L-2013-253, St. Lucie'S First Six-Month Status Report to the Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses

St. Lucie'S First Six-Month Status Report to the Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses

ML13242A006
Person / Time
Site:	Saint Lucie
Issue date:	08/27/2013
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, L-2013-253
Download: ML13242A006 (10)

Text

0 August 27, 2013 FPL. L-2013-253 10 CFR 2.202 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Florida Power & Light/St. Lucie's First Six-Month Status Report to the Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-051)

References:

I. NRC Order Number EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, Accession No. ML12056A044.

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012, Accession No. ML12221A339.

3. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 24, 2012, Accession No. ML12240A307.

4. FPL Letter L-2012-384, dated October 25, 2012, Florida Power & Light (FPL)'s Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1), Accession No. ML12300A420.

5. FPL Letter L-2013-079, dated February 28, 2013, Florida Power & Light/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1), Accession Number ML13063A026.

6. NRC Letter to Florida Power and Light St. Lucie Nuclear Plant, Units I and 2 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0090 and MF0091), dated July 16, 2013 Accession No. ML13196A079.

7. FPL Letter L-2013-223, dated July 26, 2013, Florida Power and Light St. Lucie Nuclear Power Plant Units 1 and 2 Response to Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation," Accession No. ML13219A838.

Florida Power &Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2013-253 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Florida Power & Light (FPL). Reference I was immediately effective and directs FPL to implement and maintain reliable spent fuel pool water level instrumentation.

Specific requirements are outlined in Attachment 2 of Reference 1. Reference I required submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEI 12-02, Revision I (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan.

Reference 4 provided the FPL/St. Lucie initial status report regarding reliable spent fuel pool instrumentation, as required by Reference 1. Reference 5 provided the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. Reference 6 forwarded an NRC request for additional information (RAI) concerning the Overall Integrated Plan, and in Reference 7 FPL provided the initial response to the RAIs.

This letter provides the first 6-month update to FPL/St. Lucie's Overall Integrated Plan for installing and maintaining reliable spent fuel pool water level indication that satisfies the requirements of Reference 1. This letter also provides replies to portions of the outstanding RAIs of reference 6 and the status of the RAI replies still under development.

The information in the enclosure provides the first six-month update to the FPL/St. Lucie Overall Integrated Plan for reliable spent fuel pool instrumentation pursuant to Reference 3. The enclosed Overall Integrated Plan update is based on conceptual design information that is current as of this letter. As design details and associated procedural guidance are finalized, additional information, as well as revisions to the information contained in the enclosure to this letter, will be communicated to the NRC in the 6-month Overall Integrated Plan updates as required by Reference 1.

This letter contains no new regulatory commitments.

If there are any questions regarding this submittal, please contact Eric Katzman, St. Lucie Licensing Manager, at (772) 467-7734.

L-2013-253 Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 23--J , 2013.

submitted, usp..i nsen "SiteVice President St. Lucie Plant

Enclosure:

First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector

L-2013-253 Enclosure Page 1 of 7 ENCLOSURE I FLORIDA POWER & LIGHT ST. LUCIE NUCLEAR POWER PLANT FIRST SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION I Introduction Florida Power & Light St. Lucie Nuclear Power Plant Units 1 and 2 developed an Overall Integrated Plan (Reference 1 in Section 7), documenting the modification with regard to reliable Spent Fuel Pool (SFP) instrumentation in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments St. Lucie .Unit 1 has selected and entered into a purchase agreement to procure SFP level instruments that, when installed, will meet all the criteria designated in the Overall Integrated Plan submitted on February 28, 2013 (Reference 1).

