L-2014-041, Florida Power and Light Company'S Turkey Point Units 3 & 4, Second Six-Month Status Report in Response to 03/12/2012, Commission Order Modifying Licenses with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Exte

Florida Power and Light Company'S Turkey Point Units 3 & 4, Second Six-Month Status Report in Response to 03/12/2012, Commission Order Modifying Licenses with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Extern

ML14073A454
Person / Time
Site:	Turkey Point
Issue date:	02/26/2014
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2014-041
Download: ML14073A454 (42)

Text

CFebruary 26, 2014 L-2014-041

=PL.

U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Unit 3 and Unit 4 Docket Nos. 50-250 and 50-251 Florida Power and Light Company's Turkey Point Units 3 and 4, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049)

References:

1. U.S. Nuclear Regulatory Commission, Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12056A045)

2. FPL Letter, L-2013-061, Florida Power and Light Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated February 26, 2013 ( ML13072A038)

3. FPL Letter, L-2013-249, Florida Power and Light Company's, Turkey Point Units 3 and 4, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated August 21, 2013,

( ML13248A311).

4. NRC Letter, Turkey Point Units 3 and 4-Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos.

MF0982 and MF0983), dated February 6, 2014, (ML14002A151).

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1, an immediately effective Order to all licensees including Florida Power and Light Company's (FPL) Turkey Point Units 3 and 4. In Reference 2, FPL submitted an Overall Integrated Plan for the implementation of this Order. The Order required Licensee's to provide periodic status reports for the Overall Integrated Plan.

Florida Power & Light Company 976U S.W. 344- Street Homestead, 1+/- 33035-

Turkey Point Units 3 and 4 L-2014-041 Docket Nos. 50-250 and 50-251 Page 2 of 2 FPL submitted the first six-month update to the Overall Integrated Plan on August 21, 2013 (Reference 3). On February 6, 2014, the NRC Staff provided the interim staff evaluation and audit report including open and confirmatory items (Reference 4).

The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1.

The enclosure to this letter provides an update of milestone accomplishments, confirmatory items and open items, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Turkey Point Licensing Manager, at 305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February ., (,, 2014 This letter contains no new Regulatory Commitments and no revisions to existing Regulatory Commitments.

Sincerely, Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant

L-2014-041 Enclosure Florida Power and Light Company's Turkey Point Units 3 and 4 Second Six Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 20

L-2014-041 Enclosure 1 Introduction Florida Power and Light Company's (FPL) Turkey Point developed an Overall Integrated Plan (OIP)

(Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure 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 Since the last 6 month update, ordering of long lead equipment has been completed. Significant progress has been made in performing the analysis supporting flex strategies and each are on track for completion by June 2014. Detailed design for mechanical and electrical tie-in modifications is near completion for the lead unit. Additionally, the contract for the storage building has been awarded and the design phase has commenced. Finally, the contract for low leakage reactor coolant pump seals has been awarded.

3 Milestone Schedule Status The following provides an update to Attachment 3 of the Overall Integrated Plan (Reference 1). It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The following milestone target completion dates have been adjusted or added:

Develop Strategies (Playbook) with RRC with a target completion date of November 2013 has been adjusted to January 2015.

BASIS: The extension of the completion date reflects schedule adjustments for the second grouping of plants with fall 2015 outages. This date reflects the final completed playbook. A draft of the play book will be developed in late 2014.

The revised milestone target completion dates do not impact the order implementation date.

New Milestones:

There are no new milestone dates Milestone Target Activity Status Revised Target Completion Completion Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Page 2 of 20

L-2014-041 Enclosure Milestone Target Activity Status Revised Target Completion Completion Date Date Update 3 Aug 2014 Not Started N/A Update 4 Feb 2015 Not Started N/A Update 5 Aug 2015 Not Started N/A Update 6 Feb 2016 Not Started N/A Update 7 Aug 2016 Not Started N/A Walk-through or Demonstrations:

Complete Analyses Supporting FLEX Strategies Jun-2014 Started N/A Complete Final Time Constraint Validations Nov-2014 Not Started N/A Complete Staffing Analysis (Phase 2) Jan-2015 Not Started N/A Complete Final Walkthrough Validation Feb-2015 Not Started N/A Modifications:

Issue Modification Packages for Unit 3 Jun-2014 Started N/A Unit 3 Implementation Complete Nov-2015 Not Started N/A Issue Modification Packages for Unit 4 Jun-2015 Not Started N/A Unit 4 Implementation Complete May-2016 Not Started N/A Storage:

FLEX Storage Building Completed Mar-2015 Started N/A FLEX Equipment:

Order Equipment (procurement phase 1)* Jun-2014 Complete N/A Receive Equipment (procurement phase 1)* Dec-2014 Not Started N/A Order Equipment (procurement phases 2/3)* Dec-2014 Not Started N/A Receive Equipment (procurement phase 2)* June-2015 Not Started N/A Receive Equipment (procurement phase 3)* June-2015 Not Started N/A Develop Strategies (Playbook) with RRC Nov-2013 Started Jan-2015 Procedures:

Issue Operations Procedure Changes including Sep-2014 Started N/A FSGs Create Maintenance Procedures Dec-2014 Not Started N/A Page 3 of 20

L-2014-041 Enclosure Milestone Target Activity Status Revised Target Completion Completion Date Date Training:

Operations Procedure Changes Training Sep-2014 Started N/A Material Complete Develop Training Plan Oct-2014 Started N/A Training Complete Feb-2015 Not Started N/A

• Note phase refers to the procurement sequence of equipment to be ordered, not the FLEX Phases as described in NEI 12-06.

4 Changes to Compliance Method 4.1 Changes to Modifications Modifications Nos. 2, Install Isolation Valve and Hose Connections on previously capped connection off AFW Suction Header Lines for Each Condensate Storage Tank (CST).

The previous 6 month update report (Reference 3) included a sketch showing two new hose connection points to the Condensate Storage Tank (CST) for use during Phase 2 (Modification Nos. 2 and 4). Modification No. 2 identified adding a hose connection and valve at the CST overfill drain line as an alternate fill connection. Due to constructability and operational concerns, the hose connection for the alternative fill location will be moved to the manway on top of the CST. Modification No. 4 which is the primary means to refill the tanks has not changed. A revised modification No. 2 conceptual sketch has been provided in Attachment 1.

This change will not affect the strategy or ability to maintain core cooling and heat removal by equipment credited during Phase 2.

Modification No. 5, Install isolation valve and hose connections at the Steam Generator Wet Layup (SGWLU) spectacle flanes for each individual SG.

The Overall Integrated Plan submittal (Reference 1, Attachment 4) included a sketch showing a new valve and hose connection at the SG wet layup spectacle flange (Modification No. 5). The configuration of this connection has been changed to reduce deployment time for connecting the steam generator FLEX pump. Two permanent tees with isolation valves and hose connections will be added to the common AFW discharge header on the 18 ft elevation of the turbine building. This change reduces the hose connections from six to two and eliminates having to deploy hoses from the 18 ft elevation of the turbine building up to the Feedwater (FW) platform on the 42 ft elevation. A revised modification No. 5 conceptual sketch has been provided in Attachment 2. The new connection points are within robust structures and the change will not affect the strategy or the ability to maintain core cooling and heat removal by equipment credited during Phase 2.

