ML13212A229
| ML13212A229 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/30/2013 |
| From: | Vias S J NRC/RGN-II/DRS/EB3 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| Download: ML13212A229 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303
-1257 July 30, 2013 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408
-0420
SUBJECT:
ST. LUCIE NUCLEAR PLANT
- NOTIFICATION OF NRC INSPECTION AND REQUEST FOR INFORMATION
Dear Mr. Nazar:
On September 16, 201 3, the Nuclear Regulatory Commission will begin inspection activities for the S t. Lucie Nuclear Plant in accordance with Temporary Instruction (TI) 2515-182, "Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks." This inspection is scheduled to be performed from September 16
-18, 2013, and will address the inspection requirements for Phase 2 of this TI.
In order to minimize the impact to your on
-site resources , and to ensure a productive inspection, we have enclosed a list of documents needed for the preparation and implementation of this inspection. The documents that are requested for this inspection include all relevant documents that will allow the inspector(s) to adequately complete Phase 2 of this inspection
. We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be M r. Ken Frehafer, of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Michael Coursey at (404) 997
-4430 or Abhijit.Sengupta@nrc.gov. In accordance with 10 CFR 2.390 of the NRC's "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 NRC's Agencywide M. Nazar 2 Documents Access and Management 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 Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Docket No s.: 50-335 , 389 License No.
DPR-67 , NPF-16 Enclosure s: Inspection Document Request Temporary Instruction (TI 2515
-182) TI-182 Phase II Questions
c c: (See page 3)
M. Nazar 3 cc: Joseph Jensen Site Vice President St. Lucie Nuclear Plant Electronic Mail Distribution Paul Freeman Vice President Organizational Effectiveness Florida Power & Light Company Electronic Mail Distribution Peter Wells Vice President Outage Support CFAM Florida Power & Light Company Electronic Mail Distribution Robert J. Hughes Plant General Manager St. Lucie Nuclear Pla nt Electronic Mail Distribution Daniel D. DeBoer Operations Site Director St. Lucie Nuclear Plant Electronic Mail Distribution
Eric Katzman Licensing Manager St. Lucie Nuclear Plant Electronic Mail Distribution
Larry Nicholson Director Licensing Florida Power & Light Company Electronic Mail Distribution Alison Brown Nuclear Licensing Florida Power & Light Company Electronic Mail Distribution Cynthia Becker (Acting) Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution Bryan Koon Director Florida Division of Emergency Management Electronic Mail Distribution Donna Calabrese Emergency Preparedness Manager St. Lucie Plant Electronic Mail Distribution
J. Kammel Radiological Emergency Planning Administrator Department of Public Safety Electronic Mail Distribution Senior Resident Inspector St. Lucie Nuclear Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, FL 34957
-2010 Michael Baughman Training Manager St. Lucie Nuclear Plant Electronic Mail Distribution Faye Outlaw County Administrator St. Lucie County Electronic Mail Distribution
James Petro Managing Attorney
-Nuclear Florida Power & Light Company Electronic Mail Distribution
Jack Southard Director Public Safety Department St. Lucie County Electronic Mail Distribution
Letter to Mano Nazar from Steven J. Vias dated July 31, 2013.
SUBJECT:
ST LUCIE NUCLEAR PLA N T - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Distribution:
RIDSNRRDIRS PUBLIC RidsNrrPMStLucie Resource Enclosure 1 TEMPORARY INSTRUCTION 2515
-182 INSPECTION DOCUMENT REQUEST Inspection Dates:
September 16
-18 , 201 3 Inspection Procedures
- TI 2515-182, "Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks" Inspector:
Abhijit Sengupta
, Reactor Inspector Information Requested for the Preparation and Completion of the In
-Office Inspection The following documents listed below are requested (electronic copy
, if possible) by September 6 , 201 3, to facilitate the preparation for the on
-site inspection week
- 1. Organization list of site individuals responsible for the site's underground piping and tanks program.
- 2. Copy of Site Underground Piping and Tanks program.
- 3. Please review the ENCLOSURE 2 "TI
-182 PHASE 2 QUESTIONS" and provide response and/or document requests.
- 4. Schedule for completion of the following NEI 09
-14 , "Guideline For The Management of Underground Piping and Tank Integrity," Revision 3 , attributes:
Buried Piping Procedures and Oversight Risk Ranking Inspection Plan Plan Implementation Asset Management Plan Underground Piping and Tanks Procedures and Oversight Prioritization Condition Assessment Plan Plan Implementation Asset Management Plan Information t o b e provided On
-Site t o the Inspector following the Entrance Meeting A. Location maps of buried & underground piping and tanks identified by the inspector from the information requested for the preparation week.
B. Copy of EPRI document "Recommendations for an Effective Program to Control the Degradation of Buried Pipe".
C. Self or third party assessments of the Underground Piping and Tanks Program (if any have been performed).
2 D. For any of the NEI 09
-14 Rev.3 attributes identified below which have been completed prior to the NRC's onsite inspection, provide written records that demonstrate that the program attribute is complete.
