L-2014-063, Second Overall Integrated Plan 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 No. EA-12-049)

Second Overall Integrated Plan 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 No. EA-12-049)

ML14064A192
Person / Time
Site:	Saint Lucie
Issue date:	02/26/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2014-063
Download: ML14064A192 (25)

Text

0 FPL. February 26, 2014 L-20 14-063 FPL. 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 Second Overall Integrated Plan 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:

I. 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. ML12054A736.

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),

dated October 25, 2012, 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 forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), Accession No. ML13063A020.

6. FPL Letter L-2013-192 dated June 18, 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. ML13179A184.

7. FPL Letter L -2013-254 dated August 28, 2013, Florida Power & Light (FPL)/St. Lucie's First Overall Integrated Plan 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. ML13242A274.

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

L-2014-063 Page 2 beyond-design-basis external event. 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 12-06, Revision 0 (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 mitigation strategies, as required by Reference I. Reference 5 provided the FPL/St. Lucie Overall Integrated Plan pursuant to Section IV, Condition C. 1, of Reference 1. Reference 6 informed the NRC that St.

Lucie was no longer pursuing reactor coolant pump (RCP) seal package modifications as part of the FLEX strategy. Reference 7 provided the FPL/St. Lucie first six-month Overall Integrated Plan status report.

The purpose of this letter is to provide the second six-month Overall Integrated Plan status report. The information in the enclosure 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 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) 467-7748.

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

Executed on February 2,(a , 2014.

Respectfully submitted, Joseph Jensen Site Vice President St. Lucie Plant

Enclosure:

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

L-2014-063 Enclosure 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 1 Introduction Florida Power and Light (FPL) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 3 for the St. Lucie plant. 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.

To simplify review of impacts the six-month updates have on the original Overall Integrated Plan (Reference 1),

this second six-month update has been formatted as a revision to the first six-month update (Reference 6), thus keeping all updates in one document; changes since the first six-month update are reflected via revision bars in the right-hand margin.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference I 1). Milestone accomplishments are current as of February 14, 2014.

• Submittal of First 6-Month Status Report, August 2013 (Reference 6) a FLEX Strategy (Preliminary) Walkthrough Demonstration

• Submittal of Second 6-Month Status Report, February 2014 (This Document) 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. 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. An additional milestone for FLEX Strategy Walkthrough Demonstration has been added per NEI template revision. The revised milestone target completion dates do not impact the order implementation date.

Target Revised Target Milestone Completion Date Activity Status Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Page 1 of 23

L-2014-063 Enclosure Target Revised Target Milestone Completion Date Activity Status Completion Date Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Feb 2014 Started August 2014 FLEX Strategy Walkthrough Demonstration Feb 2014 Complete Perform Staffing Analysis Oct 2014 Started Modifications:

Unit 2 Implementation Outage Mar 2015 Not Started Unit 2 Implementation Outage Nov 2015 Not Started Storage:

Storage Implementation Mar 2015 Not Started FLEX Equipment:

Procure On-Site Equipment Oct 2014 Started Procedures:

Create Site-Specific FSGs Mar 2014 Started August 2014 Create New/Revisions to OPS Procedures Mar 2014 Started August 2014 Create Maintenance Procedures Mar 2014 Started August 2014 Training:

Develop Training Plan June 2014 Started Training Complete Mar 2015 Not Started Unit 1 FLEX Implementation Mar 2015 Not Started Unit 2 FLEX Implementation Nov 2015 Not Started Full Site FLEX Implementation Nov 2015 Not Started 4 Changes to Compliance Method 4.1 RCP Seal Modification The Reference 1 (page 35 of 102) FLEX response indicated St. Lucie would modify the seals for the reactor coolant pumps of both units to include Flowserve Abeyance seal stages. Reference 2 revised the St. Lucie FLEX strategy to maintain the current Flowserve N-9000 RCP seal configuration without making a Flowserve Abeyance seal modification. The existing St. Lucie 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" (Reference

5) and with the approaches adopted by other Combustion Engineering NSSS plants that currently utilize the Flowserve N-9000 seal. Note that both St. Lucie units have excess flow check valves in the RCP controlled bleed off (CBO) lines and, additionally, have fail closed isolation valves to isolate the CBO leakage pathway.

Station Blackout Emergency Operating Procedures, have an early positive step to isolate the CBO leak path on loss of seal cooling; these procedures will be revised to require that isolation within 10 minutes post event - see Pending Action 73A.