Page 4 of 20

L-2014-041 Enclosure Modification No. 6, Install isolation valve and hose connections in Refueling Water Storage Tank (RWST) Manhole covers.

The Overall Integrated Plan submittal (Reference 1, Attachment 4) included a sketch showing a new hose connection point to the Refueling Water Storage Tank (RWST) manway cover for use during Phase 2 (Modification No. 6). Makeup to the RWST would only be required during modes 5 and 6. Adding makeup water directly to the RWST would require additional portable equipment for boron mixing. Therefore, a new permanent hose connection will be provided at the primary makeup water supply line to the boric acid blender. This will allow normal boron mixing using well water supplied by a hose from the SG FLEX pump and boric acid from boric acid storage tanks (BAST) utilizing the boric acid transfer pumps. Makeup to the BAST will be provided by supplying well water from the SG FLEX pump to the boron batching tank.

Discharge from the boric acid blender goes directly to the charging pump suction line for makeup to the RCS. As a backup, blended flow could be provided to the RWST if needed. The hose to the primary water connection from the SG FLEX pump will also supply cooling water to the existing hose connections on the Charging Pump oil coolers. A revised modification No.

6 conceptual sketch has been provided in Attachment 3. The new connection points are within robust structures, and the systems to be used for tie-in and delivery are seismically analyzed safety related systems or will be shown to be robust. This change will not affect the strategy since the charging pumps are already credited to provide reactor coolant system inventory makeup during Phase 2.

Modification No.7 Install hose connection to Intake Cooling Water line The previous 6 month update report (Reference 3) included a sketch showing two new hose connection points to the Intake Cooling Water (ICW) strainers along with a temporary hose adapter to supply both CCW heat exchangers during Phase 3. After more detailed design efforts, the temporary adapter will be provided with two hose connection instead of one to ensure adequate flow capacity. A revised modification No. 7 conceptual sketch has been provided in Attachment 4. This change will not affect the strategy or ability to maintain core cooling and heat removal by equipment credited during Phase 3.

Modification No. 12, FLEX Shallow Wells for Potable Water The Overall Integrated Plan submittal (Reference 1, Attachment 4) described adding shallow wells to provide a minimum of 600 gpm (Modification No. 12). FPL indicated in the first 6 month update report for Turkey Point (Reference 3) that deep wells would be installed for chemistry reasons instead of shallow wells. As a result of more detailed design activities for the deep wells, it is planned to install a single well to backup the "non-robust" water makeup sources should they not be available. Adequate artesian well pressure will exist at the well head to deliver 600 gpm eliminating the need for well pumps (see Section 4.2 for well pump discussion). The artesian well is a passive alternate ultimate heat sink source.

The well itself will be qualified seismically and the well head will be enclosed within a robust structure rated for all Turkey Point external hazards. Primary and alternate hose connections will be provided within the robust well structure. Since the single well will meet NEI section 3.2.1.3 and 3.2.2 guidance, FPL will install a single deep well.

Page 5 of 20

L-2014-041 Enclosure 4.2 Changes to Strategies 4.2.1 Current Strategy for Use of Well Pumps OIP Section: Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint, T+8 (hours) - Portable Diesel Generators Available to Power Well Pumps, Page 6 of 101 "The portable diesel generators will be used to power wells pumps, which are credited by hour 9 and required to be making up to the CST at hour 12" OIP Section: Intermediate Term (Phase 2) Coping Strategy, (Modes 1 through 4, and Mode 5 with Steam Generators Available - Non-Hurricane Scenario) and (Modes 1 through 4, and Mode 5 with Steam Generators Available - Hurricane Scenario), page 21 and 22 of 101 "The new well pumps will be used to refill the surviving CST(s) for the duration of the phase 2 coping time."

"The capacity of the well pumps and SG FLEX pumps will be 300 gpm per unit which was based on the recommendations of WCAP-17601-P (Ref. 4)."

"The SG FLEX pump requires a higher discharge pressure than the well pump due to operating pressure of the steam generators."

OIP Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2, Key Reactor Parameters, page 24 of 101 Portable equipment instrumentation

• Pressure and flow for well pumps OIP Section: Safety Function: Maintain RCS Inventory Control PWR Portable Equipment Phase 2, Key Reactor Parameters, page 35 of 101 Portable equipment instrumentation

• Pressure, flow, and fuel for well pumps and FLEX RCS pumps OIP Section: Attachment I - Sequence of Events Timeline Sequence of Events Timeline, page 71 of 101 Action Elapsed Action Time Remarks /

item Time Constraint Applicability YIN 8 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> Well pumps powered Y Needed to makeup and providing water to before CST(s) surviving CST deplete With subsequent dryout of steam generators Page 6 of 20

L-2014-041 Enclosure OIP Section: Attachment 4 Modifications and Sketches Change to Well Pump Strategy Each of these sections refers to having permanently installed electric shallow well pumps with flow and pressure indications. The well pumps would then be powered by portable diesel generators in phase 2. FPL indicated in the first 6 month update report for Turkey Point (Reference 3) that deep well would be installed for chemistry reasons instead of shallow wells. As a result of more detailed design activities for the deep wells, it has been determined that adequate artesian well pressure will exist at the well head to eliminate the well pumps. Calculations and similar test data from onsite wells show adequate pressure will be provided by the artesian well at the required 600 gpm flowrate to meet the NPSH requirements for the SG portable FLEX pump. The suction of the FLEX portable Steam Generator pump will connect to the well head and supply makeup to a Condensate Storage Tank (CST) or directly inject to the S/Gs if the Turbine Driven AFW pumps are not available. The revise strategy eliminates some portable equipment which simplifies and reduces deployment durations.

4.2.2 Current Strategy for Containment Pressure Control OIP Section: Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint, T+12 (hours) - Re-powering Containment Spray Pumps, Page 8 of 101 "Containment pressure and temperature could exceed design limits, especially in Modes 5 and 6. This is because the RCS would be open to the containment atmosphere and cooling would be established through feed from an RWST and boil-off through one of the designated openings in the system. Accordingly, the containment spray pumps are repowered at hour 12 to cool the containment if needed. T+ 12 was considered to be adequate to prevent exceeding design temperature and pressure. A confirmatory analysis is needed and is being tracked as pending action 1, listed in Attachment 3."

Change to Containment Pressure Control FPL will utilize venting of Containment to control pressure in modes 5 and 6. Prior to venting the RCS or removing all SG as a heat sink, an adequately sized vent path will be maintained open or have capability of being opened from outside containment. A confirmatory analysis is needed to determine the vent path size and is being tracked as pending action 1, listed in Attachment 3 of the OIP. In modes I through 4, significantly less energy will be released to Containment compared with a vented RCS. In addition, Turkey Point will be installing low leakage seals which will further reduce the energy release to Containment. The maximum pressure developed over the phase 2 120 hr period when in modes I through 4 is not expected to exceed the Containment design pressure. A confirmatory analysis is needed to determine the vent path size and is being tracked as pending action 1, listed in Attachment 3 of the OIP.

