ML18065A668

LER 96-007-00:on 960321,inadequate Emergency Lighting & Ventilation in post-fire Safe Shutdown Areas.Caused by App R Program Documentation Insufficient to Demonstrate Regulatory Compliance.Lighting modified.W/960422 Ltr

ML18065A668
Person / Time
Site:	Palisades
Issue date:	04/22/1996
From:	Engle D, Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-007, LER-96-7, NUDOCS 9604300133
Download: ML18065A668 (8)

Text

consumers Power POWERING MICHIGAN'S PROGRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 22, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT LICENSEE EVENT REPORT 96-007 -APPENDIX R, INADEQUATE EMERGENCY LIGHTING AND VENTILATION IN POST-FIRE SAFE SHUTDOWN AREAS Licensee Event Report (LER)96-007 is attached. This event is reportable to the NRC in accordance with 10CFR50.73(a)(2)(ii)(B) as a condition outside the plant design basis.

SUMMARY

OF COMMITMENTS This letter contains four new commitments as follows: .

1. Modify or install emergency lighting units in the 12 safe shutdown equipment locations which are referred to in this report as not meeting the requirements of Section Ill. J of Appendix R.

2. Design and install a nitrogen back-up and manual operation capability to valve CV-3018 to allow local manual control for High Pressure Safety Injection (HPSI) injection into the Primary Coolant System (PCS) from outside the Containment Building.

9604300133 960422 PDR ADOCK 05000255 S PDR A CMS' ENERGY COMPANY

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3. Modify the Appendix R analysis to add additional components and their associated circuits to the safe shutdown equipment list to support the use of CV-3018, when the modification to CV-3018 is implemented.

4. Modify procedural controls to specify the use of existing portable fans in the.

event a fire causes a loss of ventilation in the Control Room or Cable Spreading Room.

Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades

,Attachment

ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 LICENSEE EVENT REPORT 96-007 APPENDIX R ENHANCEMENT -

INADEQUATE EMERGENCY LIGHTING AND VENTILATION IN POST-FIRE SAFE SHUTDOWN AREAS

NRCFORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150--0104 (4195) . EXPIRES 4/30/98 ESTIMATCD IU!DEN PER RESPONSE TO COMPLY Willi nilS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED LICENSEE EVENT REPORT (LER) INTO niE LICENSING PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO niE INFORMATION AND RECORDS MANAGEMENT BRANCH (T-8 F33). U.S. lf.JCLE.AR REGULATORY COMMISSION, WASHINGTON, DC 2055~

0001, AND TO niE PAPERWORK REDUCTION PROJECT (31~104, OFFICE OF (See reverse for required number of digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON; DC 20503 TITLE(4) LICENSEE EVENT REPORT 96-007, INADEQUATE EMERGENCY LIGHTING AND VENTILATION IN POST-FIRE SAFE SHUTDOWN AREAS - APPENDIX R EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL N!JMBER REVISION NUMBER MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 FACILITY NAME DOCKET NUMBER 03 21 96 96 007 04 22 96 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check one or more) (11)

N MODE (9)

I I 20.2201 (b) 20.2203(a)(2)(v)

X 50.73(a)(2)(1) 50.73(a)(2)(iii)

I POWER 20.22Cl3(a)(1) 20.2203(a)(3)(1) 50.73(a)(2)(ii) 50.73(a)(2)(x)

• LEVEL (1 O) 100 t--~2,.,,.0.":"22=-:0,.,,.3(::-a~)(2=:-)(~l)--+--+":"20"".22=03::--:("":"a)~(3~)(i,.,..i)--......--+-5=-:0,..,,.7""'3(::-a~)(2=:-)(""'iii::-)---+---t-,7~3""'.7,.,..1- - - - - t i LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Dale E Engle, Licensing Engineer (616) 764-8913 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER *REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR I YES If ves, COMPLETE EXPECTED COMPLETION DATE x I NO EXPECTED SUBMISSION DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On March 21, 1996, at 0800 am, with the plant operating at 100% power, two areas of noncompliance with 10CFRSO, Appendix R requirements were identified. They were identified by the Palisades Appendix R Enhancement Program. The first noncompliance was identified during plant walkdowns to verify adequate emergency lighting for post-fire safe shutdown actions.

Twelve locations were identified where the existing emergency lighting was rated inadequate:.

