ML19071A090

Notification of Conduct of a Triennial Fire Protection Baseline Inspection - U. S. Nuclear Regulatory Commission Inspection Report Nos. 05000335/2019011 and 05000389/2019011

ML19071A090
Person / Time
Site:	Saint Lucie
Issue date:	03/12/2019
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Nazar M Florida Power & Light Co
References
IR 2019011
Download: ML19071A090 (15)

See also: IR 05000335/2019011

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

March 12, 2019

Mr. Mano Nazar

President and Chief Nuclear Officer

Nuclear Division

Florida Power & Light Co.

Mail Stop: EX/JB

700 Universe Blvd.

Juno Beach, FL 33408

SUBJECT: ST. LUCIE PLANT - NOTIFICATION OF CONDUCT OF A TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION - U. S. NUCLEAR REGULATORY

COMMISSION INSPECTION REPORT NOS. 05000335/2019011 AND

05000389/2019011

Dear Mr. Nazar:

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

staff will conduct a triennial fire protection baseline inspection at the St. Lucie Plant beginning

on June 17, 2019. Mr. Philipp Braaten, Reactor Inspector, will be the inspection team leader

from the NRC Region II office. The additional team members will be composed of personnel

from the NRC Region II office. The inspection will be conducted in accordance with IP 71111.05XT, the NRC's baseline fire protection inspection procedure, dated January 31, 2013.

On February 28, 2019, during a telephone conversation between Mr. Richard Sciscente,

Licensing, and Mr. Philipp Braaten, our respective staff confirmed arrangements for an

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

inspection is as follows:

• Information gathering visit: May 28 - May 30, 2019

• Week 1 of onsite inspection: June 17 - June 21, 2019

• Week 2 of onsite inspection: July 8 - July 12, 2019

The purpose of the information gathering visit is to obtain information and documentation

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

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

strategies to address Title 10 of the Code of Federal Regulations (10 CFR) Section

50.54(hh)(2), and, as necessary, obtain plant specific site access training and badging for

unescorted site access.

An initial list of the documents the team will review during the conduct of the inspection is listed

in Enclosures 1 and 2. The team leader will contact you with any additional specific document

requests prior to the information-gathering visit.

M. Nazar 2

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

administrative details: office space and location; specific documents requested to be made

available to the team in their office spaces; arrangements for reactor site access (including

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

availability of knowledgeable plant staff and licensing organization personnel to serve as points

of contact during the inspection.

We request that during the on-site inspection weeks you ensure that copies of analyses,

evaluations, or documentation regarding the implementation and maintenance of the station fire

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

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

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

requirements and conforms to applicable NRC and industry fire protection guidance (i.e., fire

protection compliance assessment documents). For the 10 CFR 50.54(hh)(2) portion of the

inspection, those documents implementing your mitigating strategies and demonstrating the

management of your commitments for the strategies are of specific interest. Also, personnel

should be available at the site during the inspection who are knowledgeable regarding those

plant systems required to achieve and maintain safe shutdown conditions from inside and

outside the control room, including the electrical aspects of the relevant post-fire safe shutdown

analyses, reactor plant fire protection systems and features, and the station fire protection

program and its implementation.

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

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

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

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

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

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

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

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

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

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

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

M. Nazar 3

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

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

contact Philipp Braaten, the team leader in the Region II office at 404-997-4651 or me at 404-

997-4521.

Sincerely,

/RA/

Scott M. Shaeffer, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos: 50-335, 50-389

License Nos: DPR-67, NPF-16

Enclosures:

1. Triennial Fire Protection Inspection Supporting

Documentation

2. Mitigating Strategies Supporting Documentation

cc: Distribution via Listserv

_ ML19071A090 _ SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DRS/EB2 RII:DRS/EB2

SIGNATURE PJB4 SMS

NAME P. BRAATEN S. SHAEFFER

DATE 03/ 8 /2019 03/ 12 /2019 3/ /2019 3/ /2019 3/ /2019 3/ /2019

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

TRIENNIAL FIRE PROTECTION INSPECTION SUPPORTING DOCUMENTATION

The documents and information requested below should generally be made available to the

inspection team during the on-site information-gathering visit for the team's use both on-site and

off-site during the inspection. Electronic format is the preferred media, except where specifically

noted. If electronic media is made available via an internet based remote document

management system, then the remote document access must allow inspectors to download,

save, and print the documents in the NRC's regional office. Electronic media on compact disc

or paper records (hard copy) are acceptable. At the end of the inspection, the documents in the

team's possession will not be retained.