Page 7 of 20

L-2014-041 Enclosure 4.2.3 Current Strategy for RCS Boration OIP Section: Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint, T+24 (hours) - Re-power Boric Acid Transfer Pumps and Charging Pumps, page 8 of 101 "To provide for long term cooling, makeup and boration, the boric acid transfer pumps and charging pumps are repowered from a portable diesel generator. Based on the cooling strategy using AFW/SG FLEX pumps, installation of low leakage RCP seals, and injection of the accumulators, this was not considered to be time critical."

OIP Section: Safety Function: Maintain RCS Inventory Control PWR Portable Equipment Phase 3, page 33 of 101.

"For RCS injection in phase 3, boron mixing equipment will be brought in. The water will be processed by offsite water purification and demineralizing plant provided by the RRC prior to boric acid batching and subsequent injection into the RCS."

Change to Boration Strategy The Charging pumps are utilized for makeup and boration but not long term core cooling. In modes 1 through 4 core cooling is provided by the SGs. In modes 5 and 6 boiling within the core provides core cooling. FPL will provide a permanent hose connection to the Primary Water Makeup line to the boric acid blender (See Modification 6 above). A hose will be run from the discharge of the SG FLEX pump to the new hose connection providing the ability to blend boric acid from the BASTs. Boric acid mixing will be accomplished with well water supplied to the boric acid batch tank from the SG FLEX pump. During phase 2 in modes 1 through 4, boration is achieved with just the BAST, boric acid transfer pumps, and the charging pumps. In modes 5 and 6, boration is achieved with BAST and SG FLEX pump supplying well water to the primary water line. In phase 2 modes 5 and 6 and in phase 3 the SG FLEX pump is only supplying one units SG or no longer required to provide make-up to the SG since decay heat will be removed using the RHR system power from the 4 KV FLEX Diesel Generator. Therefore, adequate excess capacity is available to provide primary water makeup for blending boric acid.

Once phase 3 is entered and the RHR system is put into service, RCS boiling stops and inventory losses from the RCS is through normal system leakage. Therefore, RCS makeup needs are significantly reduced during phase 3. Given the expected chemistry from the onsite deep well, the SG feed pumps can provided long term RCS makeup. In addition, after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> additional resources would be available to provide demineralized water to the site.

However, other tanks with demineralized water are available onsite to provide feed and bleed to the RCS. The CST and RWST are qualified for tornado winds. Under ELAP conditions no other external event need be considered concurrent with a tornado. The current licensing basis for the Primary Water Storage tanks (PWST), Demineralized Water Storage Tank (DWST) and the Unit 5 Demineralized Water Storage Tank does not include qualification for tornado winds or missiles. They are qualified for hurricane wind speeds.

The design basis tornado missile protection for Turkey Point includes redundancy and Page 8 of 20

L-2014-041 Enclosure separation between SSCs. The PWSTs are located adjacent to the RWSTs and are separated by approximately 130 ft. The common nuclear DWST is located on the West side of the Unit 3 and 4 Containment and is separated from the RWSTs by over 400 ft. The Unit 5fossil DWST is over 500 ft west of the RWSTs and over 1,200 ft north of the RWSTs. Given the intervening structures and separation between the RWST and the DWST and PWST tanks, reasonable assurance exist that at least one would be available as a source of water during phase 3 for long term RCS makeup.

4.2.4 Current Strategy for Makeup to RCS in Modes 5 and 6 OIlP Section: Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint, Discharge of Accumulator Tanks in Mode 6 and Mode 5, without Steam Generators Available, Page 9 of 101 "Sufficient volume is available in the accumulators or RWST for makeup and cooling prior to core un-covery. Calculations will be completed to provide a definitive time for an action to open manual valves to inject the tanks or initiate gravity flow from the RWST's. This is being tracked as pending action 7 in Attachment 3. Based on preliminary calculations, these are not expected to be a time critical actions."

Change to Strategy for Makeup to RCS in Modes 5 and 6 Given the small volume available from the Accumulator's and the maintenance that is typically done on accumulator valves and instrumentation during refueling outages, they will not be credited as a makeup source during modes 5 and 6 with RCS vented. The RWST has adequate volume to provide makeup during modes 5 and 6 for at least 70 hrs. Makeup from the boric acid system and Charging pumps can be provided after the RWST is depleted. If the accumulators are available, they will be identified as potential makeup source in FSG procedures.

4.2.5 Current Strategy for FLEX Building OIP Section: Identify how strategies will be deployed in all modes, Page 9 of 101 "The chosen location for the FLEX Storage Building will be in the protected area. The building elevation will be well above the surrounding land features with no significant barriers, foliage or overhead lines impeding access to the proposed staging areas."

OIP Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2, Storage / Protection of Equipment: Describe storage / protection plan or schedule to determine storage requirements.

Seismic, Flooding, Severe Storms : Temporary strategic locations will be used until building construction completion.

High Temperatures: Storage of FLEX equipment in the FLEX Equipment Storage Building (FESB) will include ventilation to maintain temperatures within the manufacturer's recommendations.

Page 9 of 20

L-2014-041 Enclosure Change to Strategy for FLEX Building The FLEX building floor elevation will be at elevation 17.7 ft NAVD88. The revised still water flood height determined in the Flood Hazards Re-evaluation Report (FHRR) provided in Reference 7 is 17.3 ft NAVD88. The east side of the plant is subject to wave run-up of an additional 1.8 ft or an elevation of 19.1 NAVD88. The doors to the FLEX storage building will be located on the west side of the building where they will not be subject to direct wave impact. Doors at the 17.7 ft elevation will be provided with water resistant seals to reduce any potential for water entry into the building. All equipment stored within the FLEX building will be stored in a manner that will prevent damaged during a seismic event. The construction schedule will be complete prior to delivery of any FLEX portable equipment eliminating the need for temporary storage location. Due to concerns with thermal aging of equipment stored within the FLEX building, the FLEX storage areas will be air conditioned.

FPL commits to follow the EPRI Maintenance/PM guidelines for FLEX equipment.

The existing guidance in NEI 12-06 section 10.1 indicates that at least N+ 1 sets of portable on-site equipment stored in diverse locations or in structures designed to reasonable protect from applicable. The FLEX building will provide a robust structure for all portable FLEX equipment including spares. NEI 12-06 Section 3.2.2 indicates that cables and hoses should also have spares (N+ 1). The hoses and cables utilized for deployment of FLEX strategies will have adequate design margin, be stored in a conditioned environment and appropriately tested and inspected. Hoses and cables are passive devices and unlikely to fail given the design and maintenance practices employed. Multiple strategies utilize hoses and/or cables.

It is not reasonable to assume all would become damaged or be defective when deployed in different plant locations or removed from the storage building. Therefore, FPL does not plan on storing a complete N +1 set of spare hoses and cables for all strategies within the FLEX storage building. FPL will maintain a spare quantity of hoses and cables that will allow replacement of the longest individual run for any of the strategies. This approach meets the N+I for a single hose or cable deployment.

