ML082910633

Notification of Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(c) Is in Progress (NRC Inspection Report 050000335-09-007, 05000389-09-007)

ML082910633
Person / Time
Site:	Saint Lucie
Issue date:	10/17/2008
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Stall J Florida Power & Light Co
References
IR-09-007
Download: ML082910633 (9)

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

October 17, 2008

Florida Power and Light Company

ATTN: Mr. J.A. Stall

Sr. Vice President - St. Lucie Plant

St. Lucie Nuclear Power Plant

P. O. Box 1400

Juno Beach, Florida 33408-0420

SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS

(NRC INSPECTION REPORT 05000335/2009007, 05000389/2009007)

Dear Mr. Stall:

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

Power Plant, Unit 1 in January and February of 2009. The inspection will be led by

Mr. Necota Staples, NRC Reactor Inspector, of the Region II Office. The team will be

composed of personnel from the NRC Region II Office. The inspection will be conducted in

accordance with Inspection Procedure 71111.05TTP, the NRCs baseline fire protection

inspection procedure for plants in the process of implementing 10 CFR 50.48(c) and National

Fire Protection Association Standard (NFPA) 805. The inspection guidance is different from the

regular triennial inspections, in that the inspectors will concentrate on the fire protection program

infrastructure and the adequacy of compensatory measures implemented for identified

departures from code requirements. Inspection of circuit analysis is not included in the

inspection procedure; however, electrical topics will be addressed by the team.

On October 15, 2008, during a telephone conversation, between Mr. Don Cecchett, of your

staff, and Mr. Necota Staples, of the NRC Region II Office, 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: January 06 - 08, 2009

• Week 1 of onsite inspection: January 26 - 30, 2009

• Week 2 of onsite inspection: February 09 - 13, 2009

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

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

fire protection program, fire protection features, post-fire shutdown capabilities, and plant layout.

The types of documents the team will be interested in reviewing, and possibly obtaining, are

listed in the Enclosure. Please contact Mr. Staples prior to preparing copies of the materials

listed in the Enclosure. The inspection team will try to minimize your administrative burden by

specifically identifying those documents required for inspection preparation.

FP&L 2

During the information gathering visit, the team will also discuss the following administrative

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

arrangements for reactor site access (including 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 Power

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

to the team for its review. Of specific interest are those documents which establish that your fire

protection program satisfies NRC regulatory requirements and conforms to applicable NRC and

industry fire protection guidance. 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 Power Plant fire protection program and its

implementation.

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

concerning this inspection, or the inspection teams information or logistical needs, please

contact Mr. Staples at (404) 562-4644, or me at (404) 562-4530.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure 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

(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/

Rebecca Nease, Branch Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-335, 50-389

License Nos.: DPR-67, NPF-16

Enclosure: Triennial Fire Protection Inspection Support Documentation

cc w/encl: (See page 3)

FP&L 3

cc w/encl:

Gordon L. Johnston Craig Fugate

Site Vice President Director

St. Lucie Nuclear Plant Division of Emergency Preparedness

Electronic Mail Distribution Department of Community Affairs

Electronic Mail Distribution

Michael Page

Operations Manager (Acting) J. Kammel

St. Lucie Nuclear Plant Radiological Emergency Planning

Electronic Mail Distribution Administrator

Department of Public Safety

Christopher R. Costanzo Electronic Mail Distribution

Plant General Manager

St. Lucie Nuclear Plant Douglas Anderson

Electronic Mail Distribution County Administrator

St. Lucie County

Eric Katzman 2300 Virginia Avenue

Licensing Manager Ft. Pierce, FL 34982

St. Lucie Nuclear Plant

Electronic Mail Distribution Mano Nazar

Senior Vice President and Nuclear Chief

Abdy Khanpour Operating Officer

Vice President Florida Power & Light Company

Engineering Support Electronic Mail Distribution

Florida Power and Light Company

P.O. Box 14000 Senior Resident Inspector

Juno Beach, FL 33408-0420 St. Lucie Nuclear Plant

U.S. Nuclear Regulatory Commission

Don E. Grissette P.O. Box 6090

Vice President, Nuclear Operations - South Jensen Beach, FL 34957-2010

Region

Florida Power & Light Company Peter Wells

Electronic Mail Distribution (Acting) Vice President, Nuclear

Training and Performance Improvement

M. S. Ross Florida Power and Light Company

Managing Attorney P.O. Box 14000

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

Electronic Mail Distribution

Mark E. Warner

Marjan Mashhadi Vice President

Senior Attorney Nuclear Plant Support

Florida Power & Light Company Florida Power & Light Company

Electronic Mail Distribution Electronic Mail Distribution

William A. Passetti

Chief

Florida Bureau of Radiation Control

Department of Health

Electronic Mail Distribution

October 17, 2008

Florida Power and Light Company

ATTN: Mr. J.A. Stall

Sr. Vice President - St. Lucie Plant

St. Lucie Nuclear Power Plant

P. O. Box 1400

Juno Beach, Florida 33408-0420

SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS

(NRC INSPECTION REPORT 05000335/2009007, 05000389/2009007)

Dear Mr. Stall:

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

Power Plant, Unit 1 in January and February of 2009. The inspection will be led by

Mr. Necota Staples, NRC Reactor Inspector, of the Region II Office. The team will be

composed of personnel from the NRC Region II Office. The inspection will be conducted in

accordance with Inspection Procedure 71111.05TTP, the NRCs baseline fire protection

inspection procedure for plants in the process of implementing 10 CFR 50.48(c) and National

Fire Protection Association Standard (NFPA) 805. The inspection guidance is different from the

regular triennial inspections, in that the inspectors will concentrate on the fire protection program

infrastructure and the adequacy of compensatory measures implemented for identified

departures from code requirements. Inspection of circuit analysis is not included in the

inspection procedure; however, electrical topics will be addressed by the team.