Buried Piping Procedures and Oversight Risk Ranking Inspection Plan Plan Implementation Asset Management Plan Underground Piping and Tanks Procedures and Oversight Prioritization Condition Assessment Plan Plan Implementation Asset Management Plan Inspector Contact Information Mailing Address Abhijit Sengupta US NRC- Region II Reactor Inspector Attn: Abhijit Sengupta 404-997-4430 245 Peachtree Center Avenue, Suite 1200 Abhijit.Sengupta@nrc.gov Atlanta, GA 30303
Enclosure 2 TI-182 PHASE 2 QUESTIONS Questions Response Question Number Subpart Initiative Consistency 1 a Has the licensee taken any deviations to either of the initiatives?
Yes / No b If so, what deviations have been taken and what is (are) the basis for these deviations?
2 a Does the licensee have an onsite buried piping program manager (owner) and, potentially, a staff?
Yes / No b How many buried piping program owners have there been since January 1, 2010?
c How many other site programs are assigned to the buried piping program owner?
3 a Does the licensee have requirements to capture program performance, such as system health reports and performance indicators?
Yes / No b Are these requirements periodic or event driven? Periodic / Event Driven / None c Are there examples where these requirements have been successfully used to upgrade piping systems or to avert piping or tank leaks?
Yes / No 4 a Does the licensee have a program or procedure to confirm the as
-built location of buried and underground piping and tanks at the plant?
Yes / No b Has the licensee used this program?
Yes / No c Was the program effective in identifying the location of buried pipe?
Yes / No 2 5 For a sample of buried pipe and underground piping and tanks (sample size at least 1 high and 1 low risk/priority pipe or tank), did the risk ranking and/or prioritization process utilized by the licensee produce results in accordance with the initiative guidelines, i.e.,
which emphasize the importance of components which have a high likelihood and consequence of failure and deemphasize the importance of components which have a low likelihood and consequence of failure?
Yes / No Sample size examined
_____ 6 a As part of its risk ranking process did the licensee estimate/determine the total length of buried/ underground piping included in the initiatives?
Yes / No b As part of its risk ranking process did the licensee estimate/determine the total length of high risk buried/underground piping included in the initiatives?
Yes / No Preventive Actions / System Maintenance 1 a For uncoated steel piping, has the licensee developed a technical basis for concluding that structural (e.g. ASME Code minimum wall, if applicable) and leaktight integrity of buried piping can be maintained?
Yes / No / Not Applicable (no uncoated buried steel pipe) b Is the technical basis provided as justification by the licensee consistent with the initiative (including its reference documents) or industry standards (e.g. NACE SP0169)
Yes / No 2 a For buried steel, copper, or aluminum piping or tanks which are not cathodically protected, has the licensee developed a technical basis for concluding that structural (e.g. ASME Code minimum wall, if applicable) and leaktight integrity of buried piping can be maintained?
Yes / No / Not Applicable (no buried steel, copper, or aluminum piping which is not cathodically protected)
3 b Is the technical basis provided as justification by the licensee consistent with the initiative (including its reference documents) or industry standards (e.g. NACE SP0169)
Yes / No 3 a For licensees with cathodic protection systems, does the licensee have procedures for the maintenance, monitoring and surveys of this equipment?
Yes / No / Not Applicable (no cathodic protection systems) b Are the licensee procedures consistent with the initiative (including its reference documents) or industry standards (e.g. NACE SP0169)?
Yes / No c Is the cathodic protection system, including the evaluation of test data, being operated and maintained by personnel knowledgeable of, or trained in, such activities Yes / No 4 Is there a program to ensure chase and vault areas which contain piping or tanks subject
to the underground piping and tanks initiative are monitored for, or protected against, accumulation of leakage from these pipes or tanks? Yes / No / N/A (No piping in chases or vaults) Inspection Activities / Corrective Actions 1 a Has the licensee prepared an inspection plan for its buried piping and underground piping and tanks?
Yes / No b Does the plan specify dates and locations where inspections are planned?
Yes / No c Have inspections, for which the planned dates have passed, occurred as scheduled or have a substantial number of inspections been deferred?
Occurred as scheduled / Deferred 2 a Has the licensee experienced leaks and/or significant degradation in safety related piping or piping carrying licensed material since January 1, 2009?
Leaks Yes / No Degradation Yes / No b If leakage or significant degradation did occur, did the licensee determine the cause of the leakage or degradation?
Yes / No 4 c Based on a review of a sample of root cause analyses for leaks from buried piping or underground piping and tanks which are safety related or contain licensed material, did the licensee's corrective action taken as a result of the incident include addressing the cause of the degradation?
Yes / No / N/A (no leaks) d Did the corrective action include an evaluation of extent of condition of the piping or tanks and possible expansion of scope of inspections? (Preference should be given to high risk piping and "significant" leaks where more information is likely to be available).
Yes / No / N/A (no leaks) 3 a Based on a review of a sample of NDE activities which were either directly observed or for which records were reviewed, were the inspections conducted using a predetermined set of licensee/contractor procedures?
Yes / No b Were these procedures sufficiently described and recorded such that the inspection could be reproduced at a later date?
Yes / No c Were the procedures appropriate to detect the targeted degradation mechanism?
Yes / No d For quantitative inspections, were the procedures used adequate to collect quantitative information?
Yes / No 4 Did the licensee disposition direct or indirect NDE results in accordance with their procedural requirements?
Yes / No 5 Based on a sample of piping segments, is there evidence that licensees are substantially meeting the pressure testing requirements of ASME Section XI IWA
-5244? Yes / No