3 Milestone Schedule Status There currently are no changes to the Milestone Schedule provided in the Overall Integrated Plan (Reference 1, Attachment 2) except correction of a typographical error in Unit 1 "Complete Design" date, from 3Q 2015 to 3Q 2014. Any changes to the following target dates will be reflected in the six month updates:

The current milestones are: Unit 1 Unit 2

" Commence Engineering and Design In progress In progress

" Complete Design 3Q 2014 1Q 2015

" Complete Procurement of SFP Instruments 4Q 2014 2Q 2015

" Complete Installation of SFP Instruments 1Q 2015 3Q 2015

" Instruments Operational and Training completed 2Q 2015 4Q 2015 Required implementation date: RF26 RF22 2Q 2015 4Q 2015 4 Changes to Compliance Method There currently are no changes to the compliance method documented in the Overall Integrated Plan (Reference 1). Consistent with the requirements of Order EA-12-051 and the Order guidance documents, the six month reports will delineate any proposed changes to compliance methods.

L-2013-253 Enclosure Page 2 of 7 5 Need for Relief/Relaxation and Basis for the RelieflRelaxation St. Lucie is not requesting relief from the requirements of Order EA-1 2-051 (Reference 2) or guidance document JLD-ISG-2012-03 (Reference 4) at this time.

Consistent with the requirements of Order EA-12-051 (Reference 2) and the guidance in NEI 12-02 (Reference 5), the six month reports, will delineate progress made, any proposed changes in compliance methods, updates to the schedule, and if needed, requests for relief and their bases.

6 Requests for Additional Information A response to the Request for Additional Information (RAI) received on July 16, 2013 (Reference 6) was provided on July 26, 2013 (Reference 3).

The following table provides a summary of the remaining open RAIs that were received on July 16, 2013 (Reference 6) in response to the initial Overall Integrated Plan submittal.

Open RAIs Status RAI-3 a, b, c - Mounting In progress RAI-4 a, b, c - Qualification In progress RAI-6 a, b - Power Supplies In progress RAI-7 a, b - Accuracy In progress RAI-8 a, b, c, d - Testing In progress RAI-10 a, b-Procedures In progress RAI-1 1 a, b, c - Testing and Calibration In progress The response to the RAIs in the table above requires design information that is not available at this time. A response to the RAIs will be provided in the February 2014 semi-annual update.

The following RAI responses for RAI 2 and RAI 9.a, 9.b, and 9.c were not available for submittal in Reference 3, and are provided below.

3.0 INSTRUMENTATION DESIGN FEATURES 3.1 Arrangement The OIP states, in part, that The two SFPlevel instrument channels will be installed in diverse locations, arrangedin a manner that provides reasonableprotection of the level indication function against missiles that may result from damage to the structure over the SFP. As indicatedabove,

L-2013-253 Enclosure Page 3 of 7 the primary and backup SFP level sensors will be installed in the South side of each unit's SFP, as close to the opposite comers as practical to maintain maximum attainable separation. Sensor conditioning electronicsand battery backup will be mounted in a remote location separatedfrom the SFPby a reinforcedconcrete wall(s) which will provide suitable radiationshielding for the electronics.

RAI-2

Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placementof the primary and back-up SFP level sensors, and the proposed routing of the cables that will extend from the sensors toward the location of the local electronics cabinets and read-out/displaydevices in the main control room or alternate accessiblelocation.

FPL Response to RAI-2 The following sketch shows the planned locations of the two level probes, located in the south end of the pool as close to the opposite corners as practical. As shown, the inside pool dimension of this side of the pool is 33 feet. The wiring from these sensors will be routed to maintain this distance until outside the spent fuel pool room to the extent possible. Once outside the SPF room, channel wiring will be separated in accordance with plant design basis channel separation criteria. (The sketches in this submittal are from Unit 1 drawings, but the general locations are applicable to both units. Ignore the column identifiers.)

FK3 PLAN ELEV 62.00' PSL - FUEL HANDLING BUILDING

L-2013-253 Enclosure Page 4 of 7 The following simplified sketch shows the proposed location of each major component of one typical channel. This Unit 1 sketch is typical for both units.

