IR 05000335/2002006
| ML021930434 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/11/2002 |
| From: | Mccree V Division Reactor Projects II |
| To: | Stall J Florida Power & Light Co |
| References | |
| EA-02-033 IR-02-006 | |
| Download: ML021930434 (9) | |
Text
July 11, 2002
SUBJECT:
FINAL SIGNIFICANCE DETERMINATION - NO VIOLATION OF NRC REQUIREMENTS AND NO INSPECTION FINDING (NRC INSPECTION REPORT NO.: 50-335/02-06, ST. LUCIE UNIT 1 NUCLEAR PLANT)
Dear Mr. Stall:
The purpose of this letter is to provide you with the final results of our significance determination for the preliminary White finding identified in NRC Inspection Report 50-335/02-06. The inspection finding was assessed under the significance determination process and was preliminarily characterized as White, i.e., an issue of low to moderate safety significance, which may require additional NRC inspection. The finding involved a failure to have an installed fixed fire suppression system in an Alternative Shutdown Area that was adequate to extinguish fires which may occur in the area. This issue was also preliminarily considered to be an apparent violation of Section III.G.3 of 10 CFR Part 50, Appendix R requirements.
At Florida Power & Light Companys (FPL) request, an open regulatory conference was conducted with members of your staff on June 20, 2002, to discuss FPLs position on this issue.
The enclosures to this letter include the list of attendees at the regulatory conference, and copies of the material presented by FPL and the agenda for the meeting presented by the NRC at the conference. During the conference, you presented your assessment results and disagreed with the NRCs estimate that the finding resulted in an incremental increase in core damage frequency of approximately 4.9x10-6/year. You also disagreed with the NRCs characterization of the finding as an apparent violation of regulatory requirements.
After considering the information presented at the regulatory conference, the NRC has concluded that the preliminary characterization of this issue as a White finding and as an apparent violation, as described in the inspection report, is not valid. In your presentation, you provided information that supported your position that the halon system concentration was consistent with the plants Final Safety Analysis Report (FSAR), as required by your licensing bases. We have concluded that the St. Lucie Unit 1 cable spreading room halon system meets the licensing basis as described in your FSAR. Additionally, in this case, because the performance deficiency entered into the Significance Determination Process was based on noncompliance with regulatory requirements, the performance deficiency is negated. These conclusions supercede the NRC responses to Task Interface Agreements 1999-01 and 2000-04 with respect to the halon system and compliance with regulatory requirements.
Florida Power and Light Company
However, the NRC has not developed a final position on the differing assumptions you presented during the conference and in your June 26, 2002, submittal regarding the Consolidated Model of Fire Growth and Smoke Transport (CFAST) modeling, fire risk analysis and grouped electrical cables fire hazard analysis. These issues will be examined further as part of an ongoing NRC review of fire safety issues. The underlying safety issues will be evaluated in accordance with our backfit provisions as described in 10 CFR 50.109.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosures, will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
Should you have any questions regarding this letter, please contact me or Leonard Wert, Chief, Reactor Projects Branch 3, Division of Reactor Projects, at 404-562-4540.
