L-2010-051, St. Lucie, Units 1 and 2, Response to Request for Additional Information - Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue

St. Lucie, Units 1 and 2, Response to Request for Additional Information - Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue

ML100750658
Person / Time
Site:	Saint Lucie
Issue date:	03/11/2010
From:	Anderson R L Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2010-051
Download: ML100750658 (3)

Text

0 FPL Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 March 11, 2010 L-2010-051 10 CFR 26.9 10 CFR 26.205 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 RE: St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Response to Request for Additional Information

-Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue By letter L-2009-217 dated October 16, 2009, Florida Power and Light Co. (FPL) requested an exemption from certain requirements of the Fitness for Duty Rule for Managing Fatigue.Specifically, the letter requested exemption from certain specified requirements of Part 26 during preparations for severe weather conditions (i.e., tropical storm or hurricane force winds) and the recovery from severe weather conditions.

On February 19, 2010, the NRC issued a request for additional information regarding the exemption request. The attachment to this letter provides the requested information.

If there are any questions regarding this request, please contact Eric Katzman at (772) 467-7734./4-l--Site Vice.0resii St. Lucie Plant Attachment an FPL Group company St. Lucie Units 1 and 2 L-2010-051 Docket Nos. 50-335 and 50-389 Attachment Page 1 of 2 Response to Request for Additional Information Regarding Exemption Request from Certain Requirements of 10 CFR 26 NRC Question 1 The exemption request states that, "Specifically, the letter requests exemption from certain specified requirements of Part 26 during preparations for severe weather conditions." Please indicate if the request is to include any period of time during the recovery phase, after the storm has passed.Response As stated in attachment I of FPL letter L-2009-217, the exemption would apply to severe weather conditions where tropical storm or hurricane force winds are predicted onsite requiring severe weather preparations and the possible sequestering of the St. Lucie storm crew. FPL would not need to meet the requirements of 10 CFR 26.205(c) and (d) from the time that severe weather preparations are commenced.

This exemption would continue through storm crew sequestering until exit conditions are satisfied.

After the storm has passed, it is difficult to predict when relief personnel could return to the site based on the degree of surrounding infrastructure damage caused by the storm and the different locations that personnel chose to evacuate to avoid the storm. Typically, access to the area following storm damage is controlled by local government officials.

The goal is to provide relief as soon as circumstances allow.For purposes of this exemption request, the following proposed definitions will apply: ENTRY CONDITION:

This is the start time when any individual on site who performs duties identified in Parts 26.4(a)(1) through (a)(5) of 10 CFR will not have to meet the requirements of 10 CFR 26.205(c) and (d). This occurs when site preparations are commenced per the severe weather preparation procedure (confirmed tropical storm watch, or confirmed hurricane watch or warning).EXIT CONDITION:

This is the time when St. Lucie must fully comply with the requirements of 10 CFR 26.205(c) and (d) following severe weather involving tropical storm or hurricane force winds. This date and time is determined by the Hurricane Response Coordinator when sufficient personnel who perform duties identified in Parts 26.4(a)(1) through (a)(5) of 10 CFR are available to meet the requirements of 10 CFR 26.205(c) and (d).This time may include a period during recovery when the station has exited the emergency condition but sufficient personnel and resources are not available from offsite.

St. Lucie Units 1 and 2 L-2010-051 Docket Nos. 50-335 and 50-389 Attachment Page 2 of 2 NRC Question 2 The supporting justification to the St. Lucie exemption request states that, "The hurricane staffing procedure provides specific guidance for crew staffing levels and for the process of sequestering storm crews." Does the hurricane staffing procedure or other site procedures define the condition necessary to sequester site personnel?

Please provide that procedural reference and guidance.Response Plant Procedure AP-0005753, Severe Weather Preparations, provides instructions to be followed to prepare for severe weather (e.g., tropical storms, hurricane watch/warnings).

The procedure requires that the Plant General Manager (PGM) or his designee, as the Hurricane Response Coordinator (HRC), ensures that personnel are identified to remain onsite during a hurricane as per site staffing procedure AP 0006128, and oversee hurricane preparations and response activities.

AP-0005753 gives the PGM discretion to perform hurricane preparation activities for projected weather conditions less severe than hurricanes (e.g., tropical storms).Plant Procedure AP-0006128, Hurricane Staffing, provides instructions for staffing in preparation for and during a hurricane.

The procedure includes an appendix delineating the minimum staff required to be sequestered during a storm but not the resources needed to make the station ready for severe weather since that condition varies from event to event. Once the plant is projected to receive hurricane force winds, the HRC directs that the roster be completed for the personnel who will be sequestered and remain on-site. The procedure allows for discretion to adjust staffing levels when actual and/or projected conditions warrant. For example, if the National Hurricane Center has issued a Hurricane Warning for the area including St. Lucie Plant, but does not predict on-site winds to exceed hurricane force (i.e., less than 74 mph), then a re-evaluation of staffing requirements is allowed. Procedurally, movement outdoors is limited once winds exceed tropical force winds, and the sequestered staff is expected to be onsite prior to the onset of tropical force winds.