ML091610675

IR 05000335-09-007, 05000389-09-007, on 01/26-30/2009 and 02/09-13/2009, St. Lucie Nuclear Plant, Units 1 and 2, Triennial Fire Protection Inspection

ML091610675
Person / Time
Site:	Saint Lucie
Issue date:	06/10/2009
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Nazar M Florida Power & Light Co
References
IR-09-007 IR-09-007
Download: ML091610675 (35)

See also: IR 05000335/2009007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

June 10, 2009

Mr. Mano Nazar

Executive Vice President,

Nuclear and Chief Nuclear Officer

Florida Power and Light Company

P.O. Box 14000

Juno Beach, FL 33408-0420

SUBJECT: ST. LUCIE NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION

INSPECTION REPORT 05000335/2009007 AND 05000389/2009007 AND

EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Nazar:

On February 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial

fire protection inspection at your St. Lucie Nuclear Plant, Units 1 and 2. The enclosed

inspection report documents the inspection results, which were discussed on February 12,

2009, with Mr. G. Johnston and other members of your staff. Following completion of additional

review in the Region II office, another exit meeting was held by telephone with Mr. E. Katzman,

Licensing Manager, and other members of your staff on April 30, 2009, to provide an update on

changes to the preliminary inspection findings.

The inspection examined activities conducted under your licenses as they relate to safety and

compliance with the NRCs rules and regulations and with the conditions of your licenses. The

inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel. The scope of the inspection was reduced, in accordance with NRC Inspection

Procedure 71111.05TTP, issued May 9, 2006, as a result of your ongoing project to convert the

fire protection licensing basis to the performance based risk-informed methodology described in

National Fire Protection Association Standard 805.

This report documents one NRC-identified finding of very low safety significance (Green). This

finding was determined to involve a violation of NRC requirements. However, because of the

very low safety significance and because the finding was entered into your corrective action

program, the NRC is treating the finding as a non-cited violation (NCV) consistent with Section

VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide

a response within 30 days of the date of this report, with the basis of your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident

Inspector at the St. Lucie Nuclear Plant. In addition, if you disagree with the characterization of

any finding in this report, you should provide a response within 30 days of the date of the

inspection report, with the basis for your disagreement, to the Regional Administrator, Region II,

and the NRC Resident Inspector at the St. Lucie Nuclear Plant. The information you provide will

be considered in accordance with Inspection Manual chapter 0305.

FP&L 2

The enclosed report also documents two noncompliances that were identified during the

inspection. The NRC is not taking enforcement action for these noncompliances because they

meet the criteria of NRC Enforcement Policy, Interim Enforcement Policy Regarding

Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and NRC Inspection

Manual Chapter 0305, Violations in Specified Areas of Interest Qualifying for Enforcement

Discretion.

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

enclosure, and your response, if any, will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Rebecca L. Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-335, 50-389

License Nos.: DPR-67, NPF-16

Enclosure: Inspection Report 05000335/2009007 and 05000389/2009007

w/Attachment: Supplemental Information

cc w/encl: (See page 3)

FP&L 3

cc w/encl: William A. Passetti

Gordon L. Johnston Chief

Site Vice President Florida Bureau of Radiation Control

St. Lucie Nuclear Plant Department of Health

Electronic Mail Distribution Electronic Mail Distribution

Christopher R. Costanzo Craig Fugate

Plant General Manager Director

St. Lucie Nuclear Plant Division of Emergency Preparedness

Electronic Mail Distribution Department of Community Affairs

Electronic Mail Distribution

Eric Katzman

Licensing Manager J. Kammel

St. Lucie Nuclear Plant Radiological Emergency Planning

Electronic Mail Distribution Administrator

Department of Public Safety

Abdy Khanpour Electronic Mail Distribution

Vice President

Engineering Support Mano Nazar

Florida Power and Light Company Senior Vice President and Nuclear Chief

P.O. Box 14000 Operating Officer

Juno Beach, FL 33408-0420 Florida Power & Light Company

Electronic Mail Distribution

Robert J. Hughes

Director Senior Resident Inspector

Licensing and Performance Improvement St. Lucie Nuclear Plant

Florida Power & Light Company U.S. Nuclear Regulatory Commission

Electronic Mail Distribution P.O. Box 6090

Jensen Beach, FL 34957-2010

Alison Brown

Nuclear Licensing Peter Wells

Florida Power & Light Company (Acting) Vice President, Nuclear

Electronic Mail Distribution Training and Performance Improvement

Florida Power and Light Company

Don E. Grissette P.O. Box 14000

Vice President, Nuclear Operations - South Juno Beach, FL 33408-0420

Region

Florida Power & Light Company Mark E. Warner

Electronic Mail Distribution Vice President

Nuclear Plant Support

M. S. Ross Florida Power & Light Company

Managing Attorney Electronic Mail Distribution

Florida Power & Light Company

Electronic Mail Distribution Faye Outlaw

County Adminstrator

St. Lucie County

Marjan Mashhadi Electronic Mail Distribution

Senior Attorney

Florida Power & Light Company (cc w/encl contd - See page 4)

Electronic Mail Distribution

FP&L 4

(cc w/encl contd)

Jack Southard

Director

Public Safety Department

St. Lucie County

Electronic Mail Distribution

__ ____________ xG SUNSI REVIEW COMPLETE

OFFICE RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS

SIGNATURE RA RA RA RA RA RA RA

NAME THOMAS STAPLES MILLER SUGGS MERRIWEATHER WALKER NEASE

DATE 05/ 14 /2009 05/ 14 /2009 4/29/09 05/ 8 /2009 05/13 /2009 05/9 /2009 6/10/2009

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

OFFICE RII:DRP

SIGNATURE RA

NAME SYKES

DATE 5/21/2009 6/ /2009 6/ /2009 6/ /2009 6/ /2009 6/ /2009 6/ /2009

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

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos.: 50-335, 50-389

License Nos.: DPR-67, NPF-16

Report Nos.: 05000335/2009007 and 05000389/2009007

Licensee: Florida Power & Light Company (FPL)

Facility: St. Lucie Nuclear Plant, Units 1 & 2

Location: Jensen Beach, FL 34957

Dates: January 26-30, 2009 (Week 1)

February 09-13, 2009 (Week 2)

Inspectors: N. Staples, Reactor Inspector (Lead Inspector)

M. Thomas, Senior Reactor Inspector

N. Merriweather, Senior Reactor Inspector

L. Suggs, Reactor Inspector

K. Miller, Reactor Inspector

B. Melly, Contractor

Accompanying G. Crespo, Senior Reactor Inspector - In Training

Personnel:

Approved by: Rebecca Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000335/2009007, 05000389/2009007; 01/26-30/2009 and 02/09-13/2009; St. Lucie

Nuclear Plant, Units 1 and 2; Triennial Fire Protection Inspection.

This report covers an announced two-week triennial fire protection inspection by five regional

inspectors, one contractor, and one inspector trainee. A Green non-cited violation was

identified. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609 ASignificance Determination Process@. The

cross-cutting aspect was determined using IMC 0305, Operating Reactor Assessment Program.

Findings for which the SDP does not apply may be Green or be assigned a severity level after

NRC management review. The NRC=s program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG 1649, AReactor Oversight Process@

Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The team identified two examples of a non-cited violation of St. Lucies Unit 1

and Unit 2 Renewed Operating License Conditions 3.E for the licensees failure to

promptly correct conditions adverse to quality. The first example involved failure to

take prompt corrective action for a noncompliance that was identified during the 2006

triennial fire protection inspection (Inspection Report 05000335, 389/2006010).

Specifically, the licensee did not implement corrective actions to perform surveillance

tests on the Unit 1 eight-hour battery powered portable emergency lights. The

second example identified by the team during the 2009 inspection, involved four

eight-hour battery powered fixed emergency lights that failed an annual surveillance

test and were not repaired or replaced. The licensee initiated Condition Reports

2009-4010, -4056 and -4220 to implement corrective actions to address these

issues.

The licensees failure to correct the above conditions adverse to quality involving fire

protection, as required, was a performance deficiency. The finding is more than

minor because it is associated with the reactor safety, mitigating systems,

cornerstone attribute of protection against external factors (i.e., fire) and it affects the

objective of ensuring reliability and capability of systems that respond to initiating

events. The team determined that this finding was of very low safety significance

(Green) because the operators had a high likelihood of completing the task using

flashlights. This performance deficiency is associated with the cross-cutting area:

Human Performance, Work Control: H.3(b). The finding was directly related to the

licensee not planning and coordinating work activities to support long-term

equipment reliability and their maintenance scheduling was more reactive than

preventive. (Section 1R05)

B. Licensee Identified Violations

None

Enclosure

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

The purpose of this inspection was to review the St. Lucie Nuclear Plant (PSL) fire

protection program (FPP) for selected risk-significant fire areas. The inspection was

performed in accordance with the U.S. Nuclear Regulatory Commission (NRC)

Inspection Procedure (IP) 71111.05TTP, AFire Protection-NFPA 805 Transition Period

(Triennial),@ dated 05/09/2006, for a plant in transition to National Fire Protection

Association (NFPA) Standard 805, APerformance-Based Standard for Fire Protection for

Light Water Reactor Electric Generating Plants,@ 2001 Edition. This inspection fulfilled

the baseline inspection program requirements for the triennial review of fire protection

and post-fire safe shutdown program performance. The FPP was assessed against the

requirements of 10 CFR Part 50.48(a) and (b) while the licensee is in the process of

transitioning to NFPA 805 to implement the requirements of 10 CFR 50.48(c). The NRC

reduced the scope of this inspection by not specifically targeting safe shutdown circuit

configurations for inspection. Emphasis was placed on verification that procedures for

post-fire safe shutdown (SSD) and the fire protection features provided for the selected

fire areas met NRC requirements. The inspection was performed in accordance with the

NRC Reactor Oversight Process (ROP), using a risk-informed approach for selecting the

fire areas and attributes to be inspected. The selection of risk-significant fire areas to be

evaluated during this inspection considered the licensee=s Individual Plant Examination

for External Events, information contained in FPP documents, results of prior NRC

triennial inspections, and observations noted during in-plant tours. The fire areas

(FA)/fire zones (FZ) chosen for review during this inspection were:

$ Unit 2 FA F/FZ 42I, Main Control Room, Elevation 62 feet.

