ML101090509
| ML101090509 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/19/2010 |
| From: | Reyes L Region 2 Administrator |
| To: | Nazar M Florida Power & Light Co |
| References | |
| EA-09-321, IR-10-007 IR-10-007 | |
| Download: ML101090509 (10) | |
See also: IR 05000335/2010007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
April 19, 2010
Mr. Mano Nazar
Executive Vice President and
Chief Nuclear Officer
Florida Power & Light Company
P.O. Box 14000
Juno Beach, FL 33408-0420
SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF A YELLOW FINDING AND
NOTICE OF VIOLATION (NRC COMPONENT DESIGN BASES INSPECTION
REPORT 05000335/2010007 AND 05000389/2010007), ST. LUCIE NUCLEAR
PLANT
Dear Mr. Nazar:
The purpose of this letter is to provide you with the disposition and final significance
determination of the two preliminary Greater than Green findings discussed in NRC Inspection
Report No. 05000335/2009006 and 05000389/2009006, dated January 19, 2010,
(ML100210081). The two preliminary findings were related to air intrusion into the Component
Cooling Water (CCW) system that occurred in October 2008, and involved (1) the failure of a
non-safety system that could result in a common cause failure of both trains of the CCW
system, contrary to 10 CFR 50 Appendix B, Criterion III, Design Control, and (2) the failure to
identify and correct a condition adverse to quality involving the source of the air in-leakage into
the CCW system, contrary to 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. The
NRCs Inspection Report identified two apparent violations corresponding to the two preliminary
findings.
At your request, a Regulatory Conference was held on February 19, 2010, to discuss your views
on these issues. During the conference, your staff described the circumstances surrounding the
October 2008 event, Florida Power and Light Companys (FPLs) assessment of the
significance of the two preliminary findings, its root cause evaluation, and the corrective actions
taken. FPL highlighted several differences between its risk assessment and the NRCs
preliminary risk assessment as documented in our inspection report of January 19, 2010. At the
conference, FPL contested the preliminary finding and apparent violation involving 10 CFR 50,
Appendix B, Criterion III. In summary, FPL concluded that when St. Lucie Unit 1 was licensed,
the facility was not required to incorporate a single failure design capability for a non-safety
system. As such, FPL concluded that a violation of 10 CFR 50, Appendix B, Criterion III, did not
occur. Regarding the second preliminary finding involving the failure to identify and correct the
source of air in-leakage into the CCW system, FPL concluded that the significance of the finding
should be characterized as Green. FPL did not contest the validity of the corresponding
10 CFR 50 Appendix B, Criterion XVI violation.
FPL 2
Regarding the preliminary finding involving 10 CFR 50, Appendix B, Criterion III, the NRC
considered the information provided by FPL at the conference, and reviewed available
information to determine the applicability of design control regulations to St. Lucie Unit 1. This
included a review of the requirements at the time St. Lucie Unit 1 was originally licensed, the
Safety Evaluation Report issued by the NRC following the review of St. Lucie Unit 1 design, the
Final Safety Analysis Report, and the single failure analysis associated with the CCW system.
Based on the review, the NRC determined that the Unit 1 CCW system met the design
requirements at the time of licensing and at the time of the October 2008 air intrusion event.
Therefore, this issue does not represent a performance deficiency, and accordingly, a violation
of 10 CFR 50, Appendix B, Criterion III did not occur. Accordingly, Apparent Violation
05000335, 389/2009006-05, Failure to Translate Design Basis Specifications to Prevent Single
Failure of CCW is considered closed.
After considering the information developed during the inspection and information provided by
FPL during and after the conference, the NRC has concluded that the finding involving the
failure to identify and correct the source of the air in-leakage into the CCW system is
characterized as Yellow, i.e., a finding of substantial significance with regard to safety, which will
require additional NRC inspections. The bases for the NRCs significance determination of this
finding, and the differences in the licensees characterization of the findings, are discussed in
Enclosure 2.
You have 30 calendar days from the date of this letter to appeal the staff=s significance
determination for the Yellow finding. Such appeals will be considered to have merit only if they
meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.
The NRC also has determined that the failure to identify and correct the source of the air in-
leakage into the CCW system is a violation of 10 CFR 50 Appendix B, Criterion XVI, as cited in
the enclosed Notice of Violation (Notice). The circumstances surrounding the violation were
described in detail in NRC Inspection Report No. 05000335/2009006 and 05000389/2009006,
dated January 19, 2010 (ML100210081). In accordance with the NRC Enforcement Policy, the
Notice is considered escalated enforcement action because it is associated with a Yellow
finding.