Approximately three weeks before the on-site information-gathering visit, the following

documents should be made available to the team leader for review in the regional office:

• Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (request A.1)

• Fire Hazards Analysis and/or NFPA 805 Design Basis Document (request A.2)

• Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA Document

(request A.3)

• NFPA 805 Transition Report, developed in accordance with NEI 04-02 (request A.4)

• Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3) (request A.5)

• Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4) (request A.6)

• Analysis that demonstrates nuclear safety performance criteria can be achieved and

maintained for those areas that require recovery actions (request A.7)

Based on review of the above seven documents, team leader should identify a preliminary list of

fire areas being considered for inspection prior to the on-site information gathering visit. During

the information-gathering visit, or shortly thereafter, the fire areas selected for inspection will be

determined.

This document request is based on typical documents that a generic plant might have. As such,

this generic document request is not meant to imply that any specific plant is required to have all

of the listed documents. It is recognized that some documents listed below may not be

available for your plant. In addition, the document titles listed below are based on typical

industry document names; your plant specific document titles may vary.

Enclosure 1

2

A. DESIGN AND LICENSING BASIS DOCUMENTS

A.1 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis.

A.2 Fire Hazards Analysis and/or NFPA 805 Design Basis Document.

A.3 Fire PRA Summary Document or full PRA Document (if summary document not

available).

A.4 NFPA 805 Transition Report developed in accordance with NEI 04-02.

A.5 Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3).

A.6 Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4).

A.7 Analysis that demonstrates nuclear safety performance criteria can be achieved and

maintained for those areas that require recovery actions.

A.8 Fire Protection Program and/or Fire Protection Plan.

A.9 LIST of post-fire safe shutdown components (i.e., safe shutdown equipment list).

A.10 Fire Protection System Design Basis Document.

A.11 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of

record).

A.12 LIST of deviations from (a) NFPA codes of record, or (b) NFPA 805 fundamental fire

protection program and design elements (i.e., NFPA 805, Chapter 3).

A.13 NFPA Compliance Review Report.

A.14 Report or evaluation that compares the fire protection program to the NRC Branch

Technical Position (BTP) 9.5-1 Appendix A.

A.15 COPY of licensee submittals and NRC safety evaluation reports that are specifically

listed in the facility operating license for the approved fire protection program.

A.16 COPY of NRC Safety Evaluation Reports that form the licensing basis for:

• Fire Protection Program; and

• Post-fire Nuclear Safety Capability Assessment.

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A.17 COPY of NRC approved exemptions for plant fire protection and post-fire nuclear

safety capability features.

A.18 COPY of exemption requests submitted but not yet approved for plant fire protection

and post-fire nuclear safety capability features.

A.19 LIST of nuclear safety capability design changes completed in the last three years

(including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).

A.20 Facility Operating License.

A.21 Technical Specifications (electronic format only).

A.22 Technical Requirements Manual (electronic format only).

A.23 Updated Final Safety Analysis Report (electronic format only).

B. GENERAL PLANT DESIGN DOCUMENTS

B.1 Piping and instrumentation diagrams (P&IDs) and legend list for components used to

achieve and maintain nuclear safety performance criteria for (C-size paper drawings

& electronic format)

• Fires outside the main control room; and

• Fires in areas requiring recovery actions at other than primary control stations.

B.2 P&IDs and legend list for fire protection systems, including fire water supply, water

suppression sprinklers & deluge, and CO2 and Halon systems (C-size paper

drawings & electronic format).

B.3 Yard layout drawings for underground fire protection buried piping (C-size paper

drawings & electronic format).

B.4 AC and DC electrical system single line diagrams, from off-site power down to the

highest safety-related bus level (typically 4kV, EDG bus) (C-size paper drawings &

electronic format).

B.5 Single line diagrams for motor control centers (MCCs) that supply post-fire nuclear

safety component loads (only for selected fire areas) (C-size paper drawings &

electronic format).

B.6 Equipment location drawings, which identify the physical plant locations of, post-fire

nuclear safety capability equipment (electronic format).

B.7 Plant layout drawings, which identify the following (electronic format):

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• Plant fire area boundaries;

• Combustible control zone drawings;

• Areas protected by automatic fire suppression and detection; and

• Locations of fire protection equipment.

C. CLASSIC FIRE PROTECTION

C.1 COPY of fire protection program implementing procedures (e.g., administrative

controls, surveillance testing, fire brigade).

C.2 LIST of calculations and engineering analyses, studies, or evaluations for the fire

protection system, including the fire water system.

C.3 Hydraulic calculation or analysis for fire protection water system.

