety injection flow per Figure 2, "Safety Injection Flow vs. RCS Pressure."
1.
If SIAS does NOT occur automatically, Then manually initiate SIAS.
2.
If safety injection flow is NOT per Figure 2, "Safety Injection Flow vs. RCS Pressure", Then verify SIAS per Table 1, "Safety Injection Actuation Signal."
AND B. All available charging pumps operating.
C~3 3.
If safety injection flow is inadequate due to high RCS pressure or unavailability of HPSI pumps, Then attempt to cooldown and depressurize to obtain adequate safety injection flow.
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27 of 202 5.4 RCS INVENTORY CONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS O~
4.
Ifpressurizerpressure decreases to less than 1300 psia following SIAS, Then:
A. If RCS subcooling is less than 20'F (T-hot page 211, QSPDS), Then:
- 1. Ensure all 4 RCPs are tripped.
- 2. Initiate seal injection to the RCPs if available:
4.
If pressurizer pressure is NOT less than 1300 psia, Then RCP operation may continue provided CCW flow has NOT been lost for greater than 10 minutes.
a.
Ensure charging flow is available.
- b. OPEN MV-02-1, "RCP Seal Injection Isolation."
OR B. If RCS subcooling is greater than or equal to 20'F (T-hot page 211, QSPDS), Then:
- 1. Ensure 1 RCP in each loop is tripped.
- 2. Initiate seal injection to the RCPs if available:
a.
Ensure charging flow is available.
(Continued on Next Page)
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2B of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS 4.
(continued)
B. (continued)
- 2. (continued)
- b. OPEN MV-02-1, "RCP Seal Injection Isolation."
4.
CONTINGENCY ACTIONS
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29 of 202 5A RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS 5.
Verify RCP operating limits are satisfied by the following:
A. Pump seal requirements of Figure 1, "RCS Pressure Temperature" curve.
B. Guide bearing temperatures less than 185'F.
C. Thrust bearing temperatures less than 200'F.
D. Controlled bleedoff temperature less than 225'F.
5:
If RCP operating limits are NOT satisfied, Then perform the following as appropriate:
A.
If below pump seal requirements of Figure 1, "RCS Pressure Temperature", Then monitor RCP instrumentation for cavitation or seal failure.
B.
If guide bearing temperatures exceed 185'F, Then trip the affected RCPs.
C.
If thrust bearing temperatures exceed 200'F, Then trip the affected RCPs.
D.
If controlled bleedoff temperature exceeds 225'F, Then trip the affected RCPs.
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30 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS 0+
6.
If the HPSI pumps are operating, Then determine if all the following throttling criteria are met:
CONTINGENCY ACTIONS A. Representative CET temperature indicates at least 20'F subcooling.
B. Pressurizer level is greater than or equal to 30% and NOT decreasing.
C. At least one S/G is greater than or equal to 15% (wide range) level with feedwater available for removing heat.
D. The reactor vessel level indicates hot leg covered (sensors 4 through 8 covered, page 212, QSPDS).
E. HPSI pumps are NOT being used to satisfy "Reactivity Control" Success Path 4.
7.
If HPSI throttling criteria are met, Then pumps may be throttled or stopped per Appendix S, "Safety Injection Throttling and Restoration."
7.
If HPSI throttling criteria can NOT be maintained, Then reinitiate HPSI flow per Appendix S, "Safety Injection Throttling and Restoration."
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31 of 202 5 4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps tNSTRUCTIONS CONTINGENCY ACTlONS 0+
8.
If the following criteria are met:
A. RCS pressure greater than 200 psia and controlled.
B. HPSI throttling criteria met.
Then the LPSI pumps may be stopped as follows:
HCV-3615 HCV-3625 HCV-3635 HCV-3645 8.
If LPSI termination criteria can NOT be maintained and RAS has NOT occurred, Then restart LPSI pumps and OPEN header isolation valves.
- 2. Stop 1A and 1B LPSI Pumps.
- 3. Return 1A and 1B LPSI Pump control switches to AUTO.
9.
Verify proper transfer of water from RWT to containment sump per Figure 6, "RWT Level vs.
Containment Sump Level."
9.
If RWT level versus containment sump level relationship is NOT satisfied, Then leakage outside the containment may exist.
Perform the following:
A.
Verify CIAS per Table 2, "Containment Isolation Actuation Signal."