4.2.6 Current Strategy for Providing Make-up to RCS OP Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Installed Equipment Phase 1, (Mode 6 and Mode 5 without Steam Generators Available) page 17 and 18 of 101.

"Actions to allow gravity feed from the RWST, or manual opening of the accumulator isolation valves as an alternative if available, will be the strategies credited for phase I for RCS inventory makeup. Such actions should be completed as soon as possible after the ELAP and LUHS event to provide RCS makeup. Once the RCS FLEX pump is available, it will be used to control flow such that adequate coolant level is maintained in the RCS."

O1P Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2, Modes 5 and 6 without Steam GeneratorsAvailable, page 22 of 101.

"The primary method for making up for the boil off from the RCS in Modes 5 and 6 is repowering the Charging pump from the FLEX DG to supply water from the surviving Page 10 of 20

L-2014-041 Enclosure RWST. The alternate method is to use the RCS FLEX pump to inject water from the RWST to the RCS."

OIP Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2, Modes ] and 5 with Steam GeneratorsAvailable, page 33 of 101.

"The method of injecting this water into the RCS would either be to repower a Charging pump and Boric Acid Transfer pump from the FLEX DG or to connect the RCS FLEX pump to allow pumping of RWST water into the RCS. Operation of the Charging pump must be done at full speed because cooling to the hydraulic coupling oil cooler from CCW is not available (Ref.2 1). Suction for the RCS FLEX pump would come from a connection in the RWST manway and its discharge would be to the drain lines off each Charging pump's discharge."

Change to Strategy for Providing Make-up to RCS FPL will use the permanently installed charging pumps powered by the portable FLEX Diesel Generator as both the primary and alternate makeup methods to the RCS except when RCS is vented and gravity feed from the RWST is used as the primary method and a chargnging pump is the alternate. The RCS FLEX pump has been eliminated (See modification 6 in Section 4.1). In addition, a cooling water source will be provided from the SG FLEX pump to the existing permanently installed hose connection on the Charging pump oil cooler. This will allow more flexibility in operating the charging pumps.

4.2.7 Current Strategy for RCS Makeup and Sub criticality using Accumulators 0IP Section: Safety Function: Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2, Modes 5 and 6 without Steam Generators Available, page 22 of 101 "The NPOs will depressurize the steam generators via the SDTAs to a pressure of approximately 170 psig (Ref. 12)."

OIP Section: Safety Function: Maintain RCS Inventory Control PWR Portable Equipment Phase 2, Modes 1 through 5 with Steam Generators Available, page 33 of 101 For RCS inventory control and long term sub-criticality in phase 2, the credited action will be to cooldown and depressurize the RCS for injection of boron and coolant inventory from the accumulators. This will be done after make-up has been established to the CST's. Depressurizing the RCS to inject the accumulators occurs when the steam generators are depressurized to 170 psig per EOP-ECA-0.0 (Ref.

12). The heat removed by depressurizing the steam generators also cools and depressurizes the RCS. The primary method for accomplishing RCS makeup in phase 2 is the use of the accumulators to make up for losses from the RCP Low Leakage Seals and for contraction of the primary due to cooldown. Alternate strategies involve the use of Boric Acid Storage Tank (BAST) or RWST inventories Page 11 of 20

L-2014-041 Enclosure through installed Charging and Boric Acid Transfer pumps or onsite portable RCS FLEX pump.

Following injection of sufficient accumulator volume, the accumulators are isolated to avoid nitrogen injection into the RCS. Per (Ref. 12), accumulator isolation must occur prior to depressurizing below 80 psig."

OIP Section: Safety Functions Support PWR Portable Equipment Phase 1 and 2, Key Parameters, pages 58 and 62 of 101 Key Parameters

" Steam generator water level (narrow range)

" Steam generator pressure "Reactor coolant system pressure (wide range)

"Reactor coolant system pressurizer level

" Reactor coolant system hot and cold leg temperatures

" Containment pressure

" Spent fuel pool level

" Containment temperature

• Core exit thermocouples

" Reactor vessel level

• Neutron flux

• DC bus voltage "AFW pump flow

• CST level

" RWST Level

• Accumulator pressure Change to Strategy for RCS Makeup and Sub criticality using Accumulators The final minimum SG pressure for injecting the accumulators will be calculated using the methodology from PWROG Core Cooling Position Paper RevPA-PSC-0965. Results of the calculation will be reported in a future 6 month update. In addition, FPL will add accumulator level indication a Key Parameter. OIP Attachment 6, Figure 1 Instrumentation list has been updated and included in Attachment 5. Spent fuel level indication will not be powered from the FLEX diesel generator but will have its own internal battery.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FPL expects to comply with order EA- 12-049 by the required implementation date and no relief/relaxation is required at this time.

Page 12 of 20

L-2014-041 Enclosure 6 Pending Actions from Overall Integrated Plan and NRC Interim Staff Evaluation Open Items The following tables provide a summary of the open items documented in the Overall Integrated Plan or the draft Safety Evaluation (SE) and the status of each item. Completion dates for the Overall Integrated Plan pending actions remain unaffected.

No. Overall Integrated Plan Open Item Target Completion Status (Pending Actions) Date I Perform a revised analysis of the containment structure once the Analysis started using detailed performance parameters for Jun 2014 MAAP computer code the shutdown seals are obtained and using more realistic heat input (See note 1 and 3) parameters.

2 A hydraulic analysis will be performed to determine the minimum requirements of the portable FLEX Started pumps and connection point sizes. Jun 2014 The outputs of this analysis will (See note 3) include a minimum flow and discharge pressure for each pump.

3 A hydraulic analysis will be performed to support the ability to heat up from Mode 5 to a condition where the AFW pumps are removing Jun 2014 Not Started decay heat via the SGs.

4 Heat loads will be removed via the SFP Cooling heat exchangers, RHR heat exchangers, and Containment Jun 2014 Not started Coolers. Analysis will be required to determine the minimum requirements for UHS RRC pump.

5 Analysis will be required to determine fuel requirements of FLEX equipment. This analysis will determine requirements and Started capabilities of onsite FLEX portable Jun 2014 (See note 3) pumps and diesel generators for Phase 2.

Page 13 of 20

L-2014-041 Enclosure No. Overall Integrated Plan Open Item Target Completion Status (Pending Actions) Date 6 A determination of the "drop off' location from the RRC is pending. Oct 2014 Started Once selected, the path to the site will (See note 3) be reviewed.

7 An analysis will be performed to establish the timeline for SI or RWST Jun 2014 Started injection for Modes 5 & 6 8 Complete a final assessment of haul paths and staging areas to confirm access including review for soil Sept 2014 Not Started liquefaction 9 The generic WCAP guidance recommends that a site-specific Started, evaluation be performed once the seal Jun 2014 (See note 2and 3) design is completed to validate that the cooldown and depressurization time is supported.

Notes

1. The MAAP computer model for Turkey Point was developed by an FPL vendor under their IOCFR50 Appendix B software control program. After delivery to FPL, the model has been controlled under the FPL 10CFR50 Appendix B software control program.

