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Technical Specification 6.8.1.a. requires Technical Specification 6.8.1.a. requires that written procedures shall be established, implemented, and maintained covering the activities in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Regulatory Guide 1.33, Appendix A, Section 6.v., requires procedures for combating emergencies such as plant fires. Procedure 2-ONP-100.02, Control Room Inaccessibility, Rev. 22, provided instructions for placing St. Lucie Unit 2 in a safe condition if operations could not be performed from the MCR due to a fire in the MCR. Contrary to the above, on February 12, 2009, the team identified that procedure 2-ONP- 100.02, Control Room Inaccessibility, provided inadequate guidance. Specifically, the procedure did not identify that personnel fall protection safety equipment and additional keys were required for performance of certain operator manual actions to support operation from the HSCP during post-fire SSD conditions. The licensee initiated CRs 2009-2590 and 2009-2592 to address this issue. Pursuant to the Commissions Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. On December 22, 2005, the licensee submitted a letter to the NRC stating its intent to transition to 10 CFR 50.48(c). Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). Specifically, it was likely this issue would have been identified and addressed during the licensees transition to NFPA 805, it was entered into the licensees corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.ith a finding of high safety significance.  
23:59:59, 31 March 2009  +
05000335  +  and 05000389  +
23:59:59, 31 March 2009  +
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21:50:58, 8 October 2017  +
23:59:59, 31 March 2009  +
Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)  +