Existing. plant procedures do reqJire Operations personnel t6 carry hand-held flashlights when leaving the Control Room area during post-fire safe shutdown activities. This instruction serves as a suitable compensatory measure until emergency lighting equipment can be modified_ The second noncompliance was identified during performance of a calculation to determine if the loss

-of ventilation in post-fire safe shutdown areas would result in excessive temperatures during a fire related plant shutdown. The Control Room and Cable Spreading Rqom were determined to need ventilation to prevent excessive temperatures. The use of portable fans was found to be acceptable. However, plant procedures do not instruct personnel to use the existing portable fans for cooling the two areas. Operations personnel have been instructed to utilize the existing portable fans for cooling the Control Room and Cable Spreading Room if ventilation is lost These instructions serve as a suitable compensatory measure until plant procedures can be revised to incorporate the additional instructions.

NRC FORM 366a 4195 ,

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION I

FACILITY NAME 11 \ DOCKETl2\ LER NUMBER 16\ PAGE 13\

YEAR SEQUENTIAL REVISION NUMBER NUMBER PALISADES NUCLEAR PLANT 05000255 2 OF 5 96 - 007 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On March 21, 1996, at 0800 am, with the plant operating at 100% power, two separate areas of noncompliance with 10CFR50, Appendix R requirements were identified. Th~y were identified by the Appendix R Enhancement Program. The first noncompliance was identified during plant

• walkdowns to verify adequate emergency lighting for post-fire safe shutdown actions. The walkdown identified 12Jocationswhere ex).;.Lng emergency lighting was inadequate._. Existing-plant procedures require Operations personnel to carry hand-held flashlights when leaving the Control Room area during po~t-fire safe shutdown activities. This instruction serves as a suitabl~

compensatory measure until plant modifications can be made to the emergency lighting equipment.

The second noncompliance was identified during completion of support calculations to determine if the loss of ventilation in post-fire safe shutdown areas would result in excessive temperatures during a fire related plant shutdown. Two areas, the Control Room and Cable Spreading Room, were determined to require temporary ventilation to prevent excessive temperatures; and, the use of portable fans was found to be acceptable. However, the current plant procedures for post-fire safe shutdown do not instruct plant personnel to use the existing portable fans for coo.ling the two  !

areas.

Instructions have been provided to Operations personnel to utilize existing portable faris for cooling the Cable Spreadi,ng Room and Control Room if normal/emergency ventilation is lost i during a fire, within approximately six (6) hours and fifteen (15) hours respectively, after loss of the ventilation. These instructions serve as a suitable compensatory measure until plant procedures can be revised to incorporate the additional instructions.

ANALYSIS OF THE EVENT The ongoing Appendix R Enhancement Program is systematically performing a complete redevelopment of documentation needed to support compliance with 10CFR50, Appendix R. It was this Appendix R Enhancement Program that identified these conditions.

1. The original Appendix R program lacked guidance on certain specific operator actions and their locations such that it was unclear where emergency lighting was specifically needed.

The emergency lighting deficiencies consist of 12 areas that require plant changes and are the basis for reporting this condition as outside the plant design basis .. The categories of deficiencies are as follows:

NRC FORM 366a 4195

• LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION I

FACILITY NAME 11 \ DOCKETl2\ LER NUMBER 16\ PAGE 13\

YEAR SEQUENTIAL REVISION NUMBER NUMBER PALISADES NUCLEAR PLANT 05000255 3 OF 5 96 007 00 TEXT (If more space is required, use additional copi~s of NRC Form 366A) (17) 7 Items Adding a third headlamp to existing units to improve existing illumination at the target.

3 Items Adding a new emergency lighting unit for better access/egress and target illumination.

1 Item Lowering an existing ef'!lergency lighting unit to avoid _obstructions in.the lighting path to the intended target.

1 Item Adding emergency lighting inside containment for manual operation of M0-3007 to ensure an open safety injection flowpath to the Primary Coolant System; or, to accomplish the same objective, modify the post-fire safe shutdown methodology and modify plant equipment to allow post-fire operation of valve CV-3018 located outside of containment using a different flow path. The environmental considerations inside containment make the use of battery powered lighting undesirable due to maintenance concerns, so the preferred alternative is to modify CV-3018 and allow actions outside containment. * -

The existing post-fire safe shutdown procedure requires operators t_o take hand-held flashlights upon leaving the Control Room to perform operator actions outside this area. This procedural guidance provides adequate compensatory measures until the above plant changes are completed.