2. FPL has entered into a contract with FLOWSERVE Inc to purchase NX seals. Preliminary test data has been sent to FPL with final test data expected by March 2014. Request for proposals have been sent to respect vendors to perform the RCS cooldown analysis using draft test data.

3. This action has been identified as an NRC confirmatory action and will be removed from the pending action table in the next 6 month update.

NRC Interim Staff Evaluation Open Item* Status 3.2.1.8.A- Core Sub-Criticality - Confirm that Turkey FPL will follow the Westinghouse Point will apply the generic resolution for boron mixing guidance for ensuring adequate boron under natural circulation conditions potentially involving mixing when borating the RCS two-phase flow, in accordance with the PWROG position (Reference 4). The NRC acceptance paper, dated August 15, 2013, and subject to the of the Westinghouse guidance conditions provided in the NRC endorsement letter dated required additional considerations January 8, 2014. Alternatively, justify the boric acid when using the guidance (Reference mixing assumptions that will ensure adequate shutdown 5). FPL will implement the additional margin exists through all 3 phases of an ELAP event. NRC considerations as follows:

The reactivity calculation and RCS cooldown analysis will include conditions with no reactor coolant Page 14 of 20

L-2014-041 Enclosure system leakage and with the highest applicable leakage rate for the reactor coolant pump seals and unidentified reactor coolant system leakage.

Adequate borated makeup will be provided such that the loop flow rate in two phase natural circulation does not decrease below the loop flow rate corresponding to single-phase natural circulation.

Credit for increases in the reactor coolant system boron concentration will be delayed for a minimum of one hour to account for the mixing of the borated primary makeup following the addition of the targeted quantity of boric acid to the reactor coolant system.

3.2.1.9. A- The Turkey Point RCS inventory coping See Attachment 6 strategy involves an alternate approach that relies on repowering one of three installed charging pumps in each unit from multiple power connection points using one of the two 100% capacity, portable 480 VAC FLEX diesel generators. Verify that these installed pumps will be capable of performing their mitigating strategies function following an undefined ELAP event, in contrast to using a portable FLEX pump.

3.2.4.7.A- The licensee relies on separation and See Attachment 7 redundancy of the RWSTs to show that at least one will survive a high wind event with wind-driven missiles.

Verify that the RWSTs are sufficiently robust and that sufficient separation exists between the tanks to support the determination that at least one tank will be available as a water source following a high wind event, as credited in the Turkey Point mitigating strategies.

7 Potential Draft Safety Evaluation Impacts See FPL response to open items in Section 8.

Page 15 of 20

L-2014-041 Enclosure 8 Interim Staff Evaluation Confirmatory Items Confirmatory Item 3.1.1.3.A:

Confirm that the large internal flooding sources that are not seismically robust will not impact the implementation of the mitigating strategies during an ELAP event.

Response

In Progress-This will be included in the next 6 month update Confirmatory Item 3.1.1.4.A:

Off-Site Resources -Confirm the location of the local staging area for the RRC equipment, and that access routes to the site, the method of transportation, and the drop off area have been properly evaluated for all applicable hazards.

Response

In Progress-This is scheduled for completion October 2014.

Confirmatory Item 3.2.1.A:

Confirm recalculation of the boration requirements for the Phase 2 RCS cooldown to provide additional margin and flexibility for the boration activity.

Response

In Progress-This calculation is with FPL for review. Once the calculation is approved, the final results will be included in next 6 month update.

Confirmatory Item 3.2.1.B:

Confirm the analysis used to validate the RCS cooldown and depressurization timeline once the RCP low-leakage seal. design is completed.

Response

In Progress-This is scheduled for completion June 2014. Request for proposals is in progress.

Confirmatory Item 3.2.1.1.A:

Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions before reflux condensation initiates. This includes specifying an acceptable definition for reflux condensation cooling. Confirm that Turkey Point has properly applied these conditions for the ELAP analysis.

Response

The code and methodology for performing the RCS cooldown analysis has not been selected. If NOTRUMP code is used, these issues will be addressed as applicable.

Page 16 of 20

L-2014-041 Enclosure Confirmatory Item 3.2.1.1.B:

Confirm recalculation of the SG pressure setpoint to prevent injection of nitrogen from the accumulators using the guidance in the PWROG position paper.

Response

In Progress-As part of the FSG procedure for controlling the RCS cooldown, a setpoint calculation will be developed using the PWROG position paper methodology. The milestone for completing FSG procedures is September 2014.

Confirmatory Item 3.2.1.2.A:

Confirm that the RCP seal leakage rate of one gpm/seal for the FlowServe safe shutdown/low leakage seals used in the ELAP analysis is adequately justified, including the computer code/methodology and assumptions used, and the supporting test data applied, when the site specific evaluation is performed.

Response

In Progress-FLOWSERVE will transmit the certified test report by end of February and leakage data will be included in the planned plant specific analysis scheduled for completion June 2014. Request for proposals is in progress.

Confirmatory Item 3.2.1.5.A:

Confirm that the instrumentation used to measure the listed parameters and the associated setpoints, credited in the ELAP analysis for automatic actuations and indications required for the operator to take appropriate actions, is reliable and accurate in the containment harsh conditions resulting from an ELAP event.

Response

In Progress- All of the essential instruments located in Containment listed in the updated OIP list (see Attachment 5) are environmental qualified (EQ) per 10CFR50.49 criteria for accident conditions except:

Safety Injection Accumulator Level Transmitters Reactor Vessel Level Instruments Core Exit Thermocouples The non-EQ qualified instruments been evaluated for providing post-accident indication and all have been found acceptable as Regulatory Guide 1.97 category A type I variables except for containment pressure transmitters which are type B category 1. Based on the initial Containment heatup analysis under ELAP conditions described in the OIP, EQ accident conditions bound the ELAP containment conditions. However, an updated analysis will be performed once the RCP seal leak rate is confirmed scheduled for completion June 2014. Once the final containment environment is defined, all instruments will be evaluated for operation under ELAP conditions. The results of the evaluation will be reported in the next 6 month update.

Page 17 of 20

L-2014-041 Enclosure Confirmatory Item 3.2.1.6.A:

Confirm that the revised Modular Accident Analysis Program containment analysis supports the revised strategy for maintaining containment (reliance on containment venting instead of containment spray), and also confirm that the Sequence of Events timeline is properly revised and any impacts of the changes are appropriately addressed.

Response

In Progress-The re-analysis of for Containment will be performed once the RCP seal leak rate is confirmed which is scheduled for completion June 2014. Once the analysis is completed, the time line will be updated and reported in the next 6 month update.

Confirmatory Item 3.2.1.9.B:

Confirm completion of the licensee's final engineering designs and supporting analyses for portable equipment that directly performs a FLEX mitigation strategy.

Response

In Progress-This is scheduled for completion June 2014. Analysis has started and is on schedule.

Confirmatory Item 3.2.4.1.A:

Confirm that that the charging pumps have adequate cooling following an ELAP event (i.e., through intermittent operation, or by providing cooling to the fluid drive heat exchanger).