Sincerely,
//RA//
Victor M. McCree, Deputy Director Division of Reactor Projects Docket No. 50-335 License No. DPR-67 Enclosures: 1. List of Attendees 2. Material presented by NRC 3. Material presented by FPL cc w/encls: (See Page 3)
Florida Power and Light Company
cc w/encls:
D. E. Jernigan Site Vice President St. Lucie Nuclear Plant Florida Power & Light Company Electronic Mail Distribution R. E. Rose Plant General Manager St. Lucie Nuclear Plant Electronic Mail Distribution J. T. Voorhees Acting Licensing Manager St. Lucie Nuclear Plant Electronic Mail Distribution Don Mothena, Manager Nuclear Plant Support Services Florida Power & Light Company Electronic Mail Distribution Mark Dryden Administrative Support & Special Projects Florida Power & Light Company Electronic Mail Distribution Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company Electronic Mail Distribution M. S. Ross, Attorney Florida Power & Light Company Electronic Mail Distribution William A. Passetti Bureau of Radiation Control Department of Health Electronic Mail Distribution Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs Electronic Mail Distribution cc w/encls: (Contd See Page 4)
Florida Power and Light Company
cc w/encls: (Contd)
J. Kammel Radiological Emergency Planning Administrator Department of Public Safety Electronic Mail Distribution Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Ft. Pierce, FL 34982
Distribution w/encls:
W. Travers, EDO W. Kane, DEDRP S. Collins, NRR W. Borchardt, NRR L. Chandler, OGC D. Dambly, OGC E. Julian, SECY B. Keeling, OCA Enforcement Coordinators RI, RIII, RIV E. Hayden, OPA G. Caputo, OI H. Bell, OIG W. Dean, NRR M. Johnson, NRR L. Dudes, NRR B. Moroney, NRR S. Rosenberg, OEDO F. Congel, OE C. Christensen, RII L. Plisco, RII W. Rogers, RII L. Wert, RII S. Sparks, RII T. Ross, RII C. Evans, RII S. Ninh, RII R. Hannah, RII K. Clark, RII PUBLIC OEMAIL OEWEB VIA E-MAIL VIA E-MAIL OFFICE RII:DRP RII:EICS NRR:DSSA NRR OE NRR SIGNATURE VMM CFE VIA E-MAIL VIA E-MAIL DNELSON FOR N/A NAME VMCCREE CEVANS SBLACK MJOHNSON FCONGEL LDUDES DATE 7/11/02 7/2/02 7/8/02 7/9/02 7/9/02 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:
LIST OF ATTENDEES AT THE REGULATORY CONFERENCE NUCLEAR REGULATORY COMMISSION:
S. Collins, Director, Nuclear Reactor Regulation (NRR)
J. Johnson, Deputy Director, NRR L. Reyes, Regional Administrator, Region II (RII)
V. McCree, Deputy Director, Division of Reactor Projects (DRP), RII L. Wert, Chief, Branch 3, DRP, RII T. Ross, Senior Resident Inspector, St. Lucie Nuclear Plant, RII C. Evans, Enforcement Officer, RII S. Ninh, Senior Project Engineer, DRP, RII (via videoconference)
C. Ogle, Acting Deputy Director, Division of Reactor Safety (DRS), RII (via videoconference)
W. Rogers, Senior Reactor Analyst, Division of Reactor Safety, (DRS), RII (via videoconference)
S. Sparks, Senior Enforcement Specialist, RII (via videoconference)
C. Payne, Acting Chief, Engineering Branch 1, DRS, RII (via videoconference)
G. Longo, Attorney, Office of General Counsel (OGC)
D. Nelson, Senior Enforcement Specialist, Office of Enforcement H. Berkow, Director, Project Directorate (LPD) II, Division of Licensing Project Management (DLPM), NRR S. Black, Deputy Director, Division of Systems Safety and Analysis (DSSA), NRR M. Johnson, Chief, Probabilistic Safety Assessment (SPSB), DSSA, NRR C. Carpenter, Chief, Inspection Program Branch (IIPB), Division of Inspection Program Management (DIPM), NRR B. Moroney, Project Manager, LPD II-2, DLPM, NRR E. Weiss, Chief, Fire Protection Section, Plant Systems Branch (SPLB), DSSA, NRR M. Sally, Senior Fire Protection Engineer, SPLB, DSSA, NRR S. M. Wong, Senior Reactor Analyst, SPSB, DSSA, NRR M. Yoder, Nuclear Safety Intern, SPLB, DSSA, NRR T. Tate, Project Manager, LPD I-2, DLPM, NRR R. Ennis, Senior Project Manager, DLPM, NRR C. Gratton, Senior Project Manager, LPD I-2, DLPM, NRR P. Wilson, Senior Reactor Analyst, SPSB, DSSA, NRR D. Merzke, Reactor Operations Engineer, IIPB, DLPM, NRR D. Starkey, Project Manager, LPD I-2, DLPM, NRR S. Monarque, Project Manager, LPD II, DLPM, NRR G. Shukla, Project Manager, LPD IV-2, DLPM, NRR B. Benney, Project Manager, LPD IV-2, DLPM, NRR I. Jung, Reactor Systems Engineer, Operating Reactor Improvements (RORP), Division of Regulatory Improvement Program (DRIP), NRR P. Koltay, Senior Operations Engineer,IIPB, DIPM, NRR L. Dudes, Technical Assistant (Enforcement), DIPM, NRR J. Hyslop, Senior Reactor Analyst, Probabilistic Risk Analysis Branch (PRAB), Office of Nuclear Reactor Research (RES)