As part of the revised RCP seal approach, St. Lucie will initiate the reactor coolant system cooldown to a steam generator pressure of 120 psia in a 2-6 hour timeframe as opposed to the 10-14 hour timeframe originally Page 2 of 23

L-2014-063 Enclosure indicated in Reference 1. This action is compliant with WCAP-17601-P and eliminates the deviation previously indicated within Reference 1 Attachment I B, NSSS Significant Reference Analysis Deviation Table.

4.2 Condenser Makeup Lines The Reference 1 FLEX response (page 22 of 102) stated that non-seismic condenser makeup lines from the CST would be seismically qualified to provide an additional qualified water inventory for hot standby and cooldown. In a seismic scenario, the qualified contents of the two CSTs and two RWTs will be available to provide approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of Phase 2 coping time. There is reasonable assurance that volumes of one or more non-qualified tanks may also be available. Entry into Phase 3 shutdown cooling (SDC) is expected well before use of makeup of seawater from the Ultimate Heat Sink would be anticipated. Accordingly, the current FLEX strategy does not include a modification to seismically qualify the condenser makeup lines.

4.3 Mechanical Connections The St. Lucie FLEX strategy for making mechanical system connections has evolved from that indicated in Reference 1 response figures to be consistent with NEI 12-06 guidance (Reference 4). Secondary connections may require reconfiguration (e.g., removal of valve bonnet or disassembly of a flanged pipe joint) if validated that time and resources are reasonably available to support the reconfiguration. Location of the connection points provide reasonable assurance that at least one connection will be available for all applicable hazards.

Refer to attached revised mechanical connection figures.

4.4 Electrical Connections The St. Lucie FLEX strategy for making electrical system connections has evolved from that indicated in the Reference 1 response figures to be consistent with NEI 12-06 guidance (Reference 4). Refer to attached revised electrical connection figures; final versions will be provided in a future six-month update. Note the 480 volt connections will now be made using procedurally controlled breakers rather than using transfer switches.

4.5 Boration Requirements for Shutdown Margin The Reference 1 FLEX response (page 37 of 102) discussed boration requirements for shutdown margin.

FPL is currently evaluating the position expressed by the NRC staff regarding the boron mixing issue for PWRs (Reference 7) - see Pending Action 17 and Open Item 3.2.1.8.A in Section 6. The NRC letter states that the NRC staff has reviewed the information submitted to date and concluded that use of the industry approach documented in Reference 8 is acceptable with clarifications listed in the letter.

4.6 RRC LUHS Pump The Reference 1 FLEX response (page 68 of 102) indicated a pump would be provided from the Regional Response Center (RRC) to replace the function of the Intake Cooling Water Pumps due to the Loss of Ultimate Heat Sink (LUHS) event. The design point of the SAFER RRC pump is 5000 gpm at 150 psi. The LUHS Pump criteria mentioned in Reference 1 (page 72 of 102; 7162 gpm, 90 psi) is altered to align with SAFER provided equipment. The nominal flow rate of 5000 gpm is adequate for Shutdown Cooling in the timeframe for entry some 72-120 hours after shutdown. The RRC generic pump has inadequate suction lift for the intended deployment of the RRC pump on the intake structure deck. An RRC supplied diesel/hydraulic driven suction booster pump will be used to provide the required lift capability. This pump combination will allow water to be Page 3 of 23

L-2014-063 Enclosure drawn from the intake structure downstream of the traveling water screens (non-seismic) to address debris concerns in a hurricane scenario. A backup plan will locate the floating booster pumps within the intake canal.

4.7 Makeup Water Sources The St. Lucie FLEX makeup water strategy has evolved from that indicated in the Reference 1 response crediting two Condensate Storage Tanks (CSTs) and one Refueling Water Tank (RWT - borated water source).

The current strategy is consistent with NEI 12-06 guidance (Reference 4), including their response to FLEX Guidance Inquiry 2013-11, "Use of Raw or Untreated Water."

For a seismic based event, the current FLEX strategy credits water volumes within the CSTs and RWTs of both units. All four tanks are seismically qualified, as is the cross-connect line between the CSTs. Tank inventories above the lowest non-seismic line are not credited.

For a high wind-hurricane based event, sufficient warning time will be available to ensure site tanks, e.g.,

CSTs, RWTs, City Water Storage Tanks (CWSTs), Treated Water Storage Tank (TWST) and Primary Water Storage Tanks (PWSTs), are filled with water. Analysis using current licensing basis criteria indicates that water-filled tanks are qualified for a hurricane wind event. Current plant severe weather preparations procedures require all water tanks to be filled when a hurricane watch or warning has been declared. The current FLEX strategy credits the water volumes within the subject tanks for a hurricane event.

For a high wind-tornado based event, site tanks will be pre-filled, as required by administrative procedures.

