L-2014-274, Third 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 EA-12-049)

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Third 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 EA-12-049)
ML14253A184
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 08/27/2014
From: Jensen J
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2014-274
Download: ML14253A184 (32)


Text

0 August 27, 2014 FPL. L-2014-274 10 CFR 2.202 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Florida Power & Light (FPL)/St. Lucie's Third 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:

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. 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 for Mitigation 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.

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

L-2014-274 Page 2

8. FPL Letter L-2014-063 dated February 26, 2014, 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), Accession No. ML14064A192.

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 pooi cooling capabilities in the event of a 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 1. 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. References 7 and 8 provided the FPL/St. Lucie first and second six-month Overall Integrated Plan status report.

The purpose of this letter is to provide the third 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 P!an 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.

L-2014-274 Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 2.'7 ,2014.

Respectfully submitted, J~oseph Jensen Site Vice President St. Lucie Plant JJ/KWF cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2

Enclosure:

Third 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-2014-274 Enclosure Page 1 of 29 Third 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 third six-month update has been formatted as a revision to the second six-month update (Reference 14), thus keeping all updates in one document; changes since the second 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 1). Milestone accomplishments are current as of August 11, 2014.

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

" Submittal of Second 6-Month Status Report, February 2014 (Reference 14)

  • Submittal of Third 6-Month Status Report, August 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 Complete Update 4 Feb 2015 Not Started

L-2014-274 Enclosure Page 2 of 29 Target Revised Target Milestone Completion Date Activity Status Completion Date Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Feb 2014 Started February 2015 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 September 2014 Create New/Revisions to OPS Procedures Mar 2014 Started October 2014 Create Maintenance Procedures Mar 2014 Started October 2014 Training:

Develop Training Plan June 2014 Complete 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.

L-2014-274 Enclosure Page 3 of 29 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 indicated in Reference 1. This action is compliant with WCAP-17601-P and eliminates the deviation previously indicated within Reference 1 Attachment 1B, 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 11, 12 and 14 for the latest changes.

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.

Question 25 of audit document Order EA-12-049 Mitigation Strategies, Overall Integrated Plan Regulatory Audit Questions, St. Lucie 1 & 2, Rev. 1, Dated October 30, 2013, questioned the St. Lucie FLEX strategy for isolation of Class 1E Electrical equipment from portable/FLEX equipment. The FPL response was to provide a double isolation scheme with appropriate coordinated current interrupting devices. In lieu of the double isolation concept, FPL has decided that during normal operation, these new breakers will be racked out and locked open with springs discharged. Under this arrangement, isolation between the Class IE Electrical equipment and portable/FLEX equipment is maintained.

In the same question regarding prevention of multiple sources powering the electrical buses, the strategy provided was that for Phase 3, the scheme would rely on electrically interlocked breakers of the incoming feeder breakers with the FLEX circuit breaker such that both breakers must be OPENED before the FLEX circuit breaker can be closed. The present strategy has evolved to having all the connections for FLEX power connection and breaker positioning be procedurally controlled. This strategy has evolved due to the less restricting time frame for Phase 3 coping.

L-2014-274 Enclosure Page 4 of 29 4.5 Boration Requirements for Shutdown Margin The Reference 1 FLEX response (page 37 of 102) discussed boration requirements for shutdown margin.

FPL has adopted 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. FLEX guidelines will address sub-criticality for Phase 1/2 (3007F) and Phase 3 (507F) including sources and timing for adding borated water.

Guidelines will include monitoring of Thot and Tcold to ensure single phase Natural Circulation AT conditions exist prior to adding boron and the I hour mixing delay is included prior to entering conditions requiring additional boration 4.6 RRC LUHS Pump The Reference I 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 I (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 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 I 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 I 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

L-2014-274 Enclosure Page 5 of 29 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. Rather than missile protecting the single existing source from tornado, a second source will be installed and separated by greater than diameter of typical tornado path (1200 ft) with that path oriented from the west to southwest.

See new Figure 23.

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.

4.9 DC and Extended DC Load Shedding The St. Lucie DC coping strategy has evolved from that indicated in the Reference 1 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 gpm/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 1 and Unit 2 RWTs are now considered available to cope with an event during Mode 5 & 6.

L-2014-274 Enclosure Page 6 of 29 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 now be stored elsewhere on site, resulting in a smaller FESB footprint (150' x 60'). 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 I 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 has been evaluated and a 1000 gallon trailer mounted tank is being procured. Gravity fill of this tank has been revised to use V17202 or one of two new redundant valves to be installed on the fill line. See new Figure 24.

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. A new action in the Modes 1-5, SGs Available timeline for RCP Control Bleed Off isolation is added at 10 minutes to limit RCP leakage. This addresses Confirmatory Item 3.2.1.1 .A. 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.

4.15 Instrumentation Credited for Coping Evaluations The Reference 1 FLEX response included lists of instrumentation credited for coping evaluations supporting FLEX Strategies that Maintain Core Cooling & Heat Removal, Maintain RCS Inventory Control and