C.4 Last two completed surveillance's of fire protection features in the selected fire areas

(detection, suppression, damper inspections, damper tests, penetration inspections,

barrier inspections, etc.).

C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps,

including pump controllers and batteries.

C.6 Last two completed annual fire pump pressure and flow tests.

C.7 Last two completed monthly and/or quarterly fire pump tests.

C.8 Last two completed fire loop flow tests and loop flushes.

C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate

concentrations and soak or hold times can be achieved (only for selected fire areas).

C.10 Last five hot work permits (at power).

C.11 Last five transient combustible permits (at power).

C.12 For Fire Brigade Drills, provide the following:

• Last five fire brigade drill critiques;

• Last drill critique for a drill with off-site fire department support;

• Last unannounced drill critique;

• Last back-shift drill critique;

• Dates, shifts, and locations of unannounced drills for last three years;

• Summary of any unsatisfactory drill performance items for last three years; an

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• Last unannounced drill critique by a qualified individual independent of the

licensee's staff.

C.13 For fire brigade equipment, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

C.14 Fire Brigade Qualifications, including self-contained breathing apparatus (SCBA) and

training lesson plans.

C.15 COPY of the mutual aid agreement for the first-due local fire department that is

currently in effect.

C.16 COPY of the evaluation or analysis of the effects of fire suppression activities on the

ability to achieve the nuclear safety performance criteria (only for selected fire areas),

including:

• An automatic or manually actuated suppression system, due to a fire in a single

location, will not indirectly cause damage to the success path; and

• inadvertent actuation or rupture of a suppression system will not indirectly cause

damage to the success path; and

• demonstration of adequate drainage for areas protected by water suppression

systems;

• hydrostatic rating of any floor penetration seals installed within the fire areas that

are credited with keeping water from leaking into fire areas below.

C.17 Pre-fire plans for all fire areas.

C.18 For Emergency Lighting Units (ELU), provide the following:

• COPY of performance based emergency light assessments;

• LIST of Preventive Maintenance tasks, frequencies, and bases;

• Most recently performed monthly or quarterly functional test;

• Most recently performed battery discharge performance test;

• ELU battery loading analysis;

• vendor manual(s) for on-site inspector use;

• results of black-out testing (if performed);

• Maintenance Rule program information related to the ELU; and

• Compensatory measures taken when ELU are out of service

C.19 Impairment Log (at start of inspection), for fire protection features that are out of

service.

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C.20 Three Fire Protection screening reviews for recent design changes, modifications, or

temporary modifications (i.e., an NFPA 805 plant change evaluation that screened

out).

C.21 LIST of penetration seal work, re-work, or installation activities, in the last three years.

C.22 LIST of fire wrap work, re-work, or installation activities, in the last three years.

C.23 Fire protection system health reports for the two most recent quarters.

C.24 Fire protection program health report for the two most recent quarters.

C.25 Emergency lighting system health reports for the two most recent quarters.

C.26 LIST of fire protection system design changes completed in the last three years

(including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).

C.27 LIST of fire protection system NFPA 805 engineering equivalency evaluations

completed in the last three years.

C.28 Licensee evaluation of industry operating experience, such as:

(Specific items to be selected by the inspector)

• NRC IN 2005-03, Inadequate Design and Installation of Seismic-Gap Fire Barriers;

• NRC IN 2006-22, Ultra-Low Sulfur Diesel Fuel Oil Usage, for diesel fire pump;

• NRC IN 2009-02, Bio-Diesel Fuel Oil Usage, for diesel fire pump; and

• NRC IN 2009-29, Fire Pumps Fail to Start due to a Fire.

C.29 COPY of any test, surveillance, or maintenance procedure (current revision),

including any associated data forms, for any requested "last performed" test,

surveillance, or maintenance.

D. ELECTRICAL

D.1 Identify whether the cables in the selected fire areas are predominantly Thermoset or

Thermoplastic. Specifically identify any Thermoplastic cable in the selected fire

areas.

D.2 Nuclear safety circuit coordination analysis for fuse and breaker coordination of

nuclear safety capability components.

D.3 Administrative or configuration control procedures that govern fuse replacement (e.g.,

fuse control procedures).

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D.4 Maintenance procedures that verify breaker over-current trip settings to ensure

coordination remains functional, for post-fire nuclear safety capability components.

D.5 Electrical system health reports for the two most recent quarters.

D.6 Last surveillance demonstrating operability of those components operated from the

primary control stations.

D.7 LIST of post-fire nuclear safety capability system and component design changes

completed, in the last three years.