$ Unit 2 FA A/FZ 37, Train A Switchgear, Elevation 43 feet.

$ Unit 2 FA H/FZ 51E, Reactor Auxiliary Building Hallway, Elevation 19.5

feet.

Section 71111.05-05 of the IP specifies a minimum sample size of three fire areas.

Inspection of the selected FAs/FZs fulfills the procedure completion criteria. The

inspection team evaluated the Units 1 and 2 FPP against applicable requirements which

included the fire protection program report contained in Appendix 9.5A of the Updated

Final Safety Analysis Report (UFSAR); plant Technical Specifications (TS); Units 1 and

2 Renewed Operating License, Conditions 3.E; NRC safety evaluation reports (SERs);

10 CFR 50.48(a) and (b); and 10 CFR 50, Appendix R and NRC approved exemptions

to Appendix R. The team also reviewed related documents that included the fire

hazards analysis (FHA) and post-fire safe shutdown analysis (SSA). Specific

documents reviewed by the team are listed in the Attachment.

Enclosure

4

.01 Post-Fire Safe Shutdown From Main Control Room (Normal Shutdown

a. Inspection Scope

Methodology

The team reviewed the licensees FPP described in UFSAR Section 9.5 A; applicable

sections of the licensees Appendix R SSA, Fire Area Report (2998-B-048, St. Lucie Unit

2 Appendix R Safe Shutdown Analysis); plant fire response procedures; system flow

diagrams; electrical control wiring diagrams; electrical cable routing lists; and other

engineering supporting documents. The reviews were performed to verify that hot and

cold shutdown could be achieved and maintained from the main control room (MCR),

with and without the availability of offsite power, for postulated fires in FA A/FZ 37 and

FA H/FZ 51E. The team performed plant walk-downs to verify that the plant

configuration was consistent with that described in the fire hazards analysis and the

SSA. The inspection activities focused on ensuring the adequacy of systems selected

for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring

instrumentation, and support system functions. The team reviewed the systems and

components credited for use during this shutdown method to verify that they would

remain free from fire damage.

Operational Implementation

The team reviewed the SSA, system flow diagrams, and the essential equipment list to

select a sample of SSD components that were required to be operable for post-fire safe

shutdown from the MCR for a postulated fire in FA A/FZ 37 and FA H/FZ 51E. The team

verified this sample by reviewing the raceway and fire zone cable routing data for the

cables associated with the selected SSD components to determine if the components

(i.e., power and/or control circuits) could be potentially damaged and made inoperable

by a fire in the fire areas selected.

The team reviewed the adequacy of procedures utilized for post-fire safe shutdown and

performed a walk-through of procedure steps to ensure the implementation and human

factors adequacy of the procedures. The team reviewed local operator manual actions

to ensure that the actions could be implemented in accordance with plant procedures in

the times necessary to support the SSD method for the applicable FA/FZ and to verify

that those actions met the criteria in Enclosure 2 of NRC IP 71111.05TTP. The team

also verified that the existing manual actions required for hot standby were specified in

the licensees SSA. The team reviewed and/or walked down applicable sections of the

following off-normal operating procedures (ONPs) for FA A/FZ 37 and FA H/FZ 51E.

• 2-ONP-100.01, Response to Fire, Rev. 17C

• 2-ONP-100.01, Appendix 37 (FA A/FZ 37), Rev. 17C

• 2-ONP-100.01, Appendix 51E (FA H/FZ 51E), Rev. 17C

The team also reviewed licensee Condition Report (CR) 2006-20062, which was initiated

to assess and track resolution of the operator manual action issue as part of the plant-

wide risk evaluation during the transition to NFPA 805.

Enclosure

5

b. Findings

No findings of significance were identified.

.02 Protection of SSD Capabilities

a. Inspection Scope

Through a combination of design information review, licensing basis information review,

and in-plant inspection, the team verified fire protection features used to protect safe

shutdown cables and components to ensure they satisfy the separation and design

requirements specified in the Branch Technical Position (BTP) Auxiliary and Power

Conversion Systems Branch (APCSB) 9.5-1, Appendix A and 10CFR50, Appendix R,

Section III.G.2 and III.G.3 and as implemented by the licensee in UFSAR Section 9.5A

and the licensees SSA. The team reviewed that portion of the SSA which listed the

credited and fire-affected equipment for the three FAs selected. This review included an

evaluation of the completeness and depth of the SSA in terms of the capacity and

capability to achieve and maintain hot shutdown and transition to cold shutdown. The

list of credited equipment in the SSA was compared to the SSD procedures. The team

verified whether the SSD procedures included these actions. The team compared the

SSA and the SSD procedure to ascertain that equipment specified in the procedure had

been addressed in the analysis. In addition, the accuracy of the SSA with regard to

determining the location of cables by fire area was inspected on a sample basis.

The team reviewed those portions of the UFSAR dealing with fire protection and safe

shutdown. One objective of this review was to evaluate the completeness and depth of

the analysis which determined the strategy for protecting the various system functions

necessary to achieve and maintain hot standby, accomplish long term cool down and

achieve cold shutdown following a severe fire.

b. Findings

No findings of significance were identified.

.03 Passive Fire Protection

a. Inspection Scope

The team inspected the material condition and fire rating of the boundaries for the

selected FAs/FZs in accordance with the requirements of 10 CFR 50, Appendix R,

Section III.G, and Appendix A of BTP APCSB 9.5-1, to ensure that they were

appropriate for the fire hazards in the area. The overall criterion applied to this element

of the inspection procedure was that the passive fire barriers had the capability to

contain fires for one hour or three hours as applicable. Fire barriers reviewed included

reinforced concrete walls/floors/ceilings, masonry block walls, Thermo-Lag 330-1 walls,

mechanical and electrical penetration seals, fire doors, and fire dampers. Fire doors

were examined for attributes such as material condition, tightness, proper operation,

Enclosure

6

Underwriters Laboratories label on door, frame, and latch, method of attachment to the

wall, etc. Construction detail drawings were reviewed as necessary.

In cases where the qualification of a fire barrier depended on engineering evaluations by

the licensee in lieu of testing, the team requested the licensee to provide those

evaluations for review. Where applicable, the team examined installed barriers to

compare the configuration of the barrier to the rated configuration. Construction details

and fire endurance test data which established the ratings of these fire barriers were

reviewed. Where applicable, fire model calculations were generated by the team using

NRC recommended computer codes to evaluate the selected barriers effectiveness to

contain potential fires. The team reviewed the station internal and external penetration

seal program and selected seals during plant walk-downs to verify that the penetration

seal engineering designs could be traced back to qualified fire tests that support the

penetration seals fire rating. The team reviewed the licensees responses (dated June

9, 2006, September 20, 2006, and December 19, 2006) to Generic Letter 2006-03,

Potentially Nonconforming HEMYC and MT Fire Barrier Configurations, to verify that

compensatory measures were in place until resolution of the degraded fire barriers is

accomplished during the licensees transition process to NFPA 805.

b. Findings

Introduction: The team identified two examples of a noncompliance of St. Lucie Nuclear

Plant, Units 1 and 2, Renewed Operating License Condition 3.E, for the licensees failure

to install a fire door with a 3-hour rating in the 3-hour fire barrier in accordance with the

UFSAR and the code of record, NFPA-80, Fire Doors & Windows - 1973 Edition. The

team also identified an example of a noncompliance of St. Lucie Nuclear Plant, Unit 2,

Renewed Operating License Condition 3.E, for the licensees failure to maintain a fire

rated barrier between the control room and a kitchen area, which is contiguous to the

control room, in accordance with the UFSAR and the code of record, NFPA-80, Fire

Doors & Windows - 1973 Edition. During the review of the Unit 1 and Unit 2 door

configurations, the team determined that the licensee did not meet one or more of the

requirements specified in NFPA 80-1973, paragraphs 2-1.7.2.1, 2-1.7.2.4, 2-1.7.2.5, 2-

1.7.7.1, and Table 2-1B.

Description: Example 1: The 8 wide by 7 height dual leaf fire doors were installed in an

Appendix R 3-hour fire barrier wall separating both Unit 1 safety related Train A

Switchgear Room from the safety related HVAC Equipment Room. The team identified

that the Unit 1 A SWGR Fire Door RA48 had been field modified from the tested

configuration to include a conductive hinge and an electric strike, voiding the

Underwriters Label. The licensee entered this noncompliance in the corrective action

program as part of CR 2009-3454.

