IR 05000335/2011009

NRC Temporary Instruction 2515/183 Inspection Report 05000335/2011009, 05000389/2011009

ML111330160
Person / Time
Site:	Saint Lucie
Issue date:	05/13/2011
From:	Rich D NRC/RGN-II/DRP/RPB3
To:	Nazar M Florida Power & Light Co
References
IR-11-009
Download: ML111330160 (21)

Text

UNITED STATES May 13, 2011

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000335/2011009, 05000389/2011009

Dear Mr. Nazar:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Plant using Temporary Instruction 2515/183, Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on May 6, 2011, with Mr. Anderson and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of St. Lucie to respond to extraordinary consequences similar to those that have recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection performed at other operating commercial nuclear plants in the United States, will be used to evaluate the U.S. nuclear industrys readiness to safely respond to similar events.

These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

FPL 2 NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Daniel W. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-335, 50-389 License Nos. DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2011009, 05000389/2011009

REGION II==

Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16 Report No.: 05000335/2011009, 05000389/2011009 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 6351 South Ocean Drive Jensen Beach, FL 34957 Dates: March 23 to April 29, 2011 Inspector: S. Sanchez, Acting Senior Resident Inspector Approved by: D. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000335/2011009, 05000389/2011009, 03/23/2011 - 04/29/2011; St. Lucie Temporary

Instruction 2515/183 - Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction (TI) inspection. The inspection was conducted by a resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the TI is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on

(1) assessing the licensees capability to mitigate consequences from large fires or explosions on site, (2)assessing the licensees capability to mitigate station blackout (SBO) conditions,

(3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and

(4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site.

If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection The licensee determined that the B.5.b. portable diesel fire pump (PDFP) and associated that equipment is available and equipment were the only plant components required to be tested or inspected. The PDFP, functional. Active equipment fire hoses, and all necessary fittings were inspected by the licensee. The PDFP was tested shall be tested and passive at full flow, and all the necessary fittings, fire hoses, etc., were deployed in walk-through equipment shall be walked down demonstrations of three key B.5.b. scenarios: PDFP steam generator feed; PDFP spent fuel and inspected. It is not pool (SFP) makeup; and PDFP containment flooding. The key non-plant equipment expected that permanently credited in B.5.b. response is offsite support from the St. Lucie County Fire Department. As installed equipment that is a demonstration, or test, of that capability, a fire department ladder truck was brought onsite tested under an existing and SFP makeup spray capability was demonstrated in the plants north parking lot.

regulatory testing program be retested.

Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.).

This review should be done for a reasonable sample of mitigating strategies/equipment.

The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspector assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspector independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site. The results of the inspectors independent walkdowns confirmed the results obtained by the licensee.

Discuss general results including corrective actions by licensee.

No significant deficiencies were identified in any of the three key B.5.b. scenarios. The licensee identified that spare parts for the PDFP are not maintained as part of the stations inventory. A condition report was written documenting this issue (AR 1630331) and entered into the licensees Corrective Action program (CAP). The licensee also identified several minor enhancements to procedures, equipment, and labeling that were also entered in their CAP.

Describe the licensees actions to verify that procedures are in place and can be executed Licensee Action (e.g. walkdowns, demonstrations, tests, etc.)

b. Verify through walkdowns or The licensee determined that the following plant procedures were relevant to verify the demonstration that procedures subject strategies: the B.5.b PDFP procedures; the SFP makeup procedures; the Severe to implement the strategies Accident Mitigation Guidelines (SAMGs); the auxiliary feedwater (AFW) abnormal operating associated with B.5.b and 10 procedures (AOPs); and the Extensive Damage Mitigation Guidelines (EDMGs). These CFR 50.54(hh) are in place and procedures were validated by walkdown, demonstration, or table top exercises as are executable. Licensees may appropriate.

choose not to connect or operate permanently installed Describe inspector actions and the sample strategies reviewed. Assess whether equipment during this procedures were in place and could be used as intended.

verification.

The licensees actions as discussed above were completed prior to the issuance of NRC TI This review should be done for a 2515/183. The inspector assessed the licensees capabilities by conducting a review of the reasonable sample of mitigating licensees walkdown activities. In addition, the inspector selected several sections of a strategies/equipment.

sample of the procedures walked down by the licensee and independently walked those down to verify the licensees conclusions.

Discuss general results including corrective actions by licensee.