With respect to tornado winds and missiles, the Unit 2 CST volume is fully qualified and the Unit 1 CST volume is being qualified by analysis. The seven other major tanks (RWTs, CWSTs, TWST and PWSTs) are being qualified for many of the assumed tornado missiles. It can be reasonably assumed that many of these tanks will survive a high wind-tornado based event based on their design, separation and intervening structures; the CWSTs, TWST and/or PWSTs should be available as secondary sources of water to provide makeup to the CSTs/RWTs during Phase 2 following a high wind missile event. An alternate makeup water strategy credits the underground water supply line from Fort Pierce Utilities (FPU), the local potable water supplier; the water supply connection at the north side of the plant site will be tornado missile protected.

4.8 RWT Cross-Connect As stated in the Reference 1 FLEX response (page 18 of 102), the Unit 1 & 2 RWTs are not currently cross-connected. The FLEX response indicated that, as required by the tank evaluations, the RWTs would be cross-connected with a seismically qualified, missile protected line to allow either RWT to be aligned for gravity flow to the SDC piping of either unit. Based on the numerous potential makeup water sources discussed above, as well as guidance provided in the NEI response to FLEX Guidance Inquiry 2013-10, "Shutdown Mode Capability Requirements for PWRs," the current FLEX strategy does not include a modification to install an RWT cross-connect line.

Page 4 of 23

L-2014-063 Enclosure 4.9 DC and Extended DC Load Shedding The St. Lucie DC coping strategy has evolved from that indicated in the Reference I response which was to perform load shedding on both safety related batteries. The revised strategy will be to initially secure one battery, load shed/operate on the other battery and return the secured battery to service before the first battery is depleted (and then secure the first battery). This approach will improve battery margin by using the two batteries in a series operating mode. This revised strategy is still being analyzed, which includes evaluation of specific loads to be shed and any impact to required instrumentation, as well as potential impact to the Control Room heat up evaluation - see Pending Action 26A and Confirmatory Item 3.2.4.10.A in Section 6.

4.10 Steam Generator Makeup- Mode 1-4 The Reference 1 FLEX response indicated a portable pump (FLEX SG Pump) would be used to provide makeup to the steam generators as a backup source should the existing turbine driven Auxiliary Feedwater Pump fail. The pump will be sized to provide 300 gpm at 300 psi discharge (steam generator ring pressure) while drawing from the Condensate Storage Tank. Actual makeup requirements (nominally 130 gpm following cooldown) are considerably less than the 300 gpm design point. The FLEX CST Pump will be used to replenish the Condensate Storage Tank from available site water sources with ultimate backup from the intake (seawater). The FLEX SG Pump will also be capable of drafting from the intake canal at a flowrate near to, but somewhat below, the 300 gpn/300 psi design point.

4.11 Mode 5 & 6 Strategies NEI 12-06 (Reference 4) states that the FLEX strategies are not explicitly designed for outage conditions. FPL will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures (see Reference 9 and 10), as well as that provided in the NEI response to FLEX Guidance Inquiry 2013-10, "Shutdown Mode Capability Requirements for PWRs." As such, pending actions associated with these modes have been closed, including those associated with boron batching alternatives since they are no longer required - both the Unit I and Unit 2 RWTs are now considered available to cope with an event during Mode 5 & 6.

4.12 FLEX Equipment Storage The Reference I FLEX response indicated the FLEX Equipment Storage Building (FESB) will be 170' x 70' and will be capable of housing all required FLEX equipment, including required spares ("+1" equipment). The FLEX strategy has evolved to incorporate NEI 12-06 guidance (Reference 4), including their response to FLEX Guidance Inquiry 2013-07, Reasonable Protection," that spare equipment need not be stored in the FESB. The spare equipment will be now be stored elsewhere on site, resulting in a smaller FESB footprint. The Reference 1 FLEX response also stated the FESB will include natural ventilation to maintain temperatures within the manufacturer's recommendations; in lieu of natural ventilation, air-conditioning is now being provided, which will also limit humidity extremes inside the FESB.

Note that the Reference 1 FLEX response stated the refueling of diesel fuel oil driven equipment will be accomplished via a trailer stored in the FESB, on which will be mounted a 500-gallon tank; the tank size is being evaluated and may be increased.

Page 5 of 23

L-2014-063 Enclosure 4.13 Maintenance and Testing of FLEX Equipment FPL will comply with the EPRI generic industry program for maintenance and testing of FLEX equipment as delineated in References 11 and 12.

4.14 Sequence of Events Timeline The Reference 1 FLEX response included Sequence of Events Timelines. Note that these timelines are under review and may be adjusted via a future six-month update based on ongoing evaluations and development of FLEX strategies.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FPL expects to comply with the order implementation date. No relief/relaxation is required at this time.