Example 2: The 8 wide by 7 height dual leaf fire doors were installed in an Appendix R

3-hour fire barrier wall separating both Unit 2 safety related Train A Switchgear Room

from the safety related HVAC Equipment Room. The team identified the following four

issues for the Unit 2 A SWGR Fire Door RA93: (1) Fire Door RA93 has a 1-1/2 hour B

label; (2) Fire Door RA93 lockset was listed for a single fire door, not doors swinging in

pairs; (3) The latch throw depth of approximately 9/16 was insufficient for this size door

Enclosure

7

assembly which requires a minimum of 3/4 latch throw depth. (4) The bottom flush bolt

(on the inactive leaf of Fire Door RA93) was inoperable and would not engage the

associated floor strike. The licensee entered this noncompliance in the corrective action

program as part of CR 2009-3454.

Example 3: The 3 wide by 7 height door assembly is installed penetrating a fire rated

barrier wall separating the PSL Unit 2 Control Room from a kitchen area. The team

identified that a B Label fire-rated door assembly (RA110) that separates the kitchen

from the U2 main control room was found propped open by a licensee installed kick

down holder. The licensee entered this issue in the corrective action program as CR

2009-4115.

Analysis: The licensees failure to install a fire door in accordance with the approved

UFSAR is a performance deficiency. This finding is more than minor because the

installed fire doors degraded one of the fire protection defense in depth elements and

affected the reactor safety Mitigating Systems cornerstone objective. Concerning

Examples 1 and 2) the team characterized the finding as having very low safety

significance because no potential damage targets in the exposed fire areas were unique

from those in the exposing fire area, the door provides a minimum of 20 minutes fire

endurance protection, the degraded barrier will not be subjected to direct flame

impingement and there is no credible scenario by which a fire on one side of the barrier

could propagate through both degraded fire doors to affect equipment in both fire areas.

Concerning Example 3) the team characterized the finding as having very low safety

significance because the postulated worst case cooking fire (one liter of burning cooking

oil in a twelve inch diameter pan on the range top) would be of short duration (less than

three minutes). Since the control room is continuously staffed, it was likely that one of

the control room personnel would close the Fire Door (RA110) in the event of a kitchen

area fire, containing the fire in the kitchen area.

Enforcement: St. Lucie Unit 1 and 2 License Conditions 3.E states, in part, that the

licensee shall implement and maintain in effect all provisions of the approved FPP as

described in the UFSAR, and supplemented by licensee submittals dated through

February 21, 1985 for the facility; and as approved in the various NRC SERs and

supplements. The approved FPP is maintained and documented in the St. Lucie

UFSAR, Appendix 9.5A, FPP Report. PSL FSAR Appendix 9.5A, subsection 3.12.2,

Design Basis, specifies that fire doors are designed and constructed in accordance with

the requirements of NFPA 80. Per the code of record, NFPA-80 - 1973 Edition,

Paragraph 2-1.7.2.1, specifies that only labeled locks and latches or labeled fire exit

hardware (panic devices) meeting both life safety requirements and fire protection

requirements shall be used. Paragraph 2-1.7.2.4 specifies that where the inactive leaf

pairs of doors are not required for exit purposes, it shall be provided with labeled self-

latching top and bottom bolts or labeled two-point latches. Paragraph 2-1.7.2.5 specifies

that the throw of single point latch bolts shall not be less than the minimum shown on the

fire door label. If the minimum throw is not shown or the door does not bear a label the

minimum throw shall be as required in Table 2-1B. Table 2-1B, for hollow metal (flush)

doors (doors in pairs), requires an active leaf minimum latch throw of 3/4 with top and

bottom bolts on the inactive leaf. Paragraph 2-1.7.7.1, specifies that self-closing doors

are those which, when opened, return to the closed position. The door shall swing freely

Enclosure

8

and shall be equipped with a closing device to cause the door to close and latch each

time it is opened. The closing mechanism shall not have a hold-open feature

Contrary to the above, on February 12, 2009, the team identified that the licensee failed

to implement and maintain in effect all provisions of the approved fire protection

program. Specifically, the inspectors determined that the licensee had failed to install

Fire Doors RA48, RA93, and RA110 in accordance with the applicable requirements of

NFPA-80, Fire Doors & Windows - 1973 Edition, Paragraphs 2-1.7.2.1, 2-1.7.2.4, 2-

1.7.2.5, and 2-1.7.7.1.

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, this issue would have been

expected to be identified and addressed during the licensees transition to NFPA 805,

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 (Red).

.04 Active Fire Suppression

a. Inspection Scope

The teams review of active fire suppression included the fire detection systems, fire

protection water supply system, automatic fire suppression systems and manual fire

fighting fire hose and standpipe systems. The inspection of fire detection systems

included a review and walk-down of the as-built configuration of the systems as

compared to the applicable NFPA standard. In general, the acceptance criteria applied

to active fire suppression systems were contained in applicable codes and standards

listed in the Attachment as modified by the design basis documents.

The team inspected the material condition, and operational lineup of fire detection and

fire suppression systems through in-plant observation of systems, design and testing of

the sprinkler systems in reference to the applicable NFPA codes and standards. The

team also reviewed the detection and suppression methods for the category of fire

hazards in the selected FAs. Hydraulic calculations which demonstrated the fire pumps

and piping had the capacity and capability to deliver proper flow and pressure were

reviewed. The most recent flow and pressure test data were also reviewed. The

locations of sprinkler heads were observed to check for obstructions. The redundancy of

fire protection water sources and fire pumps to fulfill their fire protection function to

provide adequate flow and pressure to hose stations and automatic suppression systems

Enclosure

9

were reviewed as compared to licensing basis requirements. In addition, the team

performed inspections of smoke control equipment availability and condition, hose

station locations, hose lengths, and nozzle types. Particular attention was given to

location and capacity of hose stations and approach routes to the FAs. The hose

stations in the selected FAs were reviewed to ensure that adequate reach and coverage

could be provided. Also, the hydraulic calculation for the hose stations in the selected

FAs were reviewed to ensure that adequate water supply and pressure could be

provided to the hose nozzles that would be used to fight a fire in these FAs.

The team reviewed and walked-down operational aspects of the fire detection system

such as the location of panels and alarms. The team compared the detector layout

drawings against actual detector field locations and then reviewed those locations

against NFPA Code 72E, Automatic Fire Detectors, spacing and placement

requirements. The testing and maintenance program and its implementation for the fire

detection system were also reviewed. The team also reviewed the pre-action sprinkler

system in Reactor Auxiliary Building (RAB) Hallway. This consisted of reviewing the

system layout drawings against the field installation. In addition, the hydraulic calculation

was reviewed against the field installed configuration to ensure that the calculation

bounded the installed configuration. The team also reviewed fire brigade staffing,

training, fire brigade response strategy, pre-fire planning, fitness for duty of brigade

members, fire brigade equipment lockers, and fire brigade staging areas. The team

performed inspections of personal protective equipment and emergency lighting. The

team also reviewed fire drill reports to assess the readiness of the fire brigade to respond

to any and all fires that may occur. The team supplemented the documentation reviews

by discussions with persons responsible for fire brigade performance.

b. Findings

No findings of significance were identified.

.05 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team evaluated whether the automatic fixed sprinkler systems or manual fire fighting

activities could adversely affect the credited SSD equipment, inhibit access to alternate

shutdown equipment, and/or adversely affect the local operator actions required for SSD

in the selected fire areas. With regard to the fixed automatic sprinkler system in the Unit

2 RAB Hallway (FA H/FZ 51E), the team considered consequences of a pipe break and

inadvertent system actuation. The team also checked that sprinkler system water would

either be contained in the fire affected area or be safely drained off. The team also

addressed the possibility that a fire in one FA could lead to activation of an automatic

suppression system in another FA through the migration of smoke or hot gases, and

thereby adversely affect SSD. This portion of the inspection was carried out through a

combination of walk-downs, drawing review, and records review.

Enclosure

10

b. Findings

No findings of significance were identified.

.06 Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)

a. Inspection Scope

Methodology

The team reviewed the licensees ability to implement an alternative shutdown strategy

for a postulated fire in the MCR (FA F/FZ 42I). The team reviewed the licensees FPP

described in UFSAR Appendix 9.5A; applicable sections of the SSA; ONPs; system flow

diagrams; electrical Control Wiring Drawings (CWDs); and other supporting documents.

The reviews focused on ensuring that the required functions for post-fire SSD and the

corresponding equipment necessary to perform those functions were included in the

procedures. These inspection activities focused on ensuring the adequacy of systems

selected for reactivity control, reactor coolant makeup, reactor heat removal, process

monitoring instrumentation, and support system functions.

The team reviewed the systems and components credited for use during this shutdown

method to verify that they would remain free from fire damage. The review included

assessing whether hot and cold shutdown from outside the MCR could be implemented,

and that transfer of control from the MCR to the hot shutdown control panel (HSCP)

could be accomplished. This review also included verification that shutdown from

outside the MCR could be performed both with and without the availability of offsite

power. Plant walk-downs were performed to verify that the plant configuration was

consistent with that described in the SSA.