No significant deficiencies were identified in any of the procedures verified. The above listed procedures were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a B.5.b event could be performed. Some minor procedural enhancements were identified by the licensee and entered into their CAP. The inspector identified an enhancement to quality-related procedure 0-OSP-100.21, Portable Diesel Fire Pump Operability Test, to determine appropriate flow rate acceptance criteria during the functional flow test of the pump. The licensee documented this enhancement in their CAP (AR 1647746).

Describe the licensees actions and conclusions regarding training and qualifications of Licensee Action operators and support staff.

c. Verify the training and The licensee determined that B.5.b. and SAMG qualifications of operators (licensed and qualifications of operators and non-licensed) and Technical Support Center personnel required verification. Those the support staff needed to qualifications were verified through review of qualification lists. In addition, an independent implement the procedures and review of training records was performed by Training Department personnel.

work instructions are current for activities related to Security Order Section B.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh).

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspector assessed the licensees training and qualification activities by conducting a review of training and qualification materials and records related to B.5.b and SAMG event response.

Discuss general results including corrective actions by licensee.

No significant personnel qualification issues were identified.

Describe the licensees actions and conclusions regarding applicable agreements and Licensee Action contracts are in place.

d. Verify that any applicable The licensee determined that per the St. Lucie Emergency Plan, Letters of Agreement agreements and contracts are in (LOA) are updated every third year and confirmed annually by direct contact, telephone, or place and are capable of correspondence with offsite agencies. All Letters of Agreement associated with the meeting the conditions needed Emergency Plan were reviewed and verified to be current and in place, including all offsite to mitigate the consequences of agencies. The various involved agencies have listed in the Letters of Agreement specific these events.

measures they will take to assist the utility.

This review should be done for a reasonable sample of mitigating For a sample of mitigating strategies involving contracts or agreements with offsite entities, strategies/equipment.

describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspector assessed the licensees capabilities by conducting an independent review of the licensees emergency response agreement with the various agencies with Letters of Agreement. The inspectors review of the agreements verified that they were current, and assessed whether or not they were adequate for meeting the licensees mitigation strategy.

Discuss general results including corrective actions by licensee.

No significant deficiencies were identified in the review of offsite agency agreements and vendor contracts. A few minor items were identified by the licensee that necessitated further action: update LOA to ensure newly purchased equipment is added to existing list for St. Lucie County Fire District; track completion of the corporate contract with Aggreko since it was in the middle of negotiations when this review occurred; and, add annual verification to a site procedure for any Fleet Service contracts that may support emergency response.

Each of these items was entered into the licensees CAP.

Document the corrective action report number and briefly summarize problems noted by the Licensee Action licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open corrective The licensee identified many items for entry into their CAP, but none that had significant action documents to assess potential to prevent the success of any existing mitigation strategy. The following entries problems with mitigating were reviewed by the inspector as responses to issues identified in section 03.01:

strategy implementation identified by the licensee.

• AR 1630331, No Spare Parts Available for B.5.b. Diesel Pump Assess the impact of the

• AR 1631154, Written in Response to IER 11-1 problem on the mitigating

• AR 1631167, Letters of Agreement capability and the remaining

• AR 1631169, Letter of Agreement Improvement Opportunity capability that is not impacted.

• AR 1631172, Hurricane Season Checklist

• AR 1631251, TSC Problem Solving Team Table Top Exercises

• AR 1631388, Marking of Roadway for B.5.b. Pump

• AR 1631449, Repair Gaitronics in Alternate Fire House

• AR 1631454, Walkdown for IER 11-1

• AR 1631033, AOP-04.01 Walkdown

• AR 1647746, B.5.b. Pump Flow Test Acceptance Criteria [NRC IDENTIFIED]

The inspector reviewed each AR for potential impact to the licensees mitigation strategies.

No significant impacts were identified.

03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design, is functional and valid. Refer to TI 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22 as a guideline. It is not intended that TI 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Describe the licensees actions to verify the adequacy of equipment needed to mitigate an Licensee Action SBO event.

a. Verify through walkdowns and The licensee reviewed emergency operating procedures (EOP) 1/2-EOP-10, Station inspection that all required Blackout, and developed a list of every procedure that was referenced in those two EOPs.

materials are adequate and All EOPs at St. Lucie use 1/2-EOP-99, Appendices, Figures, Tables and Data Sheets. All properly staged, tested, and sections of 1/2-EOP-99 that were used in Instructions or Contingency Actions of 1/2-EOP-maintained.

10 were included in the list. Each activity on the list was assembled in individual packages which included a standardized Procedure Validation Sheet developed for fleet wide use.

Step 12 of both EOP-10 procedures instructed Operations to Ensure adequate ventilation or supplemental cooling for various rooms and included Contact E/M (electrical maintenance) for portable generators and temporary fan hookup. Step 12 was also assembled into a package for E/M to demonstrate that supplemental cooling could be implemented. All field packages for both units were walked down and step 12 was performed by E/M. While staging all equipment, E/M did not violate any security or fire barriers. In addition, E/M set up the portable generators and fans behind the E/M Shop, to ensure the generators and fans operated properly. All Procedure Validation Sheets were collected and scanned into the computer and were attached to procedure change requests (PCRs).

Describe inspector actions to verify equipment is available and useable.

The inspector assessed the licensees capability to mitigate SBO conditions by conducting a review of the licensees walkdown activities. In addition, the inspector selected a sample of equipment utilized by or required for mitigation of a SBO and conducted independent walkdowns to verify that the equipment was properly aligned and staged.

Discuss general results including corrective actions by licensee.

The licensee determined that all tools and special equipment were available and that the procedures could be performed as written. There was one PCR that was initiated and completed to change the reference in 1/2-EOP-10 from 1/2-NOP-02.24, Boron Concentration Control, to 1/2-AOP-02.02, Emergency Boration. However, the Operations Department determined that EOP-10 could have been run successfully with the as-listed procedure anyway because of the availability of an approved operational aid and the training conducted for emergency boration.

E/M collected the required Supplemental Cooling Equipment which was staged in the onsite tool room. The set up for this evolution was extensive but very thorough. The complete set up is not required for every situation and most likely would only be partially implemented as prioritized by the Operations Department. Job execution would normally take 16-20 man hours, however, this evolution required 17 additional man hours due to the lack of familiarity and staging issues. This was considered not to be a failure of the step, but does not fit into a time frame normally associated with optimal EOP execution.

Enhancement comments were received on all procedures and documented on the Procedure Validation Sheets. PCRs have been initiated for each procedure and the numbers are listed in the CAP. There was one CAP document (AR 1634098) written to track completion of all issues associated with IER 11-1 recommendation 2. The Supplemental Cooling resolution or clarification of expectations will be tracked under AR 1632160.

Licensee Action Describe the licensees actions to verify the capability to mitigate an SBO event.

b. Demonstrate through Procedure 2-EOP-10 was run in the simulator and all associated Appendices, Figures, walkdowns that procedures for Tables, and Data Sheets (2-EOP-99) required for use in the Control Room were validated.

response to an SBO are In addition to the simulator exercise, 1-EOP-10 and all associated Appendices, Figures, Tables, and Data Sheets (1-EOP-99) required for use in the Control Room were validated executable.

by walkdown.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The inspector assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspector selected several sections of a sample of the procedures walked down by the licensee and independently walked those down to verify the licensees conclusions. The inspector also observed a simulator training scenario that depicted a SBO event and subsequent operator actions to restore vital power from the other unit using the SBO crosstie breaker.

Discuss general results including corrective actions by licensee.

The licensee determined that all procedures could be performed as written. Minor procedural enhancements were identified by the licensee and documented as PCRs and will be updated at the next available opportunity.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to IP 71111.01, Adverse Weather Protection, Section 02.04, Evaluate Readiness to Cope with External Flooding as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Describe the licensees actions to verify the capability to mitigate existing design basis Licensee Action flooding events.

a. Verify through walkdowns and The licensee reviewed the design basis, drawings, and procedures associated with flood inspection that all required protection materials and equipment. The licensee performed testing of active temporary materials are adequate and equipment and inspected passive equipment to verify equipment was available and properly staged, tested, and functional. In addition, the licensee verified that materials required to support flood maintained.

mitigating actions were available and that temporary materials were properly staged.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspector assessed the licensees capabilities to mitigate flooding by conducting a review of the licensees walkdown activities. These reviews included the inspector conducting independent walkdowns of selected flood mitigation equipment and observing licensee engineering personnel during their in-field walkdowns. Licensee flood mitigation procedures were reviewed to verify usability. The inspectors conclusions aligned with the results obtained by the licensee.

Discuss general results including corrective actions by licensee.

No significant deficiencies were identified. The licensee did not identify any equipment functional failures. Doors, drains, barriers, and penetration seals were found to be functional. The licensee identified a total 22 penetration seals that were not inspected due to inaccessibility (e.g., high radiation area, scaffolding required) and documented the issue in the CAP (AR 1636698). Required materials, such as stop logs and portable sump pumps were available and properly staged or stored. Based on these walkdowns and inspections, the barriers and equipment required to mitigate either an internal or external design basis flood event were in place. The licensee identified a potentially degraded flood barrier associated with the ultimate heat sink valve cubicles. The openings for the valve cubicles are below the design basis flood level, and are intended to be water tight to protect the safety-related valves and associated equipment located in the cubicles. Degraded concrete around the hatch has allowed water in-leakage. Although flooding of the ultimate heat sink valve would preclude the need to open the valve, the flood protection for the equipment is degraded from design. Licensee entered this item in their CAP as AR 1636642.

.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Describe the licensees actions to assess the potential impact of seismic events on the Licensee Action availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that The licensee performed the following actions:

all required materials are

• Reviewed drawings and procedures to identify important permanent, portable, and adequate and properly staged, temporary equipment used for mitigation of fires tested, and maintained.

• Performed a walkdown of the identified fire mitigation equipment to assess the likelihood that it would survive a seismic event (the equipment was walked down even if it was not seismically designed in order to identify any degradation, non-conforming conditions, or external hazards that could make it more vulnerable to a seismic event)

• Walked down flood protection features and equipment identified in Recommendation 3 to identify any seismic vulnerabilities, including storage and staging locations for flood protection equipment

• Identified strategies in place for use of onsite portable equipment for firefighting contingencies

• Verified through walkdowns or demonstration that procedures to implement the strategies are in place and are executable

• Assessed equipment storage locations for seismic vulnerabilities

• Identified strategies in place for use of external resources for firefighting contingencies

• Verified that agreements are in place with the supporting agencies to support the actions required by the site procedures.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors conducted multiple walkdowns, both independently and in conjunction with licensee personnel, of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during a seismic event.

This equipment included, but was not limited to: all major B.5.b contingency response equipment staged throughout the site; all installed fire protection and suppression equipment in the various important-to-safety buildings onsite; the installed electric fire pumps and their controls; watertight doors and floor plugs throughout the site. Licensee flood and fire mitigation procedures were reviewed to verify usability. The results of the inspectors reviews aligned with the licensees conclusions, as described below.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

No significant deficiencies were identified with the licensees assessment of important equipment needed to mitigate fire and flood events, to identify the potential that the equipments function could be lost during seismic events possible for the site. The normal firefighting equipment is not designed for the sites design basis seismic event. Portable firefighting equipment used to support fire fighting strategies in the event that normal firefighting equipment is lost during a seismic event and some small portable flooding mitigation pumps could be damaged or become inaccessible due to non-seismic storage facilities. A plan for addressing the seismic issues identified above will be coordinated with the industry effort to identify plant enhancements to address the lessons learned from the events at Fukushima Daiichi Nuclear Station. The licensee generated AR 1640454 to revise Unit 1 and 2 firefighting strategies to address the loss of installed fire protection systems.

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. R. Anderson and other members of licensee management on May 6, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Anderson, Site Vice President

P. Atkinson, Engineering Supervisor

M. Baughman, Training

E. Belizar, Projects Manager

E. Burgos, Chemistry Supervisor

D. Calabrese, Emergency Preparedness Manager

D. Cecchett, Licensing Engineer

J. Connor, Systems and Component Engineering Manager

R. Filapek, Design Engineering Manager

K. Frehafer, Licensing Engineer

S. Gambill, Electrical Engineering Supervisor

J. Hamm, Site Engineering Director

M. Haskin, Maintenance Manager

M. Hicks, Excellence Director

T. Horton, Assistant Operations Manger

D. Huey, Work Control Manager

B. Hughes, Plant General Manager

R. Lingle, Operations Manager

C. Martin, Radiation Protection Manager

R. McDaniel, Fire Protection Supervisor

G. McKenzie, Lead Design Engineer

M. Moore, Performance Improvement Department Manager

B. Moss, BACCP Coordinator

D. Nowakowski, ISI Planning

J. Owens, Performance Improvement Department

S. Ramani, Civil Engineering Supervisor

O. Rodriguez, Systems Engineer

M. Snyder, Site Quality Assurance Manager

G. Swider, Engineering Manager - Programs

D. West, Lead System Engineer

T. Young, Security Manager

Nuclear Regulatory Commission

N. Childs, Resident Inspector

S. Ninh, Senior Project Inspector