6 Pending Actions from Overall Integrated Plan and Draft Safety Evaluation Overall Integrated Plan Pending Actions Status I Seismic re-evaluation of site and submit to NRC. Include Started insights in development of the FLEX integrated plan 2 Flooding re-evaluation of site and submit to NRC. Include Started insights in development of the FLEX integrated plan 3 Establish location of RRC Staging Area (outside of 25 mile Started radius) 4 Review FESB deployment routes for liquefaction Started 5 Determine RRC staging area location and develop Started deployment routes to site 6 Review Communications adequacy during Phase 2 staffing Started study 7 Review Extend DC Shedding Approach regarding potential Started spurious actions 8 Determine alternate plant locations for obtaining critical Started parameters remotely 9 Review 480 VAC Diesel Generator FLEX Sizing Complete. 350 kW DG/unit is required 10 Review 4.16 KVAC Diesel Generator RRC FLEX Sizing Complete. RRC 2MW unit is acceptable 11 Analysis to maintain acceptable CR temperatures during ELAP, identify additional required strategies/ modifications Started 12 Review EER operation up to 129°F for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or provide Started portable fans, initiate FSG/Time Validation as required 13 Qualify UI CST regarding tornado wind hazards, identify Started any required modifications Page 6 of 23

L-2014-063 Enclosure Overall Integrated Plan Pending Actions Status 14 Qualify RWT(s) regarding tornado wind hazards, identify Complete. No modifications required. See any required modifications Section 4.7 and 4.8 15 Review boron batching alternatives, determine approach, Complete. Not Required. See Section 4.7 identify required modifications and 4.11 16 Perform analysis supporting survivability of one or more Started non-qualified water tanks 17 Finalize boration requirements for Cold Shutdown Margin and timing of injection with electrical power availability. Started. Letdown modification is not Ensure letdown flow is not required or provide modification required. See Section 4.5 to provide letdown. Update milestone as necessary.

18 Review boron precipitation during Phase 1&2 (pool boiling) Closed - Not Required. See Section 4.11 and Phase 3 (final cooldown) for Mode 6&5 w/o SGs 19 Evaluate establishment of contract or letter of agreement for Started water supply by tanker trucks 20 Review M5 containment vent path (RWT gravity Closed - Not Required. See Section 4.11 feed/Containment overpressure) Consider LCO 3.9.4, (Note: Reviewed; will now use 30" Escape RAB/CR ventilation. Confirm adequacy of Unit 2 8" mini- Hatch) purge line size.

21 Review potential modification for an 8" relief path to Closed - Not Required. See Section 4.11 prevent U 1 containment overpressure in M5 (and note above) 22 Review safeguard equipment initiation with respect to M5 Complete. Not Required. See Section 4.11 containment vacuum analysis (Note: Reviewed; will lockout equipment) 23 Review LUHS Pumping System RRC FLEX Sizing Started 24 Ensure FHB L-shaped door can be opened in the required Re-Opened; Under Evaluation time frame or identify alternate venting approach 25 Provide Technical Basis for WCAP-1760 1-P deviations to Ongoing. No deviations. See Section 4.1 NRC during six month updates 25A Time validation study for isolation of controlled bleed off Complete and acceptable; CBO lines can (CBO) lines within 10 minutes be isolated within 10 minutes post event Complete and acceptable for current 26 Time validation study for completing DC load shedding strategy - Unit 1: - 30 minutes; Unit 2:

26thin ecvidation Ti s oriom n DC l30 minutes (inverters)/one hour within specified time period (balance); to be re-evaluated (see Action 26A below) 26A Time validation study for completing revised DC load shedding discussed in Section 4.9 within specified time Not Started period, to include any impact to required instrumentation and Control Room heat up 27 Time validation study for Control Room ventilation Complete Page 7 of 23

L-2014-063 Enclosure Overall Integrated Plan Pending Actions Status Closed - Not Required. Battery Room roof exhausters will be powered when the 28 Time validation study for Battery Room ventilation battery room chargers are placed in operation; both will be powered by same FLEX 480V portable diesel-generator.

