ML060540308

Notice of Enforcement Discretion (NOED) for Florida Power and Light Regarding St. Lucie Unit 2

ML060540308
Person / Time
Site:	Saint Lucie
Issue date:	02/22/2006
From:	Travers W D Region 2 Administrator
To:	Stall J A Florida Power & Light Co
References
NOED 06-2-01, TAC MD0052
Download: ML060540308 (5)

Text

February 22, 2006Florida Power and Light CompanyATTN:Mr. J. A. Stall, Senior Vice PresidentNuclear and Chief Nuclear OfficerP. O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR FLORIDA POWERAND LIGHT REGARDING ST. LUCIE UNIT 2 [TAC NO. MD0052, NOED NO. 06-2-01]

Dear Mr. Stall:

By letter dated February 17, 2006, you requested that the NRC exercise discretion to notenforce compliance with the actions required in St. Lucie Unit 2 Technical Specification (TS) 3.6.1.7 Action c, which required a plant shutdown if repair of an 8-inch containment purgesupply isolation valve could not be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Your letter documented information discussed with the NRC in a teleconference on February 15, 2006 in which yourequested a NOED be granted pursuant to the NRC's policy regarding exercise of discretion foran operating facility, set out in Section VII.C, of the NRC Enforcement Policy, and be effectivefor the period from 4:10 p.m., on February 15, 2006, to March 24, 2006. This letter documentsour telephone conversation of February 15, 2006 at 2:00 p.m., wherein the NRC verballygranted discretion from TS LCO 3.6.1.7 Action c. The principal NRC staff members who participated in the telephone conference included: (1) from Region II - Charles Casto, Director, Division of Reactor Projects (DRP); Joseph Shea, Deputy Director, DRP; Son Ninh, Senior Project Engineer, DRP Branch 3; Rudy Bernhard, Senior Reactor Analyst; Tom Morrissey, Acting Senior Resident Inspector - St. Lucie and (2) from the Office of Nuclear Reactor Regulation - Catherine Haney, Director, Division of Reactor Licensing; Michael Marshall, Chief, Plant Licensing Branch 2-2; Brendan Moroney, Project Manager, St. Lucie; Harold Chernoff, lead Project Manager for NOEDs; James Pulsipher, Reactor Systems Engineer, Containment and Ventilations Systems Branch; and Robert Palla, Senior Reactor Engineer.On February 14, 2006, at 4:10 p.m. Unit 2 inboard 8-inch containment purge supply isolationvalve, FCV-25-36, failed a routine local leak rate test (LLRT) required by TS surveillance4.6.1.7.4, due to the failure of a shear pin that uncoupled the actuator from the valve stem andwas declared inoperable. TS 4.6.1.7.4 states " at least once per 92 days, each 8-inchcontainment purge supply and exhaust isolation valve with resilient material seals shall bedemonstrated OPERABLE by verifying that the measured leakage rate is less than or equal to 0.05 La when pressurized to Pa." TS 3.6.1.7 Action c was entered that requires "With acontainment purge supply and /or exhaust isolation valve(s) having a measured leakage rate exceeding the limits of Surveillance Requirements 4.6.1.7.3 and/or 4.6.1.7.4, restore theinoperable valve(s) to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

