ML20127K992
| ML20127K992 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/22/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127K977 | List: |
| References | |
| 50-335-85-06, 50-335-85-6, 50-389-85-06, 50-389-85-6, EA-85-050, EA-85-50, NUDOCS 8506270697 | |
| Download: ML20127K992 (2) | |
See also: IR 05000225/2003001
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Florida Power and Light Company
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Docket No. 50-389
St. Lucie Unit 2
License No. NPF-16
EA 85-50
During an NRC inspection conducted on February 25 - March 1, 1985, violations of
NRC requirements were identified. The violations involved the failure to comply
with NRC fire protection requirements.
In accordance with the " General Statement
of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1985), the particular violations are set forth below:
1.
Operating License Condition 2.c.13 requires the licensee to implement the fire
protection program on a schedule specified in Section 9.5.1.11(a) and (b)
of Supplement No. 3 to the Safety Evaluation Report (SSER).
Fire Protection
for Safe Shutdown Capability as specified in Section 9.5.1.6.A of this SSER
utilizes the guidelines of Appendix R to 10 CFR Part 50.Section III.G.2.
of Appendix R requires that redundant trains of systems necessary to
achieve and maintain hot shutdown conditions in areas outside of containment
be maintained free from fire damage by providing fire protection features
in accordance with Section III.G.2.a, III.G.2.b, or III.G.2.c.
Contrary to the above, as of February 19, 1985 and without approved deviation
from the required schedule, plant configurations in two areas outside of
containment were not provided with adequate fire protection features
which satisfy the requirements of Appendix R, Sections III.G.2.a, III.G.2.b,
or III.G.2.c to ensure that systems necessary to achieve and maintain hot
shutdown conditions be maintained free from fire damage. Equipment and
cables for the "A" Train are located in the "B" Train switchgear room, and
the "A" Train power cable for 480 volt switchgear 2A5 is routed in the
"B" Train cable loft.
This is a Severity Level III violation (Supplement I).
2.
Technical Specification 6.8.1.f requires the licensee to implement proce-
dures for the Fire Protection Program.
Contrary to the above, as of this inspection, two procedural errors were
identified in Emergency Operating Procedure (E0P) 2-0030144, Revision 3,
Alternate Shutdown, which affect implementation of E0P 2-0030144 as follows:
a.
E0P 2-0030144, step 5.8, NOTES, requires utilizing auxiliary spray
(chemical and volume control system) if the reactor coolant system
is greater than 200 F subcooled, and directs the manual closing of
isolation valve V-2485. This action isolates the "A" Train charging
path and make-up water to the reactor coolant system.
However, this
charging path is relied upon for make-up water as delineated in
Section 5.0, Caution, which states, "If the fire is in the cable
spreading room or control room, control of the reactor and other
reactor components must be done utilizing "A" Train components.
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b.
For a postulated fire in the control room which requires immediate
evacuation with minimal operator action (e.g., reactor trip), the
Pressurizer Power Operated Relief Valves (PORVs) cabling is not
protected to prevent their spurious operation.
E0P 2-0030144 does
not contain steps to isolate the PORVs from outside the control room.
Failure to isolate the PORVs could result in a significant loss in
reactor coolant system inventory and pressure.
This is a Severity Level IV violation (Supplement I).
3.
Operating License Condition 2.c.13 requires the licensee to implement the fire
protection program on a schedule specified in Section 9.5.1.11(a) and (b)
of Supplement No. 3 to the Safety Evaluation Report (SSER). Fire Protection
for Safe Shutdown Capability as specified in Section 9.5.1.6.A of this SSER
utilizes the guidelines of Appendix R to 10 CFR Part 50. Appendix R,
Sections III.L.2 and 3, describes the performance goal requirements for the
alternative shutdown capability and requires that procedures be in effect
to implement this capability.
Contrary to the above, without approved deviation from the required schedule,
E0P 2-0030144, Alternate Shutdown, was not approved for issue and use by
plant personnel until September 26, 1984. The procedure was required to be
implemented by April 1983 to satisfy Appendix R,Section III.L. requirements.
This is a Severity Level IV violation (Supplement I).
Pursuant to 10 CFR 2.201, Florida Power and Light Company is required to submit
to this office within 30 days of the date of this Notice a written statement or
explanation in reply including:
(1) admission or denial of the alleged
violations, (2) the reasons for the violations if admitted, (3) the corrective
steps which have been taken and the results achieved, (4) corrective steps which
will be taken to avoid further violations, and (5) the date when full compliance
will be achieved. Where good cause is shown, consideration will be given to
extending the response.
Date:
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