Enclosure 1
E. Brown, Project Manger, LPD II-2, DLPM, NRR K. Jabbour, Senior Project Manager, LPD II-2, DLPM, NRR T. Bellarmine, Summer Intern, Division of Engineer (DE), NRR T. Eaton, Fire Protection Engineer, SPLB, DSSA, NRR M. Kotzalas, Senior Communication Analyst, Program Management, Policy Development and Planning Staff (PMAS), NRR D. Frumkin, Fire Protection Engineer, SPLB, DSSA, NRR G. Parry, Senior Level Technical Advisor, SPSB, DSSA, NRR A. Jones, Health Physicist, Division of Systems Analysis and Regulatory Effectiveness, RES FLORIDA POWER AND LIGHT COMPANY (FPL) AND CONSULTANTS:
J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer *
R. Kundalkar, Vice President, Engineering D. Jernigan, Vice President, St. Lucie Plant M. Ross, Legal Counsel C. Guey, Manager, Reliability and Risk Engineering Group T. Patterson, Operations Manager P. Barnes, Supervisor, Fire Protection Engineering J. Hoffman, Project Engineer B. McDaniels, Fire Protection Engineer P. Dinenno, Hughes Associates T. Wysocki, Guardian Services J. Lambright, Lambright Associates PUBLIC CITIZENS:
M. Cooper, Entergy-ANO J. Weil, McGraw-Hill D. Ralph, Scientech
OPEN REGULATORY CONFERENCE ST. LUCIE NUCLEAR POWER PLANT 1:00 P.M.
JUNE 20, 2002 THE TWFN BUILDING AUDITORIUM ROCKVILLE, MD I.
OPENING REMARKS, INTRODUCTIONS AND MEETING INTENT L. Reyes, Regional Administrator, Region II II.
NRC REGULATORY CONFERENCE POLICY V. McCree, Deputy Director, Division of Reactor Projects, Region II III.
STATEMENT OF THE ISSUE WITH RISK PERSPECTIVES V. McCree, Deputy Director, Division of Reactor Projects, Region II IV.
SUMMARY OF APPARENT VIOLATION V. McCree, Deputy Director, Division of Reactor Projects, Region II V.
LICENSEE RISK PERSPECTIVE PRESENTATION VI.
LICENSEE RESPONSE TO APPARENT VIOLATION VII.
BREAK / NRC CAUCUS L. Reyes, Regional Administrator, Region II VIII.
CLOSING REMARKS L. Reyes, Regional Administrator, Region II Enclosure 2
Draft Apparent Violation Note: The apparent violation discussed at this Regulatory Conference is subject to further review and subject to change prior to any resulting enforcement action.
10 CFR 50.48(a)(1)(i) requires that each operating nuclear power plant have a fire protection plan that satisfies Criterion 3 of Appendix A to Part 50.
Criterion 3 of Appendix A to Part 50 states that fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety.
10 CFR 50.48(b) provides that Appendix R to Part 50 establishes fire protection features required to satisfy Criterion 3.
Section III.G.3 of 10 CFR Part 50, Appendix R, requires that fire areas which require Alternative Shutdown have fire detection and a fixed fire suppression system installed in the area.
Contrary to the above, the licensee does not have an installed fixed fire suppression system in an Alternative Shutdown Area. The licensees Cable Spreading Room (CSR)
is designated as an area requiring Alternative Shutdown capability. In 1986, the licensee installed a Halon 1301 fire protection suppression system in the CSR. In order to suppress a fire for special hazards such as a Halon fire suppression system, it must be capable of extinguishing a fire. The licensees Halon 1301 system is designed to achieve a minimum 5-7% halon concentration and minimum soak time of 10 minutes, while a minimum 10% halon concentration and minimum soak time of 10 minutes is necessary to extinguish a fire in a CSR.