B.
Verify no unexplained RAB radiation monitors in alarm.
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32 of 202 5.4 RCS INVENTORYCONTRO (continued Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS C+l 10, When RWT level ls less than or equal to 8 test, and at least one containment spray pump is running, Then:
A. Verifythe same train HPSI pump(s) running.
B. OPEN the valves listed below for the running Containment Spray pump(s) to provide cool water from the SDC heat exchanger(s) to the corresponding running HPSI pump(s) during recirculation:
- 1. V3663, nSDC Heat Exchanger 'A'o 1A HPSI Pump."
9.
(continued)
C.
Verify no unexplained RAB sump level alarms (Annunciators R-4, R-14, S-20, S-30).
D.
Replenish the RWT as necessary to maintain level greater than 4 feet, from sources identified by the Technical Support Center.
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33 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS 11.
When refueling water tank is 6-8 feet, Then:
A. Ensure power available to V3659 and V3660, "Min.
Flow Isolation Valves."
B. Ensure HVE-10A and HVE-108, "RAB Main Exhaust Fans," are stopped.
0 12.
When RWT level is less than 4 feet, Then verify RAS has
- actuated, 12.
If RAS does NOT occur automatically, Then:
A.
Manually initiate RAS.
B.
Verify RAS per Table 4, "Recirculation Actuation Signal ~"
CAUTION HPSI pump flow rate should be limited to less than 640 gpm per pump during operation after RAS.
13.
When RAS is complete, Then:
A. Verify V3659 and V3660, "Min. Flow Isolation Valves" are CLOSED, Then deenergize the valves.
13.
If the operating HPSI pumps are delivering less than 114 gpm per pump, Then:
A.
Stop one charging pump at a time until minimum flow requirements are met.
(Continued on Next Page)
(Continued on Next Page)
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34 of 202 5.4 RCS INVENTORYCONTROL (continued)
INSTRUCTIONS Success Path 2: SIAS and Charging Pumps CONTINGENCY ACTIONS 13.
(continued)
B. Verify operating HPSI pumps are delivering greater than or equal to 114 gpm per pump after RAS.
13.
(continued)
B.
If minimum HPSI flow requirements are still NOT met with all charging pumps off, Then stop the HPSI pump with the lowest indicated flow.
NOTE ECCS area sump pumps are only available when non-vital MCCs (1A2/1 B2) are energized.
14.
After RAS, pump ECCS leakage and RCS sample water collected in the ECCS area sumps to the reactor drain tank by performing the following:
A. At the CRAG panel, place ECCS Area Leakage System control switch to the RDT position and verify that:
- 1. HCV-06-9, "RDT Pump Suction" closes.
- 2. HCV-06-7, "Sump Pump to EDT" closes.
- 3. HCV-06-8, "Sump Pump to RDT" opens.
(Continued on Next Page)
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35 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRuCTIONS 14.
(continued)
B. At RTGB 105, OPEN V6301 and V6302, "RDT Containment Isolation Valves" by placing the switches to RESET, Then OPEN.
CONTINGENCY ACTIONS C. Ensure the CRAG panel annunciator, Annunciator Y-19, "ECCS Pump Room Leakage Valves Misaligned" is lit.
Cl 15.
Verify "RCS Inventory Control" is being satisfied by the following criteria:
A. Reactor vessel level indicates core is covered.
(Sensors 7 and 8 covered, page 212, QSPDS.)
AND A.
B.
Continue actions to establish inventory control while pursuing other safety functions in jeopardy, Contact the Technical Support Center to evaluate implementation of the Severe Accident Management Guidelines (SAMGs).
15.
If "RCS Inventory Control" is NOT satisfied, Then:
/R15 (Continued on Next Page)
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36 of 202 5.4 RCS INVENTORYCONTROL (continued)
Success Path 2: SIAS and Charging Pumps INSTRUCTIONS CONTINGENCY ACTIONS 15.
(continued)
B. One of the following conditions exists:
15.
- 1. All available charging pumps are operating and safety injection pumps are injecting water into the RCS per Figure 2, "Safety Injection Flow vs.
RCS Pressure."
- 2. Safety injection pumps throttling criteria has been satisfied.
16.
If "RCS Inventory Control" is satisfied, Then go to next safety function in jeopardy.
END OF SECTION 5.4 RCS INVENTORY CONTROL
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