For administrative purposes, this letter is issued as a separate NRC Inspection Report,
No. 05000335/2010007 and 05000389/2010007. Apparent Violation 05000335, 389/2009006-
06, related to the CCW air intrusion event, is now Violation 05000335/2009006-06, Failure to
Identify and Correct a Condition Adverse to Quality. This violation was determined to have a
cross-cutting aspect in the area of Human Performance, Decision Making, specifically H.1(a).
Because plant performance for this issue has been determined to be beyond the licensee
response band of the NRC Action Matrix, we will use the Action Matrix to determine the most
appropriate NRC response for this event. We will notify you, by separate correspondence, of
that determination.
The NRC has concluded that information regarding the reason for the violation, the corrective
actions taken and planned to correct the violation and prevent recurrence and the date when full
compliance will be achieved is already adequately addressed on the docket in the St. Lucie
FPL 3
Meeting Summary, dated February 26, 2010 (ML100601170). Therefore, you are not required
to respond to this letter unless the description therein does not accurately reflect your corrective
actions or your position. 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, please follow the instructions specified in the Notice of
Violation, Enclosure 1.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
Enclosures 1 and 2, and your response, if any, will be made available electronically for public
inspection in the NRC Public Document Room or from the NRC=s document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent
possible, your response, if any, should not include any personal privacy, proprietary, or
safeguards information so that it can be made available to the Public without redaction. If
personal privacy or proprietary information is necessary to provide an acceptable response,
please provide a bracketed copy of your response that identifies the information that should be
protected and a redacted copy of your response that deletes such information. If you request
withholding of such information, you must specifically identify the portions of your response that
you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). The NRC also includes significant
enforcement actions on its Web site at
http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/).
Sincerely,
/RA/
Luis A. Reyes
Regional Administrator
Docket Nos.: 50-335, 50-389
License Nos.: DPR-67 and NPF-16
Enclosures: 1. Notice of Violation
2. NRC Bases for Final Significance Determination
cc w/encls: (See page 4)
_________________________ G SUNSI REVIEW COMPLETE
OFFICE RII:ORA RII:DRS RII:DRS RII:DRS RII:DRP RII:DRS RII:ORA
SIGNATURE RA RA RA VIA EMAIL RA RA RA
NAME CEvans WRogers BDesai KKennedy LWert JLubinski VMcCree
DATE 4/7/2010 4/5/2010 3/31/2010 4/14/2010 4/14/20104/ 4/13/20104/ 4/15/2010
E-MAIL COPY? YES NO YES NO YES NO YES NO YES/2010 NO YES/2010 NO YES NO
SIGNATURE email Email
NAME RZimmerman MCUNNINGHAM
DATE 4/14/2010 4/8/2010 4/ /2010 4/ /2010 4/ /2010 4/ /2010 4/ /2010
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
FPL 4
cc w/encl: Marjan Mashhadi
Richard L. Anderson Senior Attorney
Site Vice President Florida Power & Light Company
St. Lucie Nuclear Plant Electronic Mail Distribution
Electronic Mail Distribution
William A. Passetti
Robert J. Hughes Chief
Plant General Manager Florida Bureau of Radiation Control
St. Lucie Nuclear Plant Department of Health
Electronic Mail Distribution Electronic Mail Distribution
Gene St. Pierre Ruben D. Almaguer
Vice President, Fleet Support Director
Florida Power & Light Company Division of Emergency Preparedness
Electronic Mail Distribution Department of Community Affairs
Electronic Mail Distribution
Ronnie Lingle
Operations Manager J. Kammel
St. Lucie Nuclear Plant Radiological Emergency Planning
Electronic Mail Distribution Administrator
Department of Public Safety
Eric Katzman Electronic Mail Distribution
Licensing Manager
St. Lucie Nuclear Plant Mano Nazar
Electronic Mail Distribution Executive Vice President and Chief Nuclear
Officer
Abdy Khanpour Florida Power & Light Company
Vice President P. O. Box 14000
Engineering Support Juno Beach, FL 33408
Florida Power and Light Company
P.O. Box 14000 (Vacant)
Juno Beach, FL 33408-0420 Vice President
Nuclear Plant Support
Larry Nicholson Florida Power & Light Company
Director Electronic Mail Distribution
Licensing
Florida Power & Light Company Seth B. Dunston
Electronic Mail Distribution Training Manager
St. Lucie Nuclear Plant
Alison Brown Electronic Mail Distribution
Nuclear Licensing
Florida Power & Light Company Faye Outlaw
Electronic Mail Distribution County Administrator