29 Time validation study for Electrical Equipment Room Complete ventilation 30 Time validation study for FHB ventilation and the deployment and staging of SFP makeup/spray capability Complete 31 Time validation study for 480 VAC diesel generator to the Complete station 480 VAC bus 32 Time validation study for CST non-seismic lines isolation, Closed - Not Applicable. See Section 4.2 as required by design 33 Time validation study for CST cross-connect Complete 34 Time validation study for FLEX CST pump deployment Complete 35 Time validation study for FLEX SG pumps for CST/AFW Complete and acceptable; pumps can be deployed - five hours post event) 36 Time validation study for boration to establish Cold Complete Shutdown Margin (Ml-4 w/SGs) 37 Time validation study for establishing power to SIT MOVs Complete to isolate 38 Time validation study for establishing RWT gravity flow Closed - Not Applicable. See Section 4.11 path to RCS (include mid-loop conditions) 39 Time validation study for FLEX SG pump for RWT/RCS Closed - Not Applicable. See Section 4.11 40 Time validation study for batch boration to maintain borated Closed - Not Applicable. RWT available water supply (M6 & 5 w/o SGs) for makeup use. See Section 4.7 and 4.11 41 Time validation study for venting containment in mid-loop Closed -Not Applicable. See Section 4.11 conditions 42 Time validation study for isolating Fuel Transfer Tube path. Closed - Not Applicable. See Section 4.11 43 Time validation study for establishing containment vent Closed - Not Applicable. See Section 4.11 path.

44 Time validation study for isolating CCW Flow to Closed - Not Applicable. See Section 4.11 Containment Fan Cooler Penetrations 45 Time validation study for hoses for SFP makeup/spray in Complete Phase 1 46 Time validation study for FLEX SFP pump Complete 47 Time validation study for refueling FLEX equipment Started 48 UI & U2 Construct FLEX Equipment Storage Building Started Storage Building Page 8 of 23

L-2014-063 Enclosure Overall Integrated Plan Pending Actions Status 49 U 1 & U2 Install external satellite phone antenna and Started docking stations for TSC & EOF 50 U1 & U2 Install new cabling with disconnects for MCC supplying battery chargers. Alternate connections line side 51 U 1 & U2 Change essential instrumentation source to vital Started 120VAC power panel 52 U1 & U2 Install cabling to Class IE 480 VAC Switchgear A&B for primary and alternate connection of 480 VAC Started FLEX DG 53 UI & U2 Install transfer switches on load side charging pumps and Class 1E battery chargers. Alternate connection. Closed - Not Applicable. See Section 4.4 54 UI & U2 Design cabling/disconnects for Class 1E 4.16 Started (Installation would be performed KVAC busses A&B for Phase 3) 55 U1 & U2 Install RCP low leakage seals Closed - Not Applicable. See Section 4.1 56 U 1 Install ADV seismic pneumatic backup and airpressure Started regulator, provide quick connects Complete and acceptable; Operator actions 56A UI Time validation study for ADV Operator actions can be completed within 90 minutes post event 57 UI Install modifications for CST as required by tornado Not Started wind hazard analysis 58 U 1 & U2 Qualify non-seismic lines penetrating CSTs or use Closed - Not Applicable. See Section 4.2 another approach to qualify additional CST inventory 59 U 1 & U2 Qualify non-seismic CST cross-connect Complete 60 Ul & U2 Install 2 connections per CST for refilling the Started CSTs via FLEX CST pump 61 U 1 & U2 Install 2 connections per CST for suction point for Started FLEX SG pump 62 UI & U2 Install 2 connections on AFW lines upstream of MVs for FLEX SG pump to symmetrically feed both steam Started. See Section 4.3 generators 63 U1 & U2 Install single connections for taking suction on Started (Design Issued; EC 278639) non-qualified tanks 64 U I & U2 Install modifications for RWT as required by Closed - Not Required. See Section 4.7 tornado wind hazard analyses and 4.11 65 U1 & U2 Install RWT cross-connect sized for gravity fill as Closed - Not Applicable. See Section 4.8 required by tornado wind hazard analyses 66 UI & U2 Install 2 connections per RWT for suction point Started for FLEX SG pump/FLEX CST Pump 67 U I & U2 Install 2 connections per RWT for CST FLEX Started pump discharge Page 9 of 23

L-2014-063 Enclosure Overall Integrated Plan Pending Actions Status 68 U1 & U2 Install 2 connections on LPSI pump discharge Started piping for RCS cold leg injection via FLEX pump 69 U I & U2 Install 2 connections on LPSI pump suction piping Started (Mode 6 with Rx head off/SG primary manways off) 70 U I Provide containment vent path to ensure sufficient RWT Closed - Not Required. See Section 4.11 gravideflow for RCS makeup (Note: Reviewed; will now use 30" Escape gravity fHatch) 71 UI & U2 Missile protect ICW line 1-2 1/2-CW-178 located Not Started on the exterior of UI & U2 FHBs 72 Ul & U2 Install ICW manifolds with hose connections and Started isolation valves for LUHS 73 Create new site procedures, including one(s) for use of Started Satellite communications 73A Revise existing site procedures, including EOPs to reflect Started isolation of CBO lines within 10 minutes post event 74 FSG: Establishing FLEX Control Room Ventilation Started 75 FSG: Extended DC bus load shedding Started 76 FSG: Damage assessment following event Started 77 FSG: Accessibility considerations for personnel to enter Started areas to perform local manual actions 78 FSG: Deployment and staging of portable equipment (Onsite Started and Offsite) 79 FSG: Operation of the FLEX equipment (startup, shutdown, Started operational monitoring, minor troubleshooting 80 FSG: Operation of DFO transfueler, filling from U2 DFO Started tanks, filling FLEX portable equipment, etc.