Response

In Progress- As part of modification 6 design package, the required flow will be determinied. The hydraulic analysis for portable FLEX equipment will verify that the portable SG FLEX has adequate capacity to supply the oil coolers. This is scheduled for completion June 2014.

Confirmatory Item 3.2.4.4.A:

The NRC staff has reviewed the licensee communications assessment (ADAMS Accession Nos. ML12300A425 and ML13064A359) and has determined that the assessment is reasonable (ADAMS Accession No. ML13149A382). Confirm that upgrades to the site's communications systems have been completed.

Response

In Progress-The design package for providing backup power to the phone system along with other communication upgrades described in ML12300A425 and ML13064A359 have started and are on schedule to meet the June 2014 modification milestone.

Confirmatory Item 3.2.4.9.A:

Confirm completion of the refueling plan for portable FLEX equipment and sizing of the refueling trailer.

Response

In Progress- This is schedule for completion June 2014. Analysis has started and is on schedule.

Page 18 of 20

L-2014-041 Enclosure Confirmatory Item 3.4.A:

Confirm that NEI 12-06, Section 12.2 guidelines 2 through 10 regarding offsite resources have been adequately addressed.

Response

In Progress- FPL has signed a contract for support from the Strategic Alliance for FLEX Emergency Response (SAFER) Regional Response Center (RRC) run by AREVA. As part of the contact a procedure will be developed to address NEI 12-06 Section 12.2 requirements. FPL has started development of the procedure which is on track for meeting the January 2015 milestone.

9 Enclosure References

1. L-2013-061, Florida Power and Light Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049)," dated February 26, 2013, ADAMS Accession No. ML13072A038

2. NRC Order Number EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, ADAMS Accession No. ML12056A045

3. L-2013-249, Florida Power and Light Company's, Turkey Point Units 3 and 4, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 21, 2013, ADAMS Accession No.ML13248A311

4. Westinghouse Letter, LTR-FSE-13-46, Rev. 0, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG), Dated August 15, 2013, Proprietary ADAMS Accession No ML13235A135

5. NRC Letter from Jack Davis, Director, Mitigating Strategies Directorate Office of Nuclear Reactor Regulation to Mr. Jack Stringfellow, Pressurized Water Reactors Owners Group, dated January 8, 2014, ADAMS Accession No. ML13276A183

6. NRC Letter, Turkey Point, Units 3 And 4 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order Ea-12-049 (Mitigation Strategies) (TAC NOS. MF0982 AND MF0983), dated February 6. 2014, ADAMS Accession No. ML14002A160

7. FPL Letter, L-2013-087, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding the Flood Hazard Reevaluation of Recommendation 2.1, dated March 11, 2013, ADAMS Accession No. ML13095A196 Page 19 of 20

L-2014-041 Enclosure 10 Attachments

1. Revised OIP Modification No. 2 Figure

2. Revised O1P Modification No. 5 Figure

3. Revised OUP Modification No. 6 Figure

4. Revised OUP Modification No. 7 Figure

5. Revised OIP Attachment 6, Instrumentation and Credited Equipment

6. IER Open Item 3.2.1.9.A Response RCS Inventory makeup Strategy

7. IER Open Item 3.2.4.7.A- RWST separation and redundancy Page 20 of 20

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Figure 1 Instrumentation Instrumentation Parameter Transmitter Short term Long Term Available Essential EQ Power Power Alternative Function Method S/G-3A(4A) PT- Core Y Pressure 474/475/476 Battery to Portable AC Portable test Cooling S/G-3B(4B) PT- inverter to P orta eq test Core Y Pressure 484/485/486 120V vital generator to equipment at Cooling PT- AC power battery instrument racks 494/495/496 panels chargers per O-ONOP-103.3 Core Y S/G-3C(4C)

Pressure Cooling S/G-3A(4A) LT- Core Y Narrow 474/475/476 Cooi Range Level BCooling Range LTevinBattery S/G-3B(4B) LT- inverter to to Portable geeao ACo Portable test eupeta oe Y Narrow 120V vital generator to equipment at Core Range Level 484/485/486 AC power battery instrument racks Cooling Rage C LT-e Apanels chargers per O-ONOP- 103.3 S/G-3C(4C) LT- paesCore Y Narrow Range 494/495/496 Cooling Range Level Battery to Portable AC NA FT-1401 A/B, inverter to P orta AC AFW flows 1457A/B, 120V vital generator to Local indications Core 1458A/B AC power batterC panels chargers Battery to Portable AC Core NA in verter to Unit 3(4) CST LT-6384A/B 120V vital generator to Local indications Core Level LI-6584 AC power battery Cooling panels chargers Page 1 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Figure 1 Instrumentation Instrumentation Parameter Transmitter Short term Long Term Available Essential Power Power Alternative Function Method RCS WR T- SG pressures Core Y Cold and Cooling steam tables, y Battery to Portable AC CETC QSPDS A inverter to 120V to temperatures, RCS WR T- QSPDS B vital AC power generator Portable test Core Hot panels battery chargers equipment at Cooling instrument racks per 0-ONOP- 103.3 Battery to Portable test Y ND-6649A inverter to 120V Portable AC equipment at Core Neutron Flux ND-6949B vital AC power generator to instrument Cooling panels battery chargers racks per 0-ONOP- 103.3 Core Exit TE- 1 to TE- Battery to Portable test N Thermocouple 51, inverter to 120V Portable AC equipment at Core (CETC) QSPDS A vital AC power generator to instrument Cooling temperature QSPDS B panels battery chargers racks per 0-ONOP- 103.3 Battery to Portable test Y LT-459 Pressurizer inverter to 120V Portable AC equipment at Core level LT-460 vital AC power generator to instrument Cooling LT-461 panels battery chargers racks per 0-ONOP- 103.3 Battery to None; heated N Reactor Vessel level QSPDS A inverter to 120V Portable AC junction must Core (RVLIS), QSPDS B vital AC power generator to be powered Cooling ICCS RVL panels battery chargers through existing panel Battery to Portable AC SG pressures Y RCS WR PT-404 inverter to 120V P orta AC SG p s Core Pressure PT-406 vital AC power generator to (while RCS is Cooling panels battery chargers at saturation)

Page 2 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Figure 1 Instrumentation Instrumentation Parameter Transmitter Short term Long Term Available Essential Power Power Alternative Function Method LT-920 LT-920 Portable testN N Cold Leg LT-922 Battery to Portable AC equipment at Accumulator LT-924 inverter to 120V P orta ACsequment Core (CLA) wide LT-926 vital AC power generator to instrument Cooling range level LT-928 panels battery chargers racks per 0-LT-930 ONOP- 103.3 Battery to Portable AC Localgauge N MT Prssure PT-6306A inverter to 120V PotbeA Lcague MT Pressure PT-6306B vital AC power generator to at 3/4-2063 or Containment panels battery chargers -2059 vent Portable test Y Battery to CTMT TE- inverter to 120V Portable AC equipment at Temperature vital AC power generator to instrument Containment 6702 panels battery chargers racks per 0-panels_ _ONOP-103.3 SFP Level New modification being developed per EA- 12-051 Local visual SFP Level NA DC bus Local meters Battery Battery Local meters Battery NA voltage Capacity Local NA Battery to pressure Core RWST level LI- inverter to 120V generator to gauges PJC- Cooling, 6583A/6583B vital AC power battery chargers 957A/957B, Containment panels and PI-I_ 1596A/1596B Page 3 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Permanent (Installed) Equipment Permanent (installed) equipment to be utilized in the overall FLEX coping strategies includes equipment in the following systems:

AFW System and CST Refueling Water Storage Tank (RWST)

RHR System CCW System SFP Cooling System Containment Heat Removal System Safety Injection System (Accumulators)

CVCS System 480 and 4KV Electrical Distribution Systems 125 DC System Control Building HVAC Systems For permanent equipment to be credited for FLEX actions, the equipment must be rated as ASME SC 3 or better or listed as Safety Related by PTN. Equipment not rated to AMSE SC 3 or better is not credited in the overall coping strategies detailed in previous sections. However, if some of this equipment is available following a ELAP and LUHS event, it should be used to mitigate any potential adverse consequences due to the ELAP and LUHS event.

Onsite FLEX Equipment The overall coping strategies rely on providing active onsite equipment to provide flow and power. This equipment is required to be stored in structures that meet the external hazards requirements of NEI 12-06. Other equipment will be required to be in the qualified storage structure(s) as part of the overall coping strategies and includes hoses, hose to piping adapters, fans, electrical cables, communications equipment, portable lighting, diesel fuel transfer tank, and debris removal equipment.

Page 4 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Offsite FLEX Equipment Offsite FLEX equipment will be provided by the Regional Response Center (RRC).

This equipment must be rated for the minimum requirements of the phase 3 strategies detailed above. Major equipment expected to be available from the RRC includes additional diesel powered pumps, large diesel generators, and large diesel fuel supply. Other items include additional hoses, radiation protection equipment, personnel commodities, and portable lighting.

The following Attachment 6 Tables 1 and 2 describe the onsite and offsite phase 2 and phase 3 FLEX Credited Equipment respectively:

Page 5 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Table 1 PWR Portable Equipment Phase 2 Maintenance List portable PerformanceCriteria Maintenance/ PM equipment Core Containment SFP Instrumentation Accessibility requirements Three (3) Diesel X X X X X 600 kW, 480V Will follow EPRI Generators template requirements Four (4) Electrical X X X X X 800 feet, 480V cables Will follow EPRI Cables with quick connect template requirements fittings, 750 Amps continuously Three (3) SGPump X 300 gpm, 300 psi (min) Will follow EPRI template requirements Three (3) Discharge X 500 feet each Will follow EPRI Hoses for SGPump template requirements Three (3) Suction X 50 feet each Will follow EPRI Hoses for SG Pump template requirements Three (3) SFP X 250 gpm, 150 psi Will follow EPRI Makeup Pumps (min), 200 psi (max) template requirements Three (3) Discharge X 2000 feet Will follow EPRI Hoses for SFP Pump template requirements Three (3) Suction X 50 feet with Suction Will follow EPRI Hoses for SFP Pump Strainer template requirements Hand Loader and X 80 psi (min), 200 psi Will follow EPRI Nitrogen Bottles for (max) template requirements SDTA operation L-2014-041 Enclosure Page 6 of 10 Revision 0, 2/28/2013

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Table 1 PWR Portable Equipment Phase 2 Maintenance List portable Core Containment SFP Instrumentation Accessibility Performance Criteria Maintenance /PM equipment requirements Fuel Trailer With Installed Fuel Will follow EPRI Transfer Pump template requirements L-2014-041 Enclosure Page 7 of 10 Revision 0, 2/28/2013

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Table 2 PWR Equipment Phase 3 Use and (potential/flexibility)diverse uses Maintenance List portable equipment Performance Maintenance/

Core Containment SFP Instrumentation Accessibility Criteria PM requirements Two (2) Large Load Diesel X X X X X 4160V, 3750 To be addressed Generators kVA, 150 Amps, by RRC 2 connection points One (1) Medium Diesel X X X X X 480V, 700 kVA, To be addressed Generators 600 Amps, 10 by RRC connection points Electrical Cables X X X X X 800 feet, 480V To be addressed cables with quick by RRC connect fittings, 750 Amps continuously Two (2) UHS Pumps X X X 9000 gpm, 8" To be addressed connection by RRC Two (2) UHS Pump Hoses X X X 500 feet each To be addressed by RRC Page 8 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Table 2 PWR Equipment Phase 3 Use and (potential/flexibility) diverse uses Maintenance List portable equipment Performance Maintenance/

Core Containment SFP Instrumentation Accessibility Criteria PM requirements Two (2) SG Pump X 300 gpm, 300 psi To be addressed (min), 150 feet by RRC from suction Two (2) Discharge Hoses for X 500 feet each To be addressed SG Pump by RRC Two (2) Suction Hoses for X 50 feet each To be addressed SG Pump by RRC Boric Acid X 4000 lbs (25 lb To be addressed bags) by RRC Two (2) SFP Makeup Pumps X 250 gpm, 150 psi To be addressed (min), 200 psi by RRC (max)

Two (2) Discharge Hoses for X 2000 feet To be addressed SFP Pump by RRC Page 9 of 10

L-2014-041 Enclosure Attachment 5 OIP Attachment 6 Credited Equipment Table 2 PWR Equipment Phase 3 Use and (potential/flexibility) diverse uses Maintenance List portable equipment Performance Maintenance/

Core Containment SFP Instrumentation Accessibility Criteria PM requirements Two (2) Suction Hoses for X 50 feet with To be addressed SFP Pump Suction Strainer by RRC Bulk Diesel Fuel X X X X X To be addressed by RRC Page 10 of 10

L-2014-041 Enclosure Attachment 6 Turkey Point IER Open Item 3.2.1.9.A Status In the first Turkey Point 6 month update, Reference 3, FPL changed the strategy for repowering the Charging pumps. Two Charging pumps (one in each Unit) will be repowered from two portable FLEX Diesel Generators (DG) connected to independent permanently installed 480 VAC load centers instead of the load side of the breaker to the pump. The new 480V connections for the 480V load centers will be through dedicated permanently installed breakers protected from all hazards for Class 1 equipment. One primary connection through the A train breaker and one alternate train connection through the B train breaker in each Unit. The FLEX DG for each Unit will be connected either train to repower the desired Charging pump. The revised configuration meets NEI 12-06 guidance since all required electrical distribution equipment and circuits including batteries and battery chargers are designed to Class 1E requirements and are located in a Class 1 structure or protected from external hazards. A single train of AC power provides adequate power for baseline coping capability. It is noted that the 480V load centers are within a Class I structure that is elevated well above all flood hazards including the hurricane storm surge which is the bounding flood hazard. Therefore, it is reasonable to expect all such equipment to remain functional and available after a BDB external event.

The second 6 month update substitutes the strategy to use the redundant and diverse Charging pumps for the RCS portable makeup pump. The following provides the basis for this strategy.