Operational Implementation

The team selected a sample of SSD components referenced in 2-ONP-100.02, Control

Room Inaccessibility, to determine if their electrical circuits could potentially be damaged

by a fire in the MCR. Cable routing data and CWDs were reviewed for each of the

selected SSD components. For those specific SSD components that had associated

cables routed through the selected FA, the team reviewed the CWDs to determine if

those components and associated circuits were designed to be electrically isolated from

fire damage such that they could be restored once the controls were transferred from the

MCR to the HSCP. The team also reviewed cable routing data for a sample of process

monitoring instrument channels with indicators located on the HSCP to verify that they

would be unaffected by a fire in the selected FA. In addition to the above, the team

reviewed surveillance test records of the most recent functional testing performed on the

transfer switches and circuits used to transfer electrical controls from the MCR to the

HSCP. The completed test procedures and test records were reviewed to ensure that

adequate tests were performed to verify the functionality of the alternative shutdown

capability. The components and documents reviewed are listed in the Attachment.

The team reviewed training lesson plans and job performance measures for licensed

and non-licensed operators to verify that the training reinforced the shutdown

Enclosure

11

methodology in the SSA and ONPs for the selected FZ. The team also reviewed shift

turnover logs and shift manning to verify that personnel required for SSD using the

alternative shutdown systems and procedures were available on-site, exclusive of those

assigned as fire brigade members. In addition to the above, the team reviewed

procedure 2-ONP-100.02 and performed a walk-through of procedure steps to ensure

the implementation and human factors adequacy of the procedure. The team also

reviewed selected operator manual actions to verify that the operators could reasonably

be expected to perform the specific actions within the time required to maintain plant

parameters within specified limits. Time critical actions reviewed included: electrical

power distribution alignment, establishing control at the HSCP, establishing reactor

coolant makeup, and establishing decay heat removal.

b. Findings

Introduction: The team identified a noncompliance of very low safety significance of St.

Lucie Unit 2 Technical Specification 6.8.1.a, for inadequate procedural guidance related

to the use of procedure 2-ONP-100.02, Control Room Inaccessibility. 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.

Description: The team walked-down procedure 2-ONP-100.02 with licensee operations

personnel. This procedure would be utilized to safely shut down the plant from the

HSCP in the event of a fire in the MCR (FA F/FZ 42I) that rendered the MCR

uninhabitable. Appendix B of the procedure directed operators to perform actions to

support operation from the HSCP. During the walk-down of procedure 2-ONP-100.02,

Appendix B, the team identified several deficiencies in the procedure guidance. The first

deficiency involved Appendix B, steps 7 and 8, which directed local closure of main

feedwater isolation valves HCV-09-1A and HCV-09-2A. To accomplish these steps,

personnel fall protection safety equipment would be required. Appendix B did not

identify that fall protection equipment was needed, nor did it identify that a key was

needed to unlock the padlock to access the locker where the fall protection equipment

was stored. The team observed that in order to accomplish these steps, personnel fall

protection safety equipment would be needed, in accordance with the requirements of

licensee procedure ADM-04.02, Industrial Safety Program. The second deficiency

involved Appendix B, step 13, which directed local closure of valve MV-09-14, (2B to 2A

AFW Pump Disch Cross-Tie). Local operation of this valve required use of a key.

Appendix B did not identify that a key was required to operate valve MV-09-14 locally.

The third deficiency involved Appendix B, step 13, which directed manual valves V09136

(2B AFW Pump to 2B S/G FW Isol) and V09158 (2C AFW Pump to 2B S/G FW Isol) to

be locked closed. The team observed during the procedure walk-down that these

manual valves were padlocked open, consistent with the system flow diagrams.

Appendix B did not identify that a key was required to locally reposition these padlocked

open manual valves. The team noted that these deficiencies could potentially delay

operator actions required to bring the plant to SSD conditions at the HSCP. The team

discussed these deficiencies with licensee personnel who initiated CRs 2009-2590 and -

2592 and took actions to place the additional keys in the MCR that were required by the

procedure. Also, procedure changes were processed to provide guidance to identify the

Enclosure

12

need for fall protection equipment and keys to perform SSD actions. The team

concluded that given these procedure deficiencies, and, based on their experience and

training, it was likely plant operators would be able to take the appropriate actions within

the time required to ensure post-fire SSD conditions.

Analysis: The failure to include necessary information in procedure 2-ONP-100.02 for

performance of certain operator manual actions to support operation from the HSCP

during post-fire SSD conditions is a performance deficiency. This noncompliance is

considered to be more than minor because it is associated with the procedure quality

attribute of the Mitigating Systems cornerstone and it affected the cornerstone objective

of protection against external events such as fire. The team assessed the

noncompliance using IMC 0609, Appendix F, Fire Protection Significance Determination

Process. This noncompliance was determined to be of very low safety significance

(Green) using Appendix F of the SDP, because it did not adversely affect components

credited for reactivity control, reactor coolant makeup, reactor heat removal, and support

systems functions. The team considered this noncompliance to be low degradation

because, based on their experience and training, it was likely plant operators would have

been able to take the appropriate actions within the time required to ensure post-fire

SSD conditions.

Enforcement: 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

Enclosure

13

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.

.07 Circuit Analyses

a. Inspection Scope

In accordance with IP 71111.05TTP, this segment is suspended for plants in transition

because a more detailed review of cable routing and circuit analysis will be conducted as

part of the fire protection program transition to NFPA 805. However, to support this

inspection a limited scope review of a select sample of SSD components was conducted

to verify that the existing fire response procedures were adequate for a postulated fire in

any of the selected FAs. The cables examined were based upon a list of SSD

components selected by the team. The team reviewed the electrical CWDs and

identified the cables associated with the SSD components and examined in detail the

cable routing and potential for fire damage and the effects on the circuit. The specific

components reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

.08 Communications

a. Inspection Scope

The team reviewed the plant communications systems that would be relied upon to

support fire event notification and fire brigade fire fighting activities to verify their

availability at different locations, for fire event notification, and fire brigade fire fighting

activities. The team reviewed both fixed and portable communication systems to

evaluate the capability of each system to support plant personnel in the performance of

local operator manual actions to achieve and maintain SSD conditions. Both fixed and

portable communication systems were also reviewed for the impact of fire damage in the

selected fire areas/zones. During this review, the team considered the effects of

ambient noise levels, the clarity of reception, the availability at designated locations,

reliability ensured through periodic testing, and that batteries were maintained

sufficiently charged. The team conducted the inspection of communications through a

combination of in-plant observations, drawing and records review, and interviews.

The team reviewed the radio battery usage ratings for the radios stored and maintained

on charging stations for operator use while performing the SSD procedure. The team

also reviewed preventative maintenance and surveillance test records to verify that the

communication equipment was being properly maintained. The team also reviewed

selected fire brigade drill evaluation/critique reports to assess proper operation and

effectiveness of the fire brigade command post portable radio communications during

fire drills and identify any history of operational or performance problems with radio

communications during fire drills. The team compared statements made by operations

Enclosure

14

personnel regarding which communication system they would use with commitments in

the UFSAR concerning communications for post-fire SSD.

b. Findings

No findings of significance were identified.

.09 Emergency Lighting

a. Inspection Scope

The team reviewed the 8-hour emergency lighting system to verify that it was in

accordance with 10 CFR 50.48; Renewed Operating License Condition 3.E for Unit 1

and Unit 2; NRC SERs; and the UFSAR. The team reviewed maintenance and design

aspects of the emergency lighting units (ELUs) required by 10 CFR 50, Appendix R,

Section III.J. The portable eight-hour battery-powered emergency lights are credited in

the licensee FPP for use during the performance of operator manual actions in outdoor

areas, and for access and egress routes. This review also included examination of

whether backup ELUs were provided for the primary and secondary fire emergency

equipment storage locker locations and dress-out areas in support of fire brigade

operations should power fail during a fire emergency.

The team performed plant walk-downs of selected areas for local manual operator

actions identified in the post-fire SSD procedures to observe the placement, alignment

and coverage area of fixed eight-hour battery pack emergency lights throughout the FAs.

The team also performed walk-downs to evaluate the fixed ELUs adequacy for

illuminating access and egress pathways and any equipment requiring local operation

and/or instrumentation monitoring for post fire safe shutdown for the selected FAs/FZs.

The team also observed whether emergency exit lighting was provided for personnel

evacuation pathways to the outside exits as identified in the NFPA 101, Life Safety

Code, and the Occupational Safety and Health Administration Part 1910, Occupational

Safety and Health Standards.

Preventive maintenance procedures and completed surveillance tests were reviewed to

ensure adequate surveillance testing and periodic battery replacements were in place to

ensure reliable operation of the fixed and portable emergency lights. The team also

reviewed the system health reports and discussed the maintenance rule status of the

emergency lighting systems. The team reviewed test records for the past year of

periodic maintenance functional tests, as well as the annual capacity tests, to confirm

that the batteries were being properly maintained and had the capacity to supply eight

hours of lighting. The team reviewed the maintenance work requests and work order

records that had been initiated for the identified test failures to verify that the deficiencies

were properly corrected. The manufacturers information and vendor manuals for the

fixed and portable 8-hour battery pack ELUs were reviewed to verify that the battery

power supplies were rated with at least an 8-hour capacity as described in UFSAR

Section 9.5A. The team reviewed the availability of the portable eight-hour battery

powered emergency lights located in storage lockers throughout the plant.