81 FSG: Restore AC power or alternate power sources for Started specific plant equipment 82 FSG: Lighting and communications necessary for ingress Started and egress to plant areas for deployment of FLEX strategies 83 FSG: Deployment and operation of 480 VAC diesel Started generator 84 FSG: Power restoration with ESF signals present due to de- Started energized instrument inverters 85 FSG: Repowering selected station loads to support long term Started safety functions (load management) 86 FSG: Operation of ADVs with backup compressed gas Started 87 FSG: Deployment and operation of FLEX CST pump Started 88 FSG: Maintaining flow to SGs, with identified backup Started sources and criteria for transferring between sources Page 10 of 23

L-2014-063 Enclosure Overall Integrated Plan Pending Actions Status 89 FSG: Deployment and operation of FLEX SG pump Started 90 FSG/EOP-10 to address for FLEX RCS cooldown (cooldown, solid plant conditions, SIT isolation, Attach 1B) 91 FSG: Guidance for SIT injection and isolation Started 92 FSG: Establish RWT gravity flow to RCS and criteria for Started transfer to FLEX SG pump 93 FSG: Guidance for boron mixing Closed - Not Applicable. RWT available for makeup use. See Section 4.7 and 4.11 94 FSG: Deployment and operation of FLEX SFP pump Started 95 FSG: Guidance for isolation of CCW penetrations for CFC Closed -Not Applicable. See Section 4.11 Coolers 96 FSG: Guidance for venting containment in M5/6 Once- Closed - Not Applicable. See Section 4.11 Through-Cooling with LUHS (include CS Lockout) 97 FSG: Deployment and operation of RRC 4.16 KVAC Not Started generator 98 FSG: Deployment and operation of RRC pumping system Not Started for ICW 99 FSG: Deployment and operation of FLEX SG pump: Closed - Not Applicable. See Section 4.11 injection for vapor bound LPSI pump 99A FSG: Transition from FLEX Equipment to Plant Equipment Started 100 Implement FLEX program stipulating the required Started administrative controls to be implemented 101 Confirm adequacy of access provisions for locked areas affected by loss of ac power and address any additional Started guidance or procedure upgrades required 102 Provide final versions of electrical one-line diagrams in a Started future six-month update.

103 Provide update of any changes to dc coping strategy Started. See Section 4.9 Alpha suffixes and numbers above 100 indicate additional items beyond those identified in Reference I Draft Safety Evaluation Pending Items Status Draft NRC Safety Evaluation has not been received. N/A 6A Open and Confirmatory Items from Interim Staff Evaluation The NRC Interim Staff Evaluation and Audit Report on the St. Lucie Overall Integrated Plan has been received via Reference 13, which contained the following two Open Items and 15 Confirmatory Items that FPL is in the process of developing responses to:

Page 11 of 23

L-2014-063 Enclosure Open Items Item Number Description Notes 3.2.1.8.A Core Sub-Criticality - Confirm that St. Lucie will apply the generic resolution for boron mixing under natural circulation conditions potentially involving two-phase flow, in accordance with the conditions provided in the NRC's endorsement letter dated January 8, 2014, or alternately, justify the boric acid mixing assumptions that will ensure adequate shutdown margin exists through all three phases of an ELAP event.

3.2.1.8.B The St. Lucie RCS Inventory coping strategy involves an alternate approach relying on repowering one of three installed charging pumps in each unit using a portable 480 VAC FLEX generator. Justify how these installed pumps will be capable of performing their mitigating strategies function following an undefined ELAP event, in contrast with using a portable FLEX pump.

Confirmatory Items Item Number Description Notes 3.1.1.2.A Confirm that the routes for deployment of FLEX equipment provide for at least one connection point for the FLEX equipment that will only require access through seismically robust structures, consistent with consideration 2 of NEI 12-06, Section 5.3.2.

3.1.1.4.A Confirm that the deployment routes and methods to be used will enable delivery of resources from the RRC staging area to the site following a BDBEE.