Section 3.2.2 Minimum Baseline Capabilities, Item 13 (13) Use of portable equipment, e.g., portable power supplies, portable pumps, etc.,

can extend plant coping capability. The procedures/guidance for implementation of these portable systems should address the transitions from installed sources to portable sources.

The use of portable equipment to charge batteries or locally energize equipment may be needed under ELAP/LUHS conditions. Appropriate electrical isolations and interactions should be addressed in procedures/guidance. Regardless of installed coping capability, all plants will include the ability to use portable pumps to provide RPV/RCS/SG makeup as a means to provide a diverse capability beyond installed equipment. The use of portable pumps to provide RPV/RCS/SG makeup requires a transition and interaction with installed systems.

The following NEI 12-06 Sections provide the rational for the final strategy to be used at Turkey Point 3.2 PERFORMANCE ATTRIBUTES

" ... The baseline assumptions have been established on the presumption that other than the loss of the ac power sources and normal access to the UHS, installed equipment that is designed to be robust with respect to design basis external events is assumed to be fully available. Installed equipment that is not robust is assumed to be unavailable..."

Page 1 of 3

L-2014-041 Enclosure Attachment 6 Turkey Point IER Open Item 3.2.1.9.A Status 3.2.1.3 Initial Conditions (6) Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available."

From Table D Summary of Performance Attributes for PWR Core Cooling Functions Safety Function - RCS Inventory Control/Long - Term Subcriticality o Method - Low Leak RCP Seals and/or borated high pressure RCS makeup required o Baseline Capability - Site analysis required to determine RCS makeup requirements / Boration and/or letdown path may be required o Purpose - Extended coping without RCS makeup is not possible without minimal RCS leakage. Plants must evaluate use of low leak RCP seals and/or providing a high pressure RCS makeup pump.

o Performance Attributes - Makeup capability to maintain core cooling*.

Sufficient letdown to support required makeup and ensure subcriticality*.

• Note: Items are subject to generic or plant-specific analysis" Safety Function- Core Cooling and Heat Removal (Modes 5 and 6 with steam generators not available) o Method - All Plants Provide Means to Provide Borated RCS Makeup **

o Baseline Capability- Diverse makeup connections to RCS for long-term RCS makeup and residual heat removal o Purpose - Long-term sustained coping will require RCS makeup and boration.

o Performance Attributes - In order to address the requirement for diversity, if re-powering of installed charging pumps is used for this function, then either (a) multiple power connection points should be provided to the charging pump, or (b) provide a single power supply connection point for the charging pump and a single connection point for a portable makeup pump.

Basis for Use of Two Charging Pumps The 480V load centers are physically separated in two robust structures elevated above all flooding hazards. In addition the raceways to the pump motors are also robust. Utilizing two independent charging pumps provides the same or greater diversity as a single RCS portable pump with two connection points. The charging system provides at least two different delivery points to the RCS. The portable FLEX DG connected to either independent 480 V load center provides the diversity using portable equipment for the RCS makeup function. The Turkey Point Page 2 of 3

L-2014-041 Enclosure Attachment 6 Turkey Point IER Open Item 3.2.1.9.A Status Charging pumps will be powered in a manner that meets NEI Sections 3.2 and 3.2.1.3. In addition, providing the ability to power two independent charging pumps from two independent and robust sources is equivalent from a diversity stand point to powering a single installed charging pump at two different locations. Therefore, in lieu of using a portable FLEX pump and/or locally powering a charging pump, the installed charging pumps powered by independent and robust sources provide adequate diversity for RCS makeup following an ELAP event.

Page 3 of 3

L-2014-041 Enclosure Attachment 7 Turkey Point IER Open Item 3.2.4.7.A Status Turkey Point OIP, Key Site assumptions to implement NEI 12-06 strategies, Page 5 of 101 states:

"The refueling water storage tanks (RWST's) are also rugged structures designed to withstand seismic and high wind events. They are exposed to impact from the design basis wind driven missiles. Similar to the CST's, the current licensing basis credits redundancy and separation to address the design basis wind driven missiles. Therefore, survival of one RWST is credited in the strategies."

The current UFSAR Chapter 5E indicates that the RWSTs are not required to achieve safe shutdown. However, Chapter 5E of the original Final Safety Analysis Report, which was reviewed and approved by the NRC as part of the initial operating license, identified that the RWSTs have adequate separation and redundancy to ensure one RWST would survive a design basis tornado missiles. Later versions of the UFSAR eliminated the need for the RWSTs as a boration source to maintain hot standby conditions and changed Chapter 5E accordingly. The existing Boric Acid Storage Tanks located inside a class I structure provide the needed boration sources during a tornado event. No modification or changes were done to the RWST or connected piping that changed their separation and redundancy.

Both RWSTs are rugged structures designed to withstand the design basis seismic and wind events but not tornado generated missiles. Both tanks have nearby structures on the west, north and south directions that provide full height shielding. On the east side there are several structures that provide protection to the lower half of the tanks, and the Cask Crane and support structure that provides partial protection for the full height of both tanks. These structures surrounding the RWST's would be expected to protect both tanks from the wind driven design basis tornado missiles.

NE 12-06 provides the following guidance for protection of FLEX equipment:

Section 7.3.1 (c) Protection of FLEX Equipment In evaluated storage locations separated by a sufficient distance that minimizes the probability that a single event would damage all FLEX mitigation equipment such that at least N sets of FLEX equipment would remain deployable following the high wind event. (This option is not applicable for hurricane conditions).

Consistent with configuration b., the axis of separation should consider the predominant path of tornados in the geographical location.

Consistent with configuration b., stored mitigation equipment should be adequately tied down.

Page 1 of 2

L-2014-041 Enclosure Attachment 7 Turkey Point IER Open Item 3.2.4.7.A Status Basis for RWST Separation Adequacy FPL current licensing basis does not require separation between redundant features to be orientated opposite of the predominant tornado path as previously discussed.

NEI 12-06 Section 7.3. 1(c) allows use of separation as a method for ensuring at least "N" FLEX equipment is available during tornado conditions provided the axis of separation considers the predominant path of tornados. The RWSTs are separated by a distance of approximately 130 ft (check). The 75th percentile width for a Florida tornado is 120 ft. In addition, the typical path of a tornado is from the West - South West direction. Given the historical information for tornados in Florida including widths and prevailing direction, adequate separation distance in the north-south axis is provided for the RWSTs. Additionally, there is significant protection provided by surrounding structures as discussed above and the tanks are rated for tornado wind speeds.

Based on these considerations, and that adequate separation was found acceptable for the Turkey Point design basis tornado missile in the original plant licensing basis, the RWSTs are robust and sufficient separation exist that at least one tank or portions of both tanks will be available as a water source following a high wind event to support ELAP strategies for Modes 5 and 6. For the mode 1-4 ELAP, RCS inventory is maintained by the use of low leakage seals, injection of the accumulators, and makeup from the boric acid storage tanks which provide sufficient volume until the recovery phase 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the initiation of the ELAP event. Therefore, the RWSTs are not needed during modes 1 through 4.

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