L-2013-192, 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)

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)

ML13179A184
Person / Time
Site:	Saint Lucie
Issue date:	06/18/2013
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2013-192
Download: ML13179A184 (2)

Text

0 June 18, 2013 FPL. L-2013-192 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 (FPL)/St. Lucie'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)

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External events," Revision 0, dated August 29, 2012, Accession No. ML12229A174.

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August, 2012, Accession No. ML12242A378.

4. FPL Letter L-2012-385 dated October 25, 2012, FPL's Initial 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), Accession No. ML12300A421.

5. FPL Letter L-2013-084 dated February 28, 2013, Florida Power & Light (FPL)/St.

Lucie'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), Accession No. ML13063A026.

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to FPL/St. Lucie. Reference I was immediately effective and directs FPL/St. Lucie to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference I requires 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 12-06, Revision 0 (Reference 3) with clarifications and Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2013-192 Page 2 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 mitigation strategies, as required by Reference 1.

Reference 5 provided FPL/St. Lucie's Overall Integrated Plan, based on conceptual design information, for mitigation strategies pursuant to Reference 3.

The purpose of this letter is to inform the NRC about a change to the St. Lucie Plant Diverse and Flexible Coping Strategies (FLEX) Integrated Plan regarding the reactor coolant pump (RCP) seal configuration. Page 35 of the attachment in Reference 5 stated that the existing St.

Lucie RCP N-9000 seal packages would be modified to include the new Flowserve Abeyance seal. The revised St. Lucie strategy will be to maintain the current Flowserve N-9000 RCP seal configuration without the Abeyance seal modification. The existing St. Lucie RCP seal configuration is consistent with the N-9000 RCP seal configuration evaluated in WCAP-17601 -P, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs." This revised St. Lucie FLEX approach will also make St. Lucie consistent with the other Combustion Engineering NSSS plants that currently utilize the Flowserve N-9000 seal. The most significant change to the FLEX plan will likely be to initiate the Reactor Coolant System cooldown earlier in the event. The specific changes to the St. Lucie Plant FLEX plan resulting from the decision not to install the Abeyance seals will be provided to the NRC in the August six-month update.

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) 467-7748.

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

Executed on June I6 , 2013.

jRespectfu ly submitted, Site Vice President St. Lucie Plant cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector