ML12349A038

Notification of Conduct of a Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000335-13-007 & 05000389-13-007)

ML12349A038
Person / Time
Site:	Saint Lucie
Issue date:	12/10/2012
From:	Mark King NRC/RGN-II/DRS/EB2
To:	Nazar M Florida Power & Light Co
References
IR-13-007
Download: ML12349A038 (9)

See also: IR 05000335/2013007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

December 10, 2012

Mr. Mano Nazar

Executive Vice President and

Chief Nuclear Officer

Florida Power and Light Company

P.O. Box 14000

Juno Beach, FL 33408-0420

SUBJECT: ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 - NOTIFICATION OF

CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

(NRC INSPECTION REPORT NOS. 05000335/2013007 AND

05000389/2013007)

Dear Mr. Nazar:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region II staff will conduct a triennial fire protection baseline inspection at the St. Lucie Nuclear

Plant, Units 1 and 2, in March 2013. The inspection team will be led by Mr. McKenzie Thomas,

a Senior Reactor Inspector from the NRC Region II Office. The team will be composed of

personnel from the Region II Office. The inspection will be conducted in accordance with

Inspection Procedure 71111.05T, the NRCs triennial fire protection baseline inspection

procedure, dated October 28, 2011. Inspection of circuit analysis is included in the inspection

procedure.

On December 6, 2012, during a telephone conversation between Mr. Eric Katzman, St. Lucie

Licensing Manager, and Mr. Thomas, our respective staffs confirmed arrangements for a three-

day information gathering onsite visit and a two-week onsite inspection. The schedule for the

inspection is as follows:

• Information gathering visit: February 19-21, 2013

• Week 1 of onsite inspection: March 11-15, 2013

• Week 2 of onsite inspection: March 25-29, 2013

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, to become familiar with the St. Lucie Nuclear Plant fire

protection program, fire protection features, post-fire safe shutdown capabilities, plant layout,

and mitigating strategies to address Section B.5.b of NRC Order EA-02-026, Order for Interim

Safeguards and Security Compensatory Measures, dated February 25, 2002, and Title 10 of

the Code of Federal Regulations (10 CFR) 50.54(hh)(2). The types of documents the team will

be interested in reviewing, and possibly obtaining, are listed in Enclosures 1 and 2. Please

contact Mr. Thomas at (404) 997-4673 prior to preparing copies of the materials listed in the

Enclosures. The inspection team will try to minimize your administrative burden by specifically

identifying those documents required for inspection preparation.

M. Nazar 2

During the information gathering visit, the team will also discuss the following inspection support

administrative details: office space; specific documents to be made available to the team in their

office space; arrangements for unescorted site access (including, as necessary, radiation

protection training, security, safety and fitness for duty requirements); and the availability of

knowledgeable plant engineering and licensing organization personnel to serve as points of

contact during the inspection.

We request that during the inspection weeks you ensure that copies of analyses, evaluations or

documentation regarding the implementation and maintenance of the St. Lucie Nuclear Plant

fire protection program, including post-fire safe shutdown capability, be readily accessible to the

team for their review. Of specific interest for the fire protection portion of the inspection are

those documents which establish that your fire protection program satisfies NRC regulatory

requirements and conforms to applicable NRC and industry fire protection guidance. For the

B.5.b portion of the inspection, those documents implementing your mitigating strategies and

demonstrating the management of your commitments for the strategies are of specific interest.

Also, personnel should be available at the site during the inspection who are knowledgeable

regarding those plant systems required to achieve and maintain safe shutdown conditions from

inside and outside the control room (including the electrical aspects of the relevant post-fire safe

shutdown analyses), reactor plant fire protection systems and features, and the St. Lucie

Nuclear Plant fire protection program and its implementation.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, under control number

3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to,

a request for information or an information collection requirement unless the requesting

document displays a currently valid Office of Management and Budget control number.

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection, or the inspection team's information or logistical needs, please

contact Mr. Thomas at (404) 997-4673, or me at (404) 997-4511.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document system

M. Nazar 3

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael F. King, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-335, 50-389

License Nos.: DPR-67, NPF-16

Enclosures:

1. Triennial Fire Protection Inspection Supporting Documentation

2. Mitigating Strategies Supporting Documentation

cc: (See page 4)

_________________________ xG SUNSI REVIEW COMPLETE G FORM 665 ATTACHED

OFFICE RII:DRS RII:DRS

SIGNATURE RA RA

NAME MTHOMAS MKING

DATE 12/7/2012 12/10/2012 12/ /2012 12/ /2012 12/ /2012 12/ /2012 12/ /2012

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

M. Nazar 4

cc: Cynthia Becker

Joseph Jensen (Acting) Chief

Site Vice President Florida Bureau of Radiation Control

St. Lucie Nuclear Plant Department of Health

Electronic Mail Distribution Electronic Mail Distribution

Paul Freeman Bryan Koon

Vice President Director

Organizational Effectiveness Florida Division of Emergency Management

Florida Power & Light Company Electronic Mail Distribution

Electronic Mail Distribution

Donna Calabrese

Peter Wells Emergency Preparedness Manager

Vice President St. Lucie Plant

Outage Support CFAM Electronic Mail Distribution

Florida Power & Light Company

Electronic Mail Distribution J. Kammel

Radiological Emergency Planning

Robert J. Hughes Administrator

Plant General Manager Department of Public Safety

St. Lucie Nuclear Plant Electronic Mail Distribution

Electronic Mail Distribution

Senior Resident Inspector

Daniel D. DeBoer St. Lucie Nuclear Plant

Operations Site Director U.S. Nuclear Regulatory Commission

St. Lucie Nuclear Plant P.O. Box 6090

Electronic Mail Distribution Jensen Beach, FL 34957-2010

Eric Katzman Michael Baughman

Licensing Manager Training Manager

St. Lucie Nuclear Plant St. Lucie Nuclear Plant

Electronic Mail Distribution Electronic Mail Distribution

Larry Nicholson Faye Outlaw

Director County Administrator

Licensing St. Lucie County

Florida Power & Light Company Electronic Mail Distribution

Electronic Mail Distribution

James Petro

Alison Brown Managing Attorney-Nuclear

Nuclear Licensing Florida Power & Light Company

Florida Power & Light Company Electronic Mail Distribution

Electronic Mail Distribution

Jack Southard

Director

Public Safety Department

St. Lucie County

Electronic Mail Distribution

Letter to Mano Nazar from Michael F. King dated December 10, 2012.

SUBJECT: ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 - NOTIFICATION OF

CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

(NRC INSPECTION REPORT NOS. 05000335/2013007 AND

05000389/2013007)

Distribution:

RIDSNRRDIRS

PUBLIC

RidsNrrPMStLucie Resource

Triennial Fire Protection Inspection Supporting Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested in

reviewing, and possibly obtaining, during the information-gathering site visit. The current

version of these documents is expected unless specified otherwise. Electronic media is

preferred, if readily available. (The preferred file format is searchable .pdf files on CDROM.

The CDROM should be indexed and hyperlinked to facilitate ease of use. Please provide

5 copies of each CDROM submitted.) Information in lists should contain enough information to

be easily understood by someone who has knowledge of the technology. The lead inspector

will discuss specific information needs with the licensee staff and may request additional

documents.

1. The current version of the fire protection program and fire hazards analysis.

2. Corrective action closeouts as part of operator manual actions corrective actions.

3. List of identified fire induced circuit failure configurations for select fire areas.

4. Corrective actions for fire-induced circuit failures, both single and multiple spurious

actuations for select fire areas.

5. Cable routing for components and equipment credited for safe shutdown for select fire

areas.

6. List of protected safe shutdown train equipment for select fire areas.

7. Current versions of the fire protection program implementing procedures (e.g.,

administrative controls, surveillance testing, and fire brigade).

8. Fire brigade training program and pre-fire plans.

9. Post-fire safe shutdown systems and separation analysis.

10. Post-fire alternative shutdown analysis.

11. Piping and instrumentation diagrams showing the components used to achieve and

maintain hot standby and cold shutdown for fires outside the control room and those

components used for those areas requiring alternative shutdown capability.

12. Plant layout and equipment drawings which identify the physical plant locations of hot

standby and cold shutdown equipment.

13. Plant layout drawings which identify plant fire area delineation, areas protected by

automatic fire suppression and detection, and the locations of fire protection equipment.