St. Lucie County
Mitch S. Ross Electronic Mail Distribution
Vice President and Associate General
Counsel Jack Southard
Florida Power & Light Company Director
Electronic Mail Distribution Public Safety Department
St. Lucie County
Electronic Mail Distribution
FPL 5
Letter to Mano Nazar from Luis A. Reyes dated April xx, 2010
SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A YELLOW FINDING AND
NOTICE OF VIOLATION (NRC COMPONENT DESIGN BASES INSPECTION
REPORT 05000335/2010007 AND 05000389/2010007), ST. LUCIE NUCLEAR
PLANT
Distribution w/encls:
C. Evans, RII
L. Slack, RII
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMStLucie Resource
R. Borchardt, OEDO
R. Zimmerman, OE
E. Julian, SECY
B. Keeling, OCA
Enforcement Coordinators, RI, RIII, RIV
E. Hayden, OPA
C. McCrary, OI
H. Bell, OIG
E. Leeds, NRR
M. Ashley, NRR
B. Mozafari, NRR
C. Scott, OGC
D. Decker, OCA
G. Gulla, OE
J. Circle, NRR
L. Reyes, RII
V. McCree, RII
K. Kennedy, RII
J. Lubinski, RII
L. Wert, RII
B. Desai, RII
M. Sykes, RII
R. Nease, RII
W. Rogers, RII
S. Sparks, RII
NOTICE OF VIOLATION
Florida Power and Light Docket No. 50-335
St. Lucie Nuclear Plant DPR-67
Unit 1 EA-09-321
During an inspection completed by the NRC on December 10, 2009, a violation of NRC
requirements was identified. The circumstances surrounding the violation were described in
detail in NRC Inspection Report No. 05000335/2009006 and 05000389/2009006, dated January
19, 2010 (ML100210081). In accordance with the NRC Enforcement Policy, the violation is
listed below:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states that measures shall
be established to assure that conditions adverse to quality, such as deficiencies,
deviations, and non-conformances are promptly identified and corrected. In the case of
significant conditions adverse to quality, the measures shall assure that the cause of the
condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to identify and correct a significant condition
adverse to quality affecting the Component Cooling Water (CCW) system. Specifically,
in October 2008, air intrusion from the containment instrument air (IA) system into the
CCW system occurred which affected both redundant trains of the CCW system. The
troubleshooting and subsequent corrective actions that were implemented by the
licensee failed to identify the source of the air in-leakage and ensure that the CCW
system remained capable of delivering adequate cooling to essential equipment used to
mitigate design bases accidents. In addition, the corrective actions failed to preclude a
similar air intrusion event into the CCW system in November 2009.
This violation is associated with a Yellow Significance Determination Process finding for
Unit 1 in the Initiating Events cornerstone.
The NRC has concluded that information regarding the reason for the violation, the corrective
actions taken and planned to correct the violation and prevent recurrence and the date when full
compliance will be achieved is already adequately addressed on the docket in the St. Lucie
Meeting Summary, dated February 26, 2010 (ML100601170). Therefore, you are not required
to respond to this letter unless the description therein does not accurately reflect your corrective
actions or your position. 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, clearly mark your response
as a "Reply to a Notice of Violation," include the EA number, and send it to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a
copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the
facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this
Notice of Violation (Notice).
Enclosure 1
NOV 2
If you choose to respond, your response will be made available electronically for public
inspection in the NRC Public Document Room or from the NRC=s document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to
the extent possible, the response should not include any personal privacy, proprietary, or
safeguards information so that it can be made available to the Public without redaction. If
personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
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.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 19th day of April 2010.
Enclosure 1
NRC Bases for Final Significance Determination
On February 19, 2010, the NRC held a regulatory conference with representatives of FPL, St.
Lucie Nuclear Plant, to discuss two preliminary Greater than Green inspection findings
documented in NRC Inspection Report 05000335, 389/2009006 (ML100210081). These
findings concerned issues associated with an October 8, 2008, air intrusion event from the Unit
1 containment instrument air system into the CCW system.