Enclosure

15

b. Findings

Introduction: The NRC identified two examples of a Green non-cited violation (NCV) of

St. Lucie Unit 1 and Unit 2 Renewed Operating License Conditions 3.E for the licensees

failure to promptly correct conditions adverse to quality. The first example involved

failure to take prompt corrective action for a noncompliance that was identified during the

2006 TFPI (IR 05000335, 389/2006010). Specifically, the licensee did not implement

corrective actions to perform surveillance tests on the Unit 1 eight-hour battery powered

portable emergency lights. The licensee entered this issue into their corrective action

program; however no corrective actions were implemented to resolve this issue. The

second example involved four eight-hour battery powered fixed emergency lights that

failed an annual eight-hour discharge surveillance test and were not repaired or

replaced.

Description: The licensees FPP (UFSAR Appendix 9.5A) credits the use of fixed and

portable eight-hour battery-powered ELUs during the performance of post-fire SSD

procedures. Section 7.5 of Appendix 9.5A discussed the inspection and testing

requirements of the FPP and listed emergency lighting as being subjected to periodic

inspections and/or testing.

Example One: In October of 2006, during the 2006 TFPI, NRC inspectors identified that

the licensee failed to perform surveillance tests on the Unit 1 eight-hour battery-powered

portable ELUs. The licensee entered this issue into their corrective action program as

CR 2006-29459. During the 2009 TFPI, NRC inspectors requested to review corrective

actions for CR 2006-29459 and the completed eight-hour discharge test procedures for

the portable eight-hour ELUs. The licensee provided CR-2006-29459, which included an

engineering evaluation determining that an eight-hour annual discharge test is required

on all portable ELUs. The licensee concluded that they did not have a surveillance test

procedure for the portable ELUs. The licensee further stated that a battery discharge test

had not been performed to demonstrate the eight-hour battery capability of the portable

emergency lights because the corrective actions from CR 2006-29459 had been closed

in the CR program without an action to develop a test procedure. The licensee initiated

CRs 2009-4010 and -4056 to implement corrective actions for not testing the lights and

further address this issue.

Example Two: On February 9, 2009, NRC inspectors reviewed the 2008 completed

eight-hour discharge surveillance tests for the fixed eight-hour ELUs. The inspectors

identified that four fixed emergency lights (EL-2-004, EL-2-19-002, EL-2-39-001, and EL-

2-20-003) had failed the surveillance test on December 31, 2007, and corrective actions

to repair or replace the failures had not been implemented.

On February 12, 2009, the team reviewed the licensees 2008 fourth quarter system

health reports and other maintenance documents for the 120V/208V electrical system,

which included the fixed Appendix R emergency lighting units. There were

approximately 100 ELUs for each operating unit. Inspectors reviewed adverse trend CR

2008-3563 which identified 13 open work orders for emergency lighting deficiencies on

Unit 1 and 26 open work orders for lighting deficiencies on Unit 2. These deficiencies

included the four fixed emergency lights (EL-2-004, EL-2-19-002, EL 2-39-001, and EL

Enclosure

16

2-20-003) that had failed the surveillance test on December 31, 2007. The fixed

Appendix R eight-hour ELUs were within the scope of the licensees

Maintenance Rule program because these units are relied upon and used in plant

emergency operating procedures. The licensees Maintenance Rule program adopted

the industry goal of having less than 10% deficient but has not established performance

criteria. The licensees failure to implement corrective actions on both occasions was

attributed to deficiencies in the maintenance program. The four failed fixed ELUs

remained in their degraded condition for over 13 months and maintenance personnel

had not repaired or replaced the units. The licensee developed a corrective action plan

to provide a preventive maintenance procedure to perform an annual eight-hour

discharge test for the portable emergency lights; however maintenance personnel closed

the action with a statement that the procedure will not be revised and no further action

was performed. This is contrary to the licensees corrective action program and

accepted maintenance practices. Inspectors determined that the cause of the finding

was directly related to the licensee not planning and coordinating work activities to

support long-term equipment reliability and their maintenance scheduling was more

reactive than preventive. The licensee initiated CRs 2009-4220 and 2009-6720 to

address this issue.

Analysis: The inspectors determined that the licensees failure to promptly correct a

condition adverse to quality on two occasions was a performance deficiency because

the licensee is required to comply with Unit 2 Renewed Operating License Conditions

3.E and it was within the licensees ability to foresee and correct. The finding is more

than minor because it is associated with the reactor safety, mitigating systems,

cornerstone attribute of protection against external factors (i.e., fire) and it affects the

objective of ensuring reliability and capability of systems that respond to initiating events.

The inspectors determined that this finding was of very low safety significance, Green,

because the degradation of safe shutdown functions was low and the operators were

likely to complete the task using flashlights.

The cause of the finding was evaluated against IMC 0305 Operating Reactor

Assessment Program and determined to have a cross-cutting aspect in the area of

Human Performance. The licensees failure to implement corrective actions on both

occasions was attributed to deficiencies in the maintenance program. In the first

example, the licensee developed a corrective action plan to provide a preventive

maintenance procedure to perform an annual eight hour discharge test for the portable

emergency lights; however maintenance personnel closed the action with a statement

that the procedure would not be revised and no further action was performed. In the

second example, the four failed fixed ELUs remained in their degraded condition for over

13 months and maintenance had not repaired or replaced the units. The finding was

directly related to the Work Control aspect of the Human Performance Cross-Cutting

Area in that the licensee did not plan and coordinate work activities to support long-term

equipment reliability and their maintenance scheduling was more reactive than

preventive. (H.3 (b)).

Enforcement: St. Lucie Units 1 and 2 Renewed Operating License Conditions 3.E

requires that the licensee implement and maintain in effect all provisions of the approved

FPP as described in the UFSAR, and as approved by various NRC SERs. The

Enclosure

17

approved FPP is maintained and documented in the UFSAR, Appendix 9.5A. Section

8.0 of Appendix 9.5A, Quality Assurance Program, states, in part, that the QA Program

is discussed in section 17.2 of the UFSAR, which was revised and approved by the

NRC. UFSAR Section 17.2 states, FPL Quality Assurance Topical Report (QATR),

describes the methods and establishes quality assurance program and administrative

control requirements. FPL QATR, Revision 3 states, In establishing requirements for

corrective actions, FPL commits to compliance with NQA-1, 1994, Basic Requirements

15 and 16 and Supplement 15S-1. NQA-1 Basic Requirement 16, Corrective Action,

states, conditions adverse to quality shall be identified promptly and corrected as soon

as practical.

Contrary to the above, as of February 12, 2009, the licensee failed to promptly identify

and correct conditions adverse to quality for the two examples as indicated below:

• Since October of 2006, the licensee failed to implement corrective actions to

adequately test eight-hour battery powered portable emergency lights identified in IR

05000335, 389/2006010, as required.

• Since December 31, 2007, the licensee failed to implement corrective actions to

repair or replace four fixed emergency lights that had failed the eight-hour discharge

surveillance test, as required (EL-2-004, EL-2-19-002, EL 2-39-001, and EL 2-20-

003).

The licensee initiated CRs 2009-4010, -4056, -4220, and -6720 to implement corrective

actions. Because this finding was of very low safety significance (Green), and was

entered into the licensees corrective action program, this violation is being treated as an

NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy and is identified as

NCV 05000335, 389/2009007-01, Failure to Correct Conditions Adverse to Quality.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed the licensees cold shutdown repairs that were addressed in the FPP

procedures. Based on this review, the team confirmed that procedures and equipment

for achieving and maintaining post-fire hot shutdown did not rely on cold shutdown

repairs.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

Enclosure

18

The team reviewed the administrative controls for out-of-service, degraded, and/or

inoperable fire protection features (e.g., detection and suppression systems and

equipment, passive fire barriers, or pumps, valves or electrical devices providing SSD

functions or capabilities). The team reviewed selected items on the fire protection

impairment log and compared them with the FAs/FZs selected for inspection. The

compensatory measures that had been established in these areas/zones were

compared to those specified for the applicable fire protection feature to verify that the

risk associated with removing the fire protection feature from service was properly

assessed and adequate compensatory measures were implemented in accordance with

the approved FPP. Additionally, the team reviewed the licensees short term

compensatory measures (e.g., the hourly fire watch established for the degraded Fire

Door RA93 in the A SWGR Room) to verify that they were adequate to compensate for

a degraded function or feature until appropriate corrective actions could be taken, and

that the licensee was effective in returning the equipment to service in a reasonable

period of time.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The team reviewed selected CRs related to the St. Lucie FPP to verify that items related

to fire protection and SSD were appropriately entered into the licensees corrective

action program in accordance with the licensees quality assurance program and

procedural requirements. This review was conducted to assess the frequency of fire

incidents and effectiveness of the fire prevention program and any maintenance-related

or material condition problems related to fire incidents.

The team reviewed recent independent licensee audits for thoroughness, completeness

and conformance to requirements. The team also reviewed other CAP documents,

including completed corrective actions documented in selected WRs and operating

experience program documents to verify that industry-identified fire protection issues

potentially or actually affecting St. Lucie were appropriately entered into, and resolved

by, the CAP process. Items included in the OEP effectiveness review were NRC

Information Notices, industry or vendor-generated reports of defects and non-

compliances submitted pursuant to 10 CFR 21, and vendor information letters.