On October 15, 2008, during a telephone conversation, between Mr. Don Cecchett, of your

staff, and Mr. Necota Staples, of the NRC Region II Office, 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: January 06 - 08, 2009

• Week 1 of onsite inspection: January 26 - 30, 2009

• Week 2 of onsite inspection: February 09 - 13, 2009

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

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

fire protection program, fire protection features, post-fire shutdown capabilities, and plant layout.

The types of documents the team will be interested in reviewing, and possibly obtaining, are

listed in the Enclosure. Please contact Mr. Staples prior to preparing copies of the materials

listed in the Enclosure. The inspection team will try to minimize your administrative burden by

specifically identifying those documents required for inspection preparation.

During the information gathering visit, the team will also discuss the following administrative

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

arrangements for reactor site access (including 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.

__ __

OFFICE RII:DRS RII:DRS RII:DRP

SIGNATURE SWalker /RA/ /RA/

NAME N. STAPLES S. WALKER R. NEASE

DATE 10/15/2008 10/15/2008 10/15/2008

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

FP&L 4

Letter to J.A. Stall from Rebecca Nease dated October 17, 2008

SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS

(NRC INSPECTION REPORT 05000335/2009007, 05000389/2009007)

Distribution w/encl:

RIDSNRRDIRS

PUBLIC

B. Mozafari, NRR (PM: STL, TP)

Triennial Fire Protection Inspection Support 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 CD/DVD-ROM. The CD/DVD-ROM should be indexed and hyperlinked to

facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM 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 Fire Protection Program document and the Fire Hazards Analysis.

2. The Fire Protection Program implementing procedures (e.g., administrative controls,

surveillance testing, fire brigade).

3. The fire brigade training program document and the pre-fire plans for the selected fire

areas/zones (to be determined during information gathering visit).

4. The post-fire safe shutdown analysis, including system and separation analyses.

5. The alternative shutdown analysis.

6. Piping and instrumentation (flow) diagrams for the fire suppression systems.

7. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires involving shutdown from

the control room.

8. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires in areas requiring

alternative or dedicated shutdown capability.

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

standby and cold shutdown equipment.

10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas

protected by automatic fire suppression and detection, and the locations of fire

protection equipment for the selected fire areas/zones (to be determined during

information gathering visit).

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

lighting units.

12. Plant operating procedures that describe and are used to shutdown from inside the

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

Enclosure

2

13. Plant operating procedures used to implement the alternative shutdown capability from

outside the control room with a fire in either the control or cable spreading room (or any

other alternative shutdown area).

14. Maintenance and surveillance testing procedures for alternative shutdown capability

(including Appendix R emergency lights and communication systems) and fire barriers,

detectors, fire pumps and fire suppression systems.

15. Calculations and/or justifications that verify fuse/breaker coordination for the selected fire

areas/zones (to be determined during information gathering visit) that are fed off the

same electrical buses as components in the protected train. Also, a list of the

maintenance procedures used to routinely verify fuse/breaker coordination in

accordance with the post-fire safe shutdown coordination analysis.

16. A list of the significant fire protection and post-fire safe shutdown design change

descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter

(GL) 86-10 evaluations.

17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R,

Section III.G) used to achieve regulatory compliance for the selected fire areas/zones (to

be determined during information gathering visit). That is, please specify whether 3-hour

rated fire barriers (Section III.G.2.a), 20-foot separation along with detection and

suppression (Section III.G.2.b), 1-hour rated fire barriers with detection and suppression

(Section III.G.2.c), or alternative shutdown capability (Section III.G.3) is used for the

selected fire areas/zones.

18. Procedures or instructions that govern the implementation of plant modifications,

temporary modifications, maintenance, and special operations, and their impact on fire

protection.

19. Organization chart(s) of site personnel down to the level of the fire protection staff.

20. Procedures or instructions that control the configuration of the fire protection program,

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

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

features and evaluations of code deviations (i.e., a listing of the NFPA code editions

committed to (Code of Record)).

22. The three most recent fire protection QA audits and/or fire protection self-assessments.

23. A list of open and closed fire protection problem identification and resolution reports

[also known as action reports/condition reports/problem investigation

reports/NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the

past three years.

24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and

change evaluations which form the licensing basis for the facilitys post-fire safe

shutdown configuration).

Enclosure

3

25. A list of fire protection or Appendix R calculations.

26. A list of fire impairments identified during the previous year.

27. A list of abbreviations/designators for plant systems.

Enclosure