3.2.1.A The NRC staff endorsed the PWROG position paper on the use of the Combustion Engineering Nuclear Transient (CENTS) code in the ELAP analysis for Combustion Engineering plants, with the limitation that it can only be applied to the flow conditions prior to reflux boiling initiation. Confirm that the applicable ELAP analyses for St. Lucie meet the above limitation on the use of CENTS.

3.2.1.1 .A Confirm the plant-specific RCP seal leakage rates assumed for St.

Lucie from time zero to the time when subcooling in the RCS cold-legs decreases to 50 degrees F° and confirm the impact of these leakage rates on the plant-specific time constraints and sequence of events (SOE). (Note: The TER, on page 30 of 69, listed an incorrect ADAMS accession number for the August 16, 2013, PWROG position paper on RCP seal leakage; it should be ML13235A151).

3.2.1.2.B Confirm the assumption that the RCP seal leakage rate is less than 1 gpm per RCP during an ELAP before the controlled bleed off is isolated.

Page 12 of 23

L-2014-063 Enclosure Item Number Description Notes 3.2.1.5.A Confirm that the Rosemount pressure transmitters credited in an ELAP event will continue to function in the anticipated environmental conditions.

3.2.1.9.A Justify the use of the NOTRUMP computer code to determine the integrated flow rate required to remove decay heat and sensible heat.

3.2.1.9.B Confirm that the revised calculation for RCS makeup flow demonstrates that the FLEX strategies and equipment can provide sufficient flow to accommodate the sensible heat resulting from cooldown in the 2-6 hour time frame.

3.2.1.9.C Confirm that the pump criteria and the associated analysis support the adequacy of the RRC-supplied pumps to re-establish Shutdown Cooling for Phase 3.

3.2.4.2.A Confirm that the electrical equipment room equipment is analyzed for operation up to a temperature of 129 degrees F° for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or that portable fans will be used to provide adequate room ventilation.

3.2.4.4.A The NRC staff has reviewed the licensee communications assessment (ADAMS Accession Nos. 14L12307A1 16 and ML13057A033) and has determined that the assessment for communications is reasonable (ADAMS Accession No. MLI3134A050). Confirm that upgrades to the site's communications systems have been completed.

3.2.4.6.A Confirm that the measures to provide main control room ventilation under high ambient temperatures during an ELAP event are sufficient to mitigate room heat-up and allow operators to perform their functions.

3.2.4.7.A Confirm the availability of secondary sources of water to provide makeup to the CSTs/RWTs during Phase 2 following a high wind missile event.

3.2.4.10.A The revised battery load shed strategy is to initially secure one battery, load shed and operate on the other battery, and return the secured battery to service before the first battery is depleted, thereby extending the available coping time. Confirm that this revised strategy is sufficient to power all critical loads during Phase 1, and can be implemented consistent with the assumed time constraints and SOE.

3.3.2.A Confirm that considerations 1 and 3 of Section 11.8 of NEI 12-06 will be addressed, so that: A) a historical record of previous mitigating strategies and the basis for changes will be maintained, and B) a mitigating strategies change process will be adopted which provides a documented engineering basis that ensures that any change in FLEX strategy continues to ensure the key safety functions are met; or provide an appropriate alternative.

Page 13 of 23

L-2014-063 Enclosure 7 Potential Draft Safety Evaluation Impacts Draft NRC Safety Evaluation has not been received.

8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.

1. FPL Letter L-2013-084 to NRC, 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) dated February 28, 2013

2. FPL Letter L-2013-192 to NRC, 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) dated June 18, 2013

3. 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

4. NEI 12-06 Rev 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (including supplemental guidance contained within posted Flex Guidance Inquiry Forms)

5. WCAP-17601-P Rev 1, Reactor Coolant System Response to Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs, January 2013

6. FPL Letter L-2013-254 to NRC, Florida Power & Light (FPL)/St. Lucie's First Overall Integrated Plan 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 28, 2013

7. NRC Endorsement of Reference 8, Agencywide Documents Access and Management Systems (ADAMS)

Accession No. ML13276A183, dated January 8, 2014

8. Westinghouse Position Paper entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG),"

ADAMS Accession No. ML13235A135, dated August 15, 2013

9. NEI Position Paper entitled "Shutdown / Refueling Modes," ADAMS Accession No. ML13273A514, dated September 18, 2013

10. NRC Endorsement of Reference 9, ADAMS Accession No. ML13267A382, dated September 30, 2013

11. Electric Power Research Institute (EPRI) Report 3002000623 entitled "Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment," ADAMS Accession No. ML13276A573, dated September 2013