D.8 LIST of identified fire induced circuit failure configurations (only for selected fire

areas).

E. OPERATIONS

E.1 LIST of calculations and engineering analyses, studies, or evaluations for the nuclear

safety capability methodology.

E.2 LIST of licensed operator Job Performance Measures (JPMs) for operator actions

required to achieve and maintain post-fire nuclear safety performance criteria.

E.3 LIST of non-licensed operator training associated with non-licensed operator actions

to achieve and maintain post-fire nuclear safety performance criteria (including JPMs,

in-field training walkdowns, simulations, or initial qualification).

E.4 Lesson plans for post-fire nuclear safety capability training for licensed and non-

licensed operators.

E.5 For recovery actions, provide the following:

• Manual Action Feasibility Study;

• Operator Time Critical Action Program;

• Time lines for time-critical recovery actions; and

• Time line validations.

E.6 Thermal hydraulic calculation or analysis that determines the time requirements for

time-critical manual operator actions.

E.7 Operating procedures to achieve and maintain nuclear safety performance criteria

from the control room, with a postulated fire in the selected fire areas.

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E.8 Operating procedures to achieve and maintain nuclear safety performance criteria

from outside the control room, with a postulated fire in the control room, cable

spreading room, or any area requiring recovery actions (other than recovery actions

performed in the control room or primary control stations).

E.9 For safe shutdown equipment and tools, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

E.10 LIST of procedures that implement Cold Shutdown Repairs.

E.11 For Cold Shutdown Repairs, provide the following:

• Procedure for inventory and inspection (i.e., needed tools, material, etc.); and

• Most recent inspection and inventory results.

E.12 For Radio communications, provide the following:

• Communications Plan for firefighting and post-fire safe shutdown manual actions;

• Repeater locations;

• Cable routing for repeater power supply cables;

• Radio coverage test results; and

• Radio Dead Spot locations in the plant.

E.13 Environmental and habitability evaluations for post-fire operator actions (temperature,

smoke, humidity, SCBAs, etc.).

F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS

F.1 Corrective actions for fire-induced circuit failures (including but not limited to NRC

IN 92-18), both single and multiple spurious actuations (only for selected fire areas).

F.2 Corrective actions associated with operator actions to achieve and maintain post-fire

nuclear safety performance criteria.

F.3 Self-assessments, peer assessments, and audits of fire protection activities for the

last three years.

F.4 Self-assessments, peer assessments, and audits of post-fire nuclear safety capability

methodology for the last three years.

F.5 LIST of open and closed condition reports for the fire protection system for the last

three years.

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F.6 LIST of fire event analysis reports for the last three years.

F.7 LIST of open and closed condition reports for emergency lighting units for the last

three years.

F.8 LIST of open and closed condition reports for post-fire nuclear safety capability issues

for the last three years. This includes issues affecting the nuclear safety capability

analysis, fire hazards analysis, NFPA 805 design basis, fire risk evaluations, plant

change evaluations, post-fire operating procedures and/or training, timeline

evaluations for operator actions, and supporting engineering evaluations, analysis, or

calculations.

F.9 LIST of procedures that control the configuration of the fire protection program,

features, and post-fire nuclear safety capability methodology and system design.

MITIGATING STRATEGIES SUPPORTING DOCUMENTATION

Mitigating Strategies Supporting Documentation

G. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS

G.1 LIST of all changes to regulatory commitments made to meet the requirements of

Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2).

G.2 LIST of procedures and guidelines that were revised or generated to implement the

mitigating strategies. These could be extensive damage mitigation guidelines

(EDMGs), severe accident management guidelines (SAMGs), emergency operating

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

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

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

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

to implement each strategy.

G.4 LIST of engineering evaluations or calculations that were used to verify the

engineering bases for the mitigating strategies.

G.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow

diagrams for systems relied upon in the mitigating strategies. These could be the

type used for training (C-size paper drawings).

G.6 LIST of modification packages or summary descriptions of modifications with

simplified drawings, for necessary facility changes to implement the mitigating

strategies.

G.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and

tools needed to implement 10 CFR 50.54(hh)(2) strategies.

G.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,

provide the following:

• Procedures for inventory and inspection; and

• Most recent inspection and inventory results.

G.9 LIST of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details that

differ from that documented in the submittals or the safety evaluation reportH.10

Site general arrangement drawings that show the majority of buildings and areas

referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings and electronic

copy).

Enclosure 2

2

G.10 Site general arrangement drawings that show the majority of buildings and areas

referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings).

G.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2).

G.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments)

required to implement any mitigating strategies.