Additionally, the team reviewed a sample of other issues discussed in system health

reports. The team evaluated the effectiveness of the corrective actions for the identified

issues. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

Enclosure

19

4OA3 Event Follow-up

a. Inspection Scope

The status of Licensee Event Report (LER) 2006-005-00 was reviewed during this

inspection. This LER involved the internal conduit penetration seals that are not

bounded by fire testing and the lack of regular inspection of the seals condition. To

resolve the issues identified in this LER, the licensee performed a comprehensive field

walk-down to document the as-built configuration/condition of the seals and had a fire

test conducted to determine the performance of various seal configurations. The fire test

demonstrated the viability of the stations penetration seal designs. This has enabled the

station to reduce the number of seals that need to be upgraded to those that are not

bounded by test configuration and/or seals that are in a degraded condition. At the time

of the inspection, field work to upgrade/repair seals had not been performed and the

work still in the planning stages. During the inspection, the inspectors reviewed a

sample of internal conduit penetration seals to determine the comprehensiveness of the

licensees plan to resolve this issue. At the conclusion of the walk-down it was

determined that the licensees resolution plan was thorough and comprehensive. This

LER will remain open pending resolution during NFPA 805 transition.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On February 12, 2009, the lead inspector presented the inspection results to Mr. G.L.

Johnston, Site Vice President, St. Lucie Nuclear Plant, and other members of St. Lucie

staff. The licensee acknowledged the findings. Proprietary information is not included in

this report. Following completion of additional review in the Region II office, another exit

meeting was held by telephone with Mr. Katzman, Licensing Manager, and other

members of the St. Lucie staff on April 30, 2009, to provide an update on changes to the

preliminary inspection findings. The licensee acknowledged the findings.

Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel:

E. Armando, Site Quality Manager

P. Barnes, Mechanical Supervisor, Design Engineering

D. Cecchett, Licensing Engineer

R. Conrad, Fire Protection Engineer, Design Engineering

J. Connor, Engineering Manager - Programs

T. Cosgrove, Site Engineering Director

C. Costanzo, Plant General Manager

M. Delowery, Maintenance Manager

R. Dorst, Fire Protection

K. Frehafer, Licensing Engineer

D. Fuca, Quality Supervisor

M. Hicks, Operations Manager

D. Huey, Acting Work Control Manager

G. Johnston, Site Vice President

E. Katzman, Licensing Manager

R. McDaniel, Fire Protection Supervisor

L. Neely, Work Control Manager

W. Parks, Operations Manager

T. Patterson, Performance Improvement Manager

J. Porter, Design Engineering Manager

V. Rubano, Engineering Fire Protection Chief Engineer

S. Short, Electrical Supervisor, Design Engineering

G. Swidder, System Engineering Manager

B. Tremayne, Senior Reactor Operator

M. Verbeck, Training Supervisor

NRC Personnel

R. Croteau, Deputy Division Director, Division of Reactor Safety, RII

T. Hoeg, Senior Resident Inspector, St. Lucie Nuclear Plant

S. Sanchez, Resident Inspector, St. Lucie Nuclear Plant

S. Walker, Fire Protection Team Leader, RII

G. Crespo, Senior Reactor Inspector-In Training

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000335, 389/2009007-01 NCV Failure to Correct Conditions Adverse to Quality (Section

1R05.09)

Discussed

05000335, 389/2006005-00 LER Internal Conduit Penetration Seals Outside Appendix R

Design Basis

Closed

None

Attachment

LIST OF FIRE BARRIER FEATURES INSPECTED

(Refer Report Section 1RO5.02- Passive Fire Barriers)

Fire Door Identification Description

Door RA 110 FA: F/FZ: 42I MCR U2

Door RA 93 FA: A/FZ: 37 A SWGR U2

Door RA 48 FA: A/FZ: 60 A SWGR U1

Door RSDRA 91 FA: A/FZ: 37 A SWGR U2

Door RSDRA 47 FA: A/FZ: 60 A SWGR U1

Fire Damper Identification

FDPR-25-120

FDPR-25-122

FDPR-25-123

FDPR-25-132

FDPR-25-13

FDPR-25-110

FDPR-25-107

Fire Barrier Penetration Seal Identification

C5/SL-31 L5/SL-1

C5/SL-32 L5/SL-2

C5/SL-33 L5/SL-3

C5/SL-34 L5/SL-4

C5/SL-35 L5/SL-5

11561M-3 (C5) L5/SL-6

11558A-3 (C5) L5/SL-7

L5/SL-11 L5/SL-18

L5/SL-12 L5/SL-19

L5/SL-13 L5/SL-20

L5/SL-14 L5/SL-21

C5/SL-36

C5/SL-37 15013G-3(C5)

C5/SL-38 15003J-3(SA)(L5)

10176U-2(C5)

Attachment

THE FOLLOWING SSD PROCEDURES WERE REVIEWED AND WALKED THROUGH

(Refer Report Section 1R05.05 - Operational Implementation etc.)

LIST OF COMPONENTS REVIEWED

SSD Components Examined for Cable Routing - Sections 1R05.01 / Section 1R05.06

Valves

MV-09-9, AFWP 2A Discharge to SG 2A

1-SE-09-2, AFWP 2A Discharge to SG 2A

V-1474, Pressurizer PORV

V-1475, Pressurizer PORV

MV-08-18A, SG 2A Atmospheric Steam Dump

Pump Motors

AFW Pump 2A

ICW Pump 2A

Pressurizer Heaters

Pressurizer Heater Transformer 2A3

Pressurizer Heater Transformer 2B3

Instruments

LI-1105, Pressurizer Level

PT-1108, Pressurizer Pressure

LT-9012, SG 2A Level

TI-1125-1, RC Loop Temperature

PIC-08-1A1, SG 2A ATM STM Dump

PT-1105/1106, Pressurizer Pressure Low Range

PT-1103/1104, Pressurizer Pressure Low Range

Fans

2HVS-5A, Electrical Equipment Room Supply Fan

Attachment

LIST OF DOCUMENTS REVIEWED

List of CRs Generated During this Inspection

CR 2006-26459, There is No 8 Hour Test Data Available for Portable Handheld Lights

CR 2006-28784, Missed Non-Tech Spec Surveillance on Unit 1

CR 2006-29158, Clarify Requirements for Testing Sound Powered Phones

CR 2006-29744, Inadequate Updating of PSL-ENG-SEES-98-039, Rev. 3, Evaluation of

the St. Lucie Plant 10CFR, Appendix R 8-Hour Batter-Packed Emergency Lighting

Requirements

CR 2006-35505, No Data to Prove the Portable Emergency Lights Have Been Tested

CR 2007-8751, Unit 2 Sound Powered Phone Deficiencies

CR 2008-21225, Sound Powered Phone Jack Does Not Work

CR 2009-2254, Procedure 2-ONP-100.01, Response to Fire Appendix 37 A Switchgear Room

indicates that both Pressurizer level instruments LI-1110X and LI-1110Y are not protected for

use in fire zone 37 (A switchgear room) and reliability cannot be assured.

CR 2009-2260, During the review for the triennial fire protection inspection a discrepancy has

been discovered between the information in the Unit 2 safe shutdown analysis and the

response to fire procedure 2-ONP-100.01 Appendix 37.

CR 2009-2263, Procedure 2-GOP-305 step 6.23.2 A and B doesnt indicate that there are 4

fuses to install on pressurizer low range pressure indicators.

CR 2009-2385, Procedure 2-ONP-100.02 Enhancements

CR 2009-2405, During a walk-down with the NRC for cables associated with LI-1110Y it was

discovered that cable 20090E does not enter fire zone 37 as listed in CARS cable by fire zone

report.

CR 2009-2586, Procedure 2-ONP-100.02 Appendices A, B, C, D validation times after

procedure revision per CR 2008-23665

CR 2009-2590, Procedure 2-ONP-100.02 Appendix B enhancements identified

CR 2009-2592, Fall protection issue identified during 2-ONP-100.02 walk-down

CR 2009-3754, Drawing Errors Identified

CR 2009-3843, Typographical Errors identified in PSL-FPER-05-048

CR 2009-4027, Sprinker system 2F Hydraulics Documents not Identified or Reviewed

CR 2009-4010, The portable emergency lights have not been 8-hour discharge tested on an

annual basis as was required by CR 2006-35505.

CR 2009-4055, Time critical testing of operator manual actions not consistently applied to both

Units JPMs for 2-ONP-100.02 Appendices A, B, C, D

CR 2009-4056, CR 2006-35505 Action #2 was closed without taking any action, changing the

CR evaluation or providing a link to any additional actions.

CR 2009-4115, Kitchen Door in MCR found to be not in Accordance with SER Oct. 1981

CR 2009-4220, Failed to provide fixed 8 hr. emergency lights in accordance with SL2 UFSAR

App. 9.5A Section 3.7.2

CR 2009-6720, Assess Appendix R E-Light Performance Criteria for Maintenance Rule.

CRs Reviewed During Inspection

CR 2006-20062, NRC Regulatory Issue Summary: Regulatory Expectations with Appendix R

Paragraph III.G.2 Operator Manual Actions

2007-31402, Aux Spray Valve SE-02-4 Failed Stroke Time

CR 2008-23665, Time critical actions of 1-ONP-100.02 Cannot Be Completed in Time

CR 2008-26101, Cable Spreading Room Fire Dampers25-117, 25-118 and 25-119 Failed to

Close following Halon System Discharge during Tropical Storm Fay, August 19, 2008.