2. Previous assessment of the adequacy of room temperatures upon loss of normal/emergency ventilation was inadequate. The calculations prepared to support the Appendix R Enhancement Program were responsible for identifying the need for additional ventilation in the Control Room and Cable Spreading Room. Additional efforts were undertaken to determine if existing plant procedures addressed the use of the existing portable ventilation fans, and when this was found to be inadequate, the condition was identified and guidance was given to the plant operators.

NRC FORM .366a 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION I

FACILITY NAME 11 l DOCKET12\ LER NUMBER 16\ PAGE (3)

YEAR SEQUENTIAL REVISION NUMBER NUMBER PALISADES NUCLEAR PLANT 05000255 4 OF 5 96 007 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

SAFETY SIGNIFICANCE

1. Inadequate Emergency Lighting The lack of adequate emergency lighting in the areas identified by the plant walkdown has been adequately compensated for by the existing procedural guidance to carry the hand-held

. _ Jlashlights when leaving the Control Room to perform post-fire safe shutdown actions. _

il The use of hand-held flashlights is not adequate to meet regulatory requirements, but is adequate to perform the operator actions. Most of the lighting deficiencies were inadequate illumination, not a complete lack of illumination. There are approximately 100 Appendix R related emergency lighting units at Palisades and only 12 locations required some. correction to meet the licensing basis. The ability to attain post fire safe shutdown within requfred limits

. was minimally impacted in _a small fraction of the areas that could be affected.. In view of this fact, the safety significance of this design deficiency is low.

2. Inadequate Post-Fire Ventilation The lack of procedural guidance to utilize existing portable ventilation fans to ensure proper cooling of the Control Room and Cable Spreading Room if normal/emergency ventilation is lost would not create a concern for approximately six hours after the loss of ventilation occurs. The new calculations.indicate, under worst case conditions, the Cable Spreading ....*,

Room would require portable ventilation to be initiated approximately six hours after the loss of ventilation occurred. The Control Room would not require the use of portable ventilation for approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the loss of ventilation. Therefore, it is reasonable to assume that adequate time* is available to take initial actions to stabilize the plant, bring in additional manpower, and trouble shoot nonproceduraliz.ed items that require attention. The existing portable ventilation fans are used for fire brigade fire protection activities. These activities should be completed within one hour for most realistic fires at Palisades, but in all cases well within six hours. Therefore, the fans and knowledgeable personnel would be available to use the fans to cool any rooms that have lost ventilation and are overheating. Due to the extended time before use of the portable ventilation fans is required, and the availability of equipment and personnel at that time, it is reasonable to assume proper utilization of the portable ventilation fans would have occurred without the guidance being provided in a procedure. Therefore, the safety significance of this procedural inadequacy is low.

NRC FORM 366a 4195 * .

• LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION I

FACILITY NAME 11\ DOCKETl2\ LER NUMBER 161 PAGE 131 YEAR SEQUENTIAL REVISION NUMBER NUMBER PALISADES NUCLEAR PLANT 05000255 5 OF 5 96 007 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

CAUSE OF THE EVENT Appendix R program documentation was insufficient to demonstrate regulatory compliance on its own merit. The original Appendix R review of emergency lighting did not adequately address the specific operator actions needed at each component to accomplish equipment manipulations fo,r:., .

post-fire safe shutdown. The amount of light was found to be insufficient at specific equipment

, .!~_cations to perform the riecessary equipment_mal"!*ipulati<?~S: The_original C§!lculatior:i which; . _

provided the bases for the ventilation requirements did not provide sufficient detail to be consistent with the final conclusions.

CORRECTIVE ACTIONS

1. Modify or install emergency* lighting units in the 12 safe shutdown equipment locations which  ; ,.

are referred to in this report as not meeting the requirements of Section Ill J. of Appendix R.

2. Design and install a nitrogen back-up and manual operation capability to valve CV-3018 to *1 l allow local manual control for HPSI injection .into the PCS from outside the containment .

building. ,

3. Modify the Appendix R analysis to add any added components and their associated circuits i I to the safe shutdowr:i .equipment list to support the use of CV-3018, when the modification to

.CV-3018 is implemented.

4. . Modify procedural controls to specify the use of existing portabl.e fans in the event a fire causes a loss of ventilation in the Control Room or Cable Spreading Room.