ML091610675
| 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
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
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
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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
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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.
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
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