You stated that Unit 2 would violate the allowed outage time for Action c on February 15, 2006 FP&L2at 4:10 p.m., because the valve could not be restored to OPERABLE status within the allowed24 hours. You verbally requested enforcement discretion to allow the use of a blind flange to satisfy TS 3.6.1.7 Action c requirements during our telephone conference on February 15, 2006. Additionally, you committed to submitting an exigent license amendment request to allow this additional action, which is consistent with the standard Combustion Engineering TS.Your letter of February 17, 2006, stated that the proposed NOED would avoid an unnecessarytransient as a result of compliance with TS 3.6.1.7 Action c; thereby, minimizing the potentialsafety consequences and operational risks. It also stated that the requested NOED wouldprovide adequate time for completing the necessary engineering and administrative activities for implementing a permanent TS change, which would allow installation of a blind flange to satisfy TS 3.6.1.7 Action c requirements for containment purge penetrations that failed therespective LLRT TS surveillance. In addition, your letter indicated that the impact on containment isolation does not contribute to core damage frequency, only large early releasefrequency (LERF), however, the impact of loss of the continuous containment purge/hydrogen purge systems functions would be insignificant to the LERF. As such, your letter concluded thatthe proposed NOED would not be of potential detriment to the public health and safety,because there is no net increase in radiological risk to the public. Moreover, the only compensatory measure implemented is the installation of a passive blind flange. This configuration enhances plant safety. In your letter of February 17, 2006, you confirmed your commitment to submit a followuplicense amendment request (LAR) by close of business February 21, 2006, which incorporates a permanent change contained in this NOED into the St. Lucie Unit 2 TS. We plan to complete our review and disposition of your followup license amendment by March 24, 2006. On the basis of the staff's evaluation of your request, we have concluded that granting thisNOED is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on public health and safety or the environment. Therefore, it is our intention to exercise discretion to not enforce compliance with TS 3.6.1.7 Action c for the period from 3:00 p.m. onFebruary 15, 2006, to March 24, 2006. As stated in the Enforcement Policy, action will be taken, to the extent that violations wereinvolved, for the root cause that led to the noncompliance for which this NOED was necessary.Sincerely,/RA by Loren R. Plisco Acting For/William D. TraversRegional Administrator Docket No.: 50-389License No.: NPF-16cc: (See page 3)

FP&L3 cc:William Jefferson, Jr.

Site Vice President St. Lucie Nuclear Plant Florida Power & Light Company Electronic Mail DistributionG. L. JohnstonPlant General Manager St. Lucie Nuclear Plant Electronic Mail DistributionTerry L. PattersonLicensing Manager St. Lucie Nuclear Plant Electronic Mail DistributionMark Warner, Vice PresidentNuclear Operations Support Florida Power & Light Company Electronic Mail DistributionRajiv S. KundalkarVice President - Nuclear Engineering Florida Power & Light Company Electronic Mail DistributionM. S. Ross, Managing AttorneyFlorida Power & Light Company Electronic Mail DistributionMarjan Mashhadi, Senior AttorneyFlorida Power & Light Company Electronic Mail DistributionWilliam A. PassettiBureau of Radiation Control Department of Health Electronic Mail DistributionCraig Fugate, DirectorDivision of Emergency Preparedness Department of Community Affairs Electronic Mail DistributionJ. KammelRadiological Emergency Planning Administrator Department of Public Safety Electronic Mail DistributionDouglas AndersonCounty Administrator St. Lucie County 2300 Virginia Avenue Ft. Pierce, FL 34982Distribution: (See next page)

Letter to Mr. J.A. Stall from William D. Travers dated February 22, 2006

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR FLORIDA POWER AND LIGHT REGARDING ST. LUCIE UNIT 2 [TAC NO MD0052, NOED NO. 06-02-01]Distribution w/encl

B. Wetzel, OEDO W. Travers, RII, ORAI B. Sheron, ADES C. Haney, DORL E. Hackett, DORL M. Johnson, OE T. Tate, NRR NOED OEWEB J. Munday, RII, DRP C. Evans, RII M. Marshall, NRR B. Moroney, NRR T. Hoeg, RII, DRP RIDSNRRDIPMLIPB PUBLIC

_________________________OFFICENRRRII:DRPRII:DRPRII:ORARII:EICSSIGNATUREJTM for, by telephoneJTMCAC1LRPCFENAMECHaneyJMundayCCastoLPliscoCEvansDATE02/22/0602/22/0602/23/0602/22/0602/22/06 E-MAIL COPY? YESNO YES NO YESNO YESNO YESNO