CR 2008-29442, Fire Pump 1A Breaker Trip, Fire Pump 1B Auto Start and Fire System

Hydraulic Pressure Surge, September 23, 2008

Attachment

2

Procedures

ADM-04.02, Industrial Safety Program, Rev. 11A

AP-0010434, Plant Fire Protection Guidelines, Rev. 42

EPIP-01, Classification of Emergencies, Rev. 16

IMP-15.01, Smoke Detector Testing, Rev. 13

JPM 0821001, Perform RCO A Actions IAW CRI ONP, App A-Unit 2 HSCP, Rev. 14

JPM 0821091, Perform US Actions During CRI-Unit 2, Cable Spreading Room, A/B Switchgear

Rooms, HSCP-Unit 2, Rev. 16

JPM 0821139T, Implement EPIP for a Control Room Fire, Simulator/In-Plant, Rev. 13

JPM 0821194TA, Perform RCO B Actions During CRI-Unit 2 Turbine Bldg, Rev. 2

0-PME-50.10, Self Contained Emergency Lighting Unit Maintenance and Inspection,

Rev.1

1-OSP-61.01, Control Room Telephone Communication Checks, Rev. 1C

2-FME-15.02, 12 Month Operability Test of the Fire Protection Sprinkler System for the Unit 2

RAB, Rev. 0

2-EMP-15.03, Annual Testing of the Unit 2X Type Heat detection Instrumentation, Rev. 0D

2-M-0018F, Mechanical Maintenance Preventive Maintenance Program, (Fire PMs), Rev. 33

2-MMP-100.18B, Fire Valve Preventive Maintenance (PM), Rev. 4D

2-1800023, Unit 2 Fire Fighting Strategies, Rev. 28

2-0120034, Reactor Coolant Pump Operation, Rev. 35

2-ONP-02.03, Charging and Letdown, Rev. 15B

2-ONP-100.01, Response to Fire, Rev. 17C

2-ONP-100.02, Control Room Inaccessibility, Rev. 22

2-ONP-100.02, Control Room Inaccessibility, Rev. 22

2-OSP-100.15, Remote Shutdown Monitoring Monthly Channel Check, Rev. 11

2-ADM-03.01G, Unit 2 Power Distribution Breaker List AC Power Panels, 120 VAC

Regulated Vital AC Bus 2A-1, Rev. 0

2-OSP-61.01, Control Room Telephone Communication Checks, Rev. 1C

2-OSP-61.02, Sound Powered Phone Communication Test, Rev. 0

Completed Surveillance Test Procedures and Test Records

2-OSP-61.02, Sound Powered Phone Communication Test, Rev. 0, Completed

06/27/2008

2-OSP-61.02, Sound Powered Phone Communication Test, Rev. 0, Completed

03/27/2007

2-OSP-100.16, Remote Shutdown Components 18 Month Functional Test, Completed 12/31/07

2-OSP-100.16, Remote Shutdown Components 18 Month Functional Test, Completed 12/31/06

Work Orders (WO)

WO 36027455-01, Sound Powered Phone System Perform PM

WO 37024006-01, U2 E-Lights Annual Discharge (4th Quarter)

WO 37027742-01, U2 E-Lights Annual Discharge (2nd Quarter)

WO 37020814-01, U2 E-Lights Annual Discharge (1st Quarter)

WO 38007047-01, U2 E-Lights Annual Discharge (3rd Quarter)

WO 38015559-01, Neither Sound Powered Phone Ckt 1 or 2 Works

WO 38018289-01, U2 Appendix Emergency Light Monthly PM

WO 38020851-01, U2 Appendix Emergency Light Monthly PM

WO 38025276-01, U2 Appendix R Emergency Light Monthly PM

Attachment

3

Calculations, Analyses and Evaluations

07-0444, PM Program Change Request, Add the Portable Handheld Emergency lights to U1

Appendix R Emergency Lighting PM

00105.01.0115-CALC-2998, Unit 2, System 2F Remote Area and Additions, Rev. 0

ENG-SPSL-02-0124, St. Lucie Unit 2, Disposition of Unit 2 Detection System

Nonconformances, PSL-FPER-00-004, Rev. 1

ENG-SPSL-06-0234, Response to GL 2006-03, Potentially Nonconforming Hemyc and MT Fire

Barrier Configurations

PSL-BFSM-98-004, St. Lucie Units 1 & 2 - Hose Station Supply Piping (Standpipes) Hydraulic

Analysis, Rev. 0

PSL-ENG-SEMS-98-067, Unit 2 Appendix R Validation Effort Safe Shutdown Analysis, Rev. 3

PSL-FPER-99-011, Disposition of Unit 2 NFPA 13 Code Nonconformances, Rev. 1

PSL-FPER-08-081, Ceramic Fiber & Mastic Internal Conduit Seals - Evaluation of 3 Hour Fire

Rated Qualification, Rev. 0

2998-B-048, St. Lucie Unit 2 Appendix R Safe Shutdown Analysis, Rev. 16

Flow Drawings

2998-G-078, Sheet 107, Flow Diagram Reactor Coolant System, Rev. 12

2998-G-078, Sheet 108, Flow Diagram Reactor Coolant System, Rev. 5

2998-G-078, Sheet 109, Flow Diagram Reactor Coolant System, Rev. 18

2998-G-078, Sheet 110, Flow Diagram Reactor Coolant System, Rev. 8

2998-G-078, Sheet 120, Flow Diagram Chemical & Volume Control System, Rev. 18

2998-G-078, Sheet 121A, Flow Diagram Chemical & Volume Control System, Rev. 31

2998-G-078, Sheet 121B, Flow Diagram Chemical and Volume Control System, Rev. 29

2998-G-078, Sheet 122, Flow Diagram Chemical and Volume Control System, Rev. 25

2998-G-079, Sheet 1, Flow Diagram Main Steam System, Rev. 1

2998-G-079, Sheet 2, Flow Diagram Main Steam System, Rev. 36

2998-G-080, Sheet 1A, Flow Diagram Condensate System, Rev. 46

2998-G-080, Sheet 1B, Flow Diagram Condensate System, Rev. 47

2998-G-080, Sheet 2A, Flow Diagram Feedwater & Condensate System, Rev. 43

2998-G-080, Sheet 2B, Flow Diagram Feedwater & Condensate System, Rev. 36

2998-G-083, Sheet 1, Flow Diagram Component Cooling System, Rev. 41

2998-G-083, Sheet 2, Flow Diagram Component Cooling System, Rev. 40

Fire Protection

2998-C-124 Sh. FP-4, Hose Station HS-15-40 Isometric Piping Drawing, Rev. 4, January 14,

1983.

2998-G-165 Sh. 1, Reactor Auxiliary Building El. 62.0 & 74.0, Fire Doors, Dampers & Sprinkler

System, Rev. 7, October 15, 2001.

2998-G-165 Sh. -2, Reactor Auxiliary Building El. 43.0, Fire Doors, Dampers & Sprinkler

System, Rev. 6, July 18, 2001.

2998-G-165 Sh. 3, Reactor Auxiliary Building El. 19.5, Fire Doors, Dampers & Sprinkler

System, Rev. 9, June 5, 2007.

2998-G-413 Sh. 2, Reactor Auxiliary Building, Fire Detection System Conduit Layout, El. 19.5,

Rev. 10, March 1, 2002.

2998-G-413 Sh. 3, Reactor Auxiliary Building, Fire Detection System Conduit Layout, El. 43.0,

Rev. 11, March 1, 2002.

2998-G-413 Sh. 7, Reactor Auxiliary Building, Fire Detection System Conduit Layout, El. 62.0,

Rev. 10, August 13, 2007.

2998-G-424 Sh. 2, Fire Protection Reactor Aux. Bldg. El. 19.5, Fire Detectors and Emergency

Lights, Rev. 9, June 2, 2000.

Attachment

4

2998-G-424 Sh. 3, Fire Protection Reactor Aux. Bldg. El. 43.0, Fire Detectors and Emergency

Lights, Rev. 7, June 2, 2000.

2998-G-424 Sh. 4, Fire Protection Reactor Aux. Bldg. El. 62.0 & 74.0, Fire Detectors and

Emergency Lights, Rev. 7, October 7, 2008.

2998-15743, Reactor Auxiliary Building, System 2F, Cable Loft Area, , El. 19.5, Rev. 5,

January 11, 1989.

2998-15843, Reactor Auxiliary Building, Piping for Valve Headers at Elevations (-) 0.5, 19.5 &

43.0, Rev. 8, January 22, 1985.

2998-16010, Reactor Auxiliary Building, System 2F, El. 19.5, Rev. 3, January 10, 1984.