14. Plant layout drawings which identify the general location of the post-fire emergency

lighting.

15. Plant operating procedures which would be used and describe shutdown from inside the

control room with a postulated fire occurring in any plant area outside the control room,

Enclosure 1

2

procedures which would be used to implement alternative shutdown capability in the

event of a fire in the control room or cable spreading room.

16. Maintenance and surveillance testing procedures for alternative shutdown capability and

fire barriers, detectors, pumps, and suppression systems.

17. Maintenance procedures which routinely verify fuse breaker coordination in accordance

with the post-fire safe shutdown coordination analysis.

18. A list of significant fire protection and post-fire safe shutdown related design change

packages and evaluations according to Generic Letter 86-10, Implementation of Fire

Protection Requirements.

19. The reactor plant's Individual Plant Examination for External Events (IPEEE), results of

any post-IPEEE reviews, and listings of actions taken/plant modifications conducted in

response to IPEEE information.

20. Organization charts of site personnel (including fire protection staff personnel).

21. If applicable, drawings of potential reactor coolant/recirculation pump lube oil system

leakage points and associated lube oil collection systems.

22. Licensing basis documents for fire protection (safety evaluation reports, pertinent

sections of the final safety analysis report, exemptions, deviations, letters to/from the

NRC regarding fire protection/fire safe shutdown, etc.).

23. Procedures/instructions that control the configuration of the plant's fire protection

program, features, and post-fire safe shutdown methodology and system design.

24. A list of applicable codes and standards related to the design of plant fire protection

features and evaluations of code deviations.

25. Procedures/instructions that govern the implementation of plant modifications,

maintenance, and special operations, and their impact on fire protection.

26. Internal and external self-assessments, audits, peer-assessments or similar reviews

related to post-fire safe shutdown capability or the fire protection program completed

since the previous NRC fire protection triennial inspection.

27. Recent quality assurance surveillances of fire protection activities.

28. A listing of open and closed fire protection condition reports (problem reports/nuclear

condition reports/event analysis reports/problem identification and resolution reports)

since the last triennial inspection.

Enclosure 1

Mitigating Strategies Supporting Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested in

reviewing, and possibly obtaining, during the information gathering site visit. The current

version of these documents is expected unless specified otherwise. Electronic media is

preferred, if readily available. (The preferred file format is searchable .pdf files on CDROM.

The CDROM should be indexed and hyperlinked to facilitate ease of use. Please provide 5

copies of each CDROM submitted.) Information in lists should contain enough information to

be easily understood by someone who has knowledge of the technology. The lead inspector

will discuss specific information needs with the licensee staff and may request additional

documents.

1. A list of all modifications to regulatory commitments made to meet the requirements of

Section B.5.b of NRC Order, EA-02-026, Order for NRC Interim Safeguards and

Security Compensatory Measures, dated February 25, 2002, the subsequently imposed

license conditions, and Title 10 of the Code of Federal Regulations (10 CFR)

50.54(hh)(2).

2. Lists of procedures/guidelines that were revised or generated to implement the

mitigation strategies. These could be extensive damage mitigation guidelines (EDMGs),

severe accident management guidelines (SAMGs), emergency operating procedures

(EOPs), abnormal operating procedures (AOPs), etc.

3. A matrix that shows the correlation between the mitigation strategies identified in

Nuclear Energy Institute 06-12, Revision 2, B.5.b Phase 2 & 3 Submittal Guideline,

issued December 2006, and the site-specific procedures or guidelines used to

implement each strategy.

4. Engineering evaluations/calculations that were used to verify engineering bases for the

mitigation strategies.

5. Piping and instrumentation diagram for systems relied upon in the mitigation strategies.

These could be of the type used for training.

6. A list of modification packages or simplified drawings or descriptions of modifications

that were made to plant systems to implement the mitigation strategies.

7. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.) required

to implement the mitigation strategies.

8. A list of B.5.b strategies, if any, that have implementing details that differ from those

documented in the submittals and the safety evaluation report.

9. A copy of site general arrangement drawing(s) that show the majority of buildings/areas

referenced in B.5.b documents.

10. Training records, training matrix, and lesson plans related to B.5.b.

11. Copies of memoranda of understanding (e.g., with local fire departments) required to

implement any mitigating strategies.

Enclosure 2