12. NRC Endorsement of Reference 11, ADAMS Accession No. ML13276A224, dated October 7, 2013

13. Interim Staff Evaluation and Audit Report by the Office of Nuclear Reactor Regulation Related to Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Florida Power and Light Company, St. Lucie Plant, Units I and 2, Docket Nos. 50-335 and 50-389, dated February 6, 2014 Page 14 of 23

L-2014-063 Enclosure SIMPLIFIED ONE-LINE DIAGRAM OF UNIT 1 CLASS 1E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM 416 SWGR 1A2 4.16 SWGR 1B2 UNIT 1 EDO EDO FLEXB FLEX 45ONG EDO4160 DG SECONDARY STRATEGY PRIMARY STRATEGY 4.16 SWGR 1A3 RTR.ATEGY 4.1 fa SWGR lAB 4.16 SWGR 1B 1A CCW 1A LPSI 1ccc 1B CCW I B LPSI PUMP PUMP PUMP PUMP PUMP SBO ACOSSTIE TOUNIT2 1-B2SST CONNECTION CONNECTION PANEL LEX DG FLEX DG PANEL

-l--. SECONDARY PRIMARY C,"E-*

1480VAC SWGR1A2 STRATEGY STRATEGY I480VAC SWGR 1B2 MCCIA MCAQ1B SA rer480VAC SWGR lABt 1aA Battery Charger MCCJ1AB SOKVA lao10010 IA Battery (125) 15 15 CHARGING CHARGING CHARGING 1BB Battery PUMP 1A PUMPiC PUMP 1B Charger lAB Battery charger Figure 1 PSL FLEX Electrical Connections (Unit 1) (Rev OA)

Page 15 of 23

L-2014-063 Enclosure SIMPLIFIED ONE-LINE DIAGRAM OF UNIT 2 CLASS 1 E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM Figure 2 PSL FLEX Electrical Connections (Unit 2) (Rev OA)

Page 16 of 23

L-2014-063 Enclosure annji niniade cin bannetý-n abandoned check valve.

FLEX CST Pump DidiharTgi ind FLEX SG PuAmp Eurfino Portion of -Drawing 8770-g-OSO Sh. 4 iadarg an FEX S6 PMar Suction, REX~STi~unp Portion of Drawing 29.8-'G-Oa Sh_ 2B F.ig r ...... ...

Figure I I Connections for CST FLEX Pump Suction on CSTs (Rev OA)

Page 17 of 23

L-2014-063 Enclosure wtin cu.m3n an bnnnt

,ade aalandanndcheck v-* ei oSf

.FLEX EST. J'4-Fimp iharge a-nd FLEX.SG PumipSutwn, Portion of Drawing 8770-G-080Sh.: 4 B1ranch cann ecdiansfarFlEX connectiansLfor FLEX (CST Pimp Oiriieadd FLEX 56 PUurnpSiircan Portion.of Drawinq 2998:-O80 Sh. 2Bý.

Figure 12 Connections for CST/SG FLEX Pump Discharge for CST Fill (Rev OA)

Page 18 of 23

L-2014-063 Enclosure Install a 4" -isolation valve and hose connection to the AFW pump IC(2C) discharge piping-for Steam Generator Injection by using a FLEX pump.

(MMM 4O Portion of Drawing 8770MG-080 Sh. 4

,Portion of Drawing 2998-G-080 Sh. 2B Figure 13 Connections for SG FLEX Pump Discharge to AFW Pump Discharge Lines (Rev OA)

Page 19 of 23

L-2014-063 Enclosure Install a 3V -4" isolation valve and hose connection on the LPSI 1AlIB and LPSI 2A12B discharge piping. For RCS cold leg injection with FLEX pump drawing suction from the RW'T.

FLEX Cormections for Common Train Design Portion of Drawing 8T770G-078 Sh. 130B FLEX Connections for Split Train Design Portion of Drawing 2998-G-078 Sh. 130B Figure 14 Connections for SG FLEX Pump Discharge to LPSI Pump Discharge Lines (Rev OA)

Page 20 of 23

L-2014-063 Enclosure INTAK(ESTRUIJ FLE T~TO ConIoWAERPUP fRC INTAKECOOLING WATER PUMP 1i INTAKE CANAL Figure 17 Connections for RRC LUHS Pumping System (Unit 1) (Rev OA)

Page 21 of 23

L-2014-063 Enclosure WAIM Figure 18 Connections for RRC LUHS Pumping System (Unit 2) (Rev OA)

Page 22 of 23

L-2014-063 Enclosure DV Figure 21 Connections for CST/SG FLEX Pump Suction From PWSTs (Unit 2, Unit I Similar) (Rev OA)

Page 23 of 23