2998-B-327, Sheet 852, Fire Water Pumps 1A and 1B, Rev. 8, dated 4/25/1988

8770-B-327, Sheet 852, Fire Water Pump 1A, Rev. 14, dated 11/27/1994

8770-B-327, Sheet 853, Fire Water Pump 1B, Rev. 16, dated 01/28/1986

2998-G-333, Sheet 2, Communications System, Rev. 7, dated 08/13/2007

JPN-095-295-111, Sheet 1, Reactor Aux. Building El.43.00 Communication System Embedded

CND Layout, Rev. 0, dated 09/18/1995

JPN-095-295-113, Reactor Aux. Building El.43.00 Communication System Exposed Conduit

Layout, Rev. 0, dated 09/18/1995

JPN-095-295-103, Sheet 2, Communications System, Reactor Auxiliary Building Rev. 0, dated

09/18/1995

JPN-095-295-108, Sheet 37, Reactor Aux. Building El.43.00 Conduit Layout, Rev. 0, dated

09/18/1995

JPN-095-295-110, Sheet 6H, Reactor Aux. Building Conduit Layout Sections and Details,

Rev. 0, dated 09/18/1995

FSA-2998-E-036, Sheet 2055, Communications System Connection Diagram, Rev. 4,dated

06/03/1985

FSA-2998-E-039, Sheet 206, Sound Power Wiring Diagram

2995-B-327, Sheet 1201, Page and Party Line Communication System, Rev. 8,dated

04/18/2000

FSG-2998-E-015, SH 2, Sheet 3 of 4, Reactor Aux. Building EL. 43.00 Communications

System Exposed Conduit Layout, Rev. 6, dated 08/10/1989

FSG-2998-E-015, SH 2, Sheet 4 of 4, Reactor Aux. Building EL. 43.00 Communications

System Exposed Conduit Layout, Rev. 6, dated 08/10/1989

Control Wiring Diagrams

2998-B-327, Sheet 131, 480V Pressurizer Heater Bus 2A3, Rev. 7

2998-B-327, Sheet 132, 480V Pressurizer Heater Bus 2B3, Rev. 7

2998-B-327, Sheet 136, Reactor Coolant Loop Temp Ch. T-1111Y, T-1111X & T-1115, Rev. 18

2998-B-327, Sheet 137, Reactor Coolant Loop Temp Ch. T-1121Y, T-1121X & T-1125, Rev. 19

2998-B-327, Sheet 165, Boric Acid Gravity Feed Valve V-2508, Rev. 14

2998-B-327, Sheet 166, Boric Acid Gravity Feed Valve V-2509, Rev. 11

2998-B-327, Sheet 177, Charging Pump 2A, Rev. 21

2998-B-327, Sheet 189, AUX Spray Valves I-SE-02-3 & I-SE-02-4, Rev. 9

2998-B-327, Sheet 369, Steam Generators 2A/2B Pressure & Level, Rev. 12

2998-B-327, Sheet 370, Pressurizer Pressure & Level, Rev. 12

2998-B-327, Sheet 476, Electrical Equipment Room Supply Fan 2HVS-5A, Rev. 20

2998-B-327, Sheet 603, STM GEN 2A & 2B ATM STM Dump, Rev. 15

2998-B-327, Sheet 608, AUX FWP 2A Discharge To STM GEN 2A MV-09-9, Rev. 14

2998-B-327, Sheet 627, Feedwater Regulating System 2A&2B Flow Indication, Rev. 17

2998-B-327, Sheet 629, Auxiliary Feedwater Pump 2A, Rev. 23

2998-B-327, Sheet 832, Intake Cooling Water Pump 2A, Rev. 20

Attachment

5

2998-B-327, Sheet 1626, STM GEN 2A ATM STM DUMP VALVE MV-08-18A, Rev. 12

2998-B-327, Sheet 1629, Relief Valve V-1474, Rev. 10

2998-B-327, Sheet 1630, Relief Valve V-1475, Rev. 10

2998-B-327, Sheet 1631, AFWP 2A DISCH TO SG 2A I-SE-09-2, Rev. 11

2998-B-327, Sheet 943, PRESS HTR. TRANSF 2A3 4160V FDR BKR, Rev. 17

2998-B-327, Sheet 944, PRESS HTR. TRANSF 2B3 4160V FDR BKR, Rev. 18

Completed Surveillance or Test

Fire Drill 09-08-98, Unit 2, 2A3 Load Center.

Fire Drill 04-30-99, Unit 2, RAB HVE-13A.

Fire Drill 09-12-03, Unit 2, RAB 19.5 Drumming Room.

Fire Drill 05-05-05, Unit 2, RAB 19.5 Drumming Room.

Fire Drill, 12-18-06, Unit 2, RAB 19.5 Drumming Room.

FPSP-15.01, Penetration Seal Inspection, Performed: 2006

FPSP-15.01, Penetration Seal Inspection, Performed: 2007

FPSP-15.01, Fire Barrier Inspection, Performed: 2006

FPSP-15.01, Fire Barrier Inspection, Performed: 2007

FPSP-15.01, ERFBS Inspection, Performed: 2006

FPSP-15.01, ERFBS Inspection, Performed: 2007

2-M-0018F, Fire Door Inspection, 2007

2-EMP-15.02, Sprinkler System Inspection, Performed: 2007

2-EMP-15.02, Sprinkler System Inspection, Performed: 2008

2-EMP-15.03, Detection System Inspection, Performed: 2007

2-EMP-15.03, Detection System Inspection, Performed: 2008

OSP-15.15A, Fire Pump Inspection, Performed 2005

OSP-15.15A, Fire Pump Inspection, Performed 2007

OSP-15.15B, Fire Pump Inspection, Performed 2005

OSP-15.15B, Fire Pump Inspection, Performed 2007

OSP-15.16, Annual Flush, Performed 2007

OSP-15.16, Annual Flush, Performed 2008

OSP-15.17, Triennial Flow Test, Performed 2003

OSP-15.17, Triennial Flow Test, Performed 2006

Miscellaneous

Drawing No. 2998-B-049, St. Lucie Unit 2 Essential Equipment List, Rev. 9

Unit 1 System Health Report 10/01/2008 - 12/31/2008, System 48, 120V/208V Electrical

System

Unit 2 System Health Report 10/01/2008 - 12/31/2008, System 48, 120V/208V Electrical

System

Licensing Basis Documents

AP-1800022 FP Plan, Fire Protection Plan, Rev. 43, July 24, 2008

SLS2, UFSAR Chapter 9.5A Fire Protection Program Report, Amendment 18, January 2008

NUREG-0843, St. Lucie Unit 2 Safety Evaluation Report (SER), October 1981

FPL Quality Assurance Topical Report (QATR), Rev. 3

UFSAR Appendix 9.5A, Fire Protection Program Report

UFSAR Section 17.2, Quality Assurance During The Operating Phase

Unit 1 License Condition 2.C(3), Fire Protection

9.5A Section 8.0, Quality Assurance Program

Unit 2 License Condition 2.C(20), Fire Protection

Attachment

6

Technical Specifications 3.3.3.5.a and b, Remote Shutdown System Instrumentation Limiting

Conditions for operation

Technical Specifications 4.3.3.5.1 and 2, Remote Shutdown System Surveillance Requirements

Technical Specification Table 3.3-9, List of Remote Shutdown System Instrumentation

Technical Specification Table 4.3-6, List of Remote Shutdown Monitoring Instrumentation

Surveillance Requirements

Applicable Codes and Standards

NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 1973 Edition

NFPA 13, Standard for the Installation of Sprinkler Systems, 1973 Edition

NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1973 Edition

NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1982 Edition

NFPA 72A, Standard for the Installation, Maintenance, and Use of Proprietary Protection

Signaling Systems, 1972 Edition

NFPA 80, Fire Doors & Windows, 1973 Edition

NFPA 101, Life Safety Code

Technical Manuals and Vendor Information

Streamlight LiteBox Rechargeable Lantern, Rev 1

Streamlight LiteBox/FireBox Rechargeable Operating Instructions, Rev. A

Carpenter/atek Emergency Lighting, F5 Series - Portable Emergency Lighting

Dual-Lite Spectron Series Emergency Lighting Equipment

Intertek Report No. 3148622, Ceramic Fiber & FlameSafe S105 Cable Sealant Compound, 3

Hour Fire Resistance Test, December 11, 2008

Dow Corning Corporation, Material Safety Data Sheet, Dow Corning (R) 561 Silicone

Transformer Liquid, MSDS No.: 01496204, December 6, 2002

Audits and Self Assessments

QRNO 08-0107, Fire Protection, Fire Water Pump Motors, September 19, 2008.

Attachment

LIST OF ACRONYMS AND ABBREVIATIONS

ANSI American National Standards Institute

APCSB Auxiliary and Power Conversion Systems Branch

BTP Branch Technical Position

CAP Corrective Action Program

CFR Code of Federal Regulations

CR Condition Report (a corrective action program document)

CWDs Control Wiring Diagrams

ELU Emergency Lighting Unit

ERFBS Electrical raceway Fire Barrier

FA Fire Area

FHA Fire Hazards Analysis

FZ Fire Zone

FPP Fire Protection Program

HSCP Hot Shutdown Control Panel

IR Inspection Report

IP Inspection Procedure

LER Licensee Event Report

MCR Main Control Room

NFPA National Fire Protection Association

NRC Nuclear Regulatory Commission

NUREG An explanatory document published by the NRC

OSHA Occupational Safety and Health Administration

PSL Plant St. Lucie

RAB Reactor Auxiliary Building

Rev. Revision

ROP Reactor Oversight Process

SDP Significance Determination Process

SER Safety Evaluation Report

SSA Safe Shutdown Analysis

SSD Safe Shutdown

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

Attachment