N-'

F44 FW4 PSL - FUEL HANDLING BUILDING WCTTO SCALU As shown, the signal transmitter for each channel is located outside the SFP room, one floor elevation lower in the new fuel storage area. The level indicator enclosures, including independent UPS and backup batteries for each channel, are located on the ground floor of the SFP pump and filter room (plant elevation 19.5').

L-2013-253 Enclosure Page 5 of 7 The proposed conduit routing is shown in the final drawing below. The proposed routing uses a combination of new and existing conduits and raceways. Each channel's conduit and indicator enclosures will be separated in accordance with the plant design basis channel separation criteria. The boxes may be mounted in slightly different areas of this room for each unit based on existing mounting space and interferences, but they will be located in the same general area.

The proposed Unit 1 configuration is depicted below.

PLAN ELEV. 19.HB PSL - FUEL HANDLING BUILDING 3.8 Display The O/P states, in part, that The design will include remote indication that will be accessible during post event conditions.

RAI-9

Please provide the following:

a) The specific location for the primary and backup instrument channel display.

L-2013-253 Enclosure Page 6 of 7 b) Since both the primary and backup display locations are not in the main control room, please provide a description of the location for the primary and back up displays, including primary and alternate route evaluation, habitability at display location(s),

continual resource availabilityfor personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.

c) The reasonsjustifying why the locations selected will enable the information from these instruments to be considered "promptlyaccessible". Include considerationof various drain-down scenarios.

FPL Response to RAI-9.a The primary and backup instrument channel displays will be located in the spent fuel pool pump and filter area on the 19.5' elevation of the spent fuel pool building.

FPL Response to RAI-9.b The primary SFP display access route from the control rooms would be down the West interior stairs to the RAB 19.5' elevation, out the North RAB door and across the yard into the Fuel Handling Building 19.5' elevation South door. The short outside portion of this route is above the design basis flood elevation and is sheltered from storm winds by the adjacent seismically qualified structures. The plant Severe Weather Preparations procedure also specifically installs personnel lifelines for storm access between the RAB and FHB (Reference 7).

Alternate SFP display access routes from the control rooms include a diverse route out the East side of the control rooms and across the RAB 62' elevation roof to the 62' elevation FHB roof and down the South FHB exterior stairs and into the 19.5' elevation South door.

Habitability at the display location is acceptable because the displays are located inside the 19.5 foot elevation of the FHB and the top of the Spent Fuel Pool is in a completely different portion of the FHB at the 62' elevation. Any steam from the SFP surface would be vented out through the FHB L-shaped hatch opening. Radiation shielding for drain down scenarios would be provided by the multiple concrete walls between the fuel assemblies and the display location. Operations personnel will be available to read the display because they will be entering the FHB to perform Emergency Operating Procedure and FLEX Support Guideline actions. Operations personnel will utilize portable plant radios to communicate SFP display information directly to the control rooms.

FPL Response to RAI-9.c The information from these instruments will be promptly accessible because access to the displays and plant portable radios for communication with the control room are readily available as described above. Access would not be constrained under drain-down scenarios because the displays are located in a completely different section of the FHB from the SFP as described above.

L-2013-253 Enclosure Page 7 of 7 7 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Florida Power and Light St. Lucie Nuclear Power Plant Units 1 and 2 Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 [ML13063A026]

2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 [ML12056A044]

3. Florida Power and Light St. Lucie Nuclear Power Plant Units 1 and 2 Response to Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-1 2-051, "Reliable Spent Fuel Pool Instrumentation", dated July 26, 2013

[ML13219A838]

4. JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 [ML12221A339]

5. NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"', dated August, 2012 [ML12240A307]

6. NRC Letter to Florida Power and Light St. Lucie Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0090 and MF0091), dated July 16, 2013 [ML13196A079]

7. Administrative Procedure 0005753, Severe Weather Preparations, Revision 71