At the regulatory conference, FPL highlighted their assumptions in determining the risk
associated with the air intrusion event as Green. These assumptions differed in some instances
with those used by the NRC in the preliminary significance determination. In determining the
final significance, NRC considered FPL assumptions and factored them into the significance
determination process when appropriate. A number of FPLs assumptions were fully accepted
and integrated into the NRC final significance determination. These assumptions included: the
most probable outcome of air intrusion into the CCW system would be operators terminating the
event by isolating the air intrusion source; the dominant accident sequence was operators failing
to stop the air intrusion prior to CCW failure followed by operators failing to trip the reactor
coolant pumps (RCPs) upon a loss of CCW; and, operators would follow established
procedures to the best of their abilities. Also, based upon FPLs input, the final NRC
significance determination assumed that operators had time to stop the air intrusion before
CCW system failure.
There were several differences between NRC and FPL in NRCs final significance
determination. The paragraphs below provide a summary of the differences and the bases for
the NRCs final significance determination.
FPL assumed that due to the preponderance of alarms available to the operators, it was highly
likely that the operators would trip the reactor and stop the RCPs before CCW system failure
would occur. The NRC did not consider these actions in the preliminary significance
determination. However, based upon FPLs input, it was included in the final significance
determination. The NRC recognized that available alarms would indicate irregular flow in the
CCW system and that some of these alarms would direct operators to stop the RCPs and trip
the reactor. However, the NRC assumed that the collective set of alarms and indications would
provide for competing actions to trip the CCW pumps and/or trip the RCPs. Further, some of
the alarms would occur either after CCW failure or at imminent failure. Therefore, assigning a
probability to the actions to trip the reactor and stopping the RCPs prior to CCW failure as highly
likely was not used. Instead, as an assumption for the final significance determination, a less
likely probability than assumed by FPL was assigned by the NRC. Specifically, the NRC
assigned a 50/50 probability that operators would trip the reactor and stop the RCPs prior to
CCW failure in the final significance determination as compared to FPL, which did not present
specific numbers at the conference but, indicated a significantly high probability for operators
succeeding in this action.
Enclosure 2
According to FPLs calculations, the conditional core damage probability associated with the air
intrusion event, based upon the latest plant specific PRA and the NRCs SPAR model, varied
between 1E-4 & 6E-4. The NRC used the latest available information regarding the RCP seals,
the procedures associated with the RCPs, and operator training in updating the NRCs SPAR
model of St. Lucie. Further, the NRC, in contrast to FPL, used an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> versus 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
exposure time for RCP seal failure in the final conditional core damage probability calculation to
account for a standard reactor shutdown.
As a result, the NRC determined that the conditional core damage probability associated with
this event was 5.6E-4. Although the NRC applied a different methodology, this numerical result
was consistent with the licensees input and had no affect on the final significance
determination.
FPL did not present specific numbers but assumed that the probability of operators failing to
recognize and mitigate the air intrusion before CCW pump failure was two to three orders of
magnitude less than 1E-1, the number assigned by the NRC, in the preliminary significance
determination.
The failure probability used by the NRC for the final significance determination, like FPL,
included a dependency, since different crews would be involved in the recognition and
mitigation of the air intrusion event. The NRC used a standard Human Reliability Assessment
(HRA) protocol in determining the assumption for this operator failure probability in the final
significance determination. Like FPL, the performance shaping factors used in the final HRA
included 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for operators to recognize and mitigate air intrusion before CCW failure.
However, NRC differed from FPL in the performance shaping factor contributions due to the fact
that no specific procedure existed to direct operators in diagnosing air intrusion into the CCW
system, the high level of complexity associated with diagnosing the source of air intrusion, and
limited operator training/experience associated with CCW events of this nature. In its final
significance determination, the NRC, after factoring in all the performance shaping factors, used
6.58 E-2 as the probability that operators would not stop the air intrusion into the CCW system
prior to pump failure. While FPL did not present specific numbers, their assumptions differed by
approximately two to three magnitudes from the NRC. This difference in performance shaping
factor assumptions was effectively the most significant difference between the NRC and FPL in
determining the final significance associated with the event.
In conclusion, FPL determined, based on best-estimate assumptions, that the delta core
damage frequency (CDF) increase was less than 1E-6. The NRC did not agree with FPLs
determination of delta CDF being less than 1E-6. Even after factoring in numerous FPL
assumptions, NRC determined the delta CDF for the CCW air intrusion performance deficiency
to be approximately 2E-5. With this delta CDF being greater than 1E-5, the performance
deficiency was classified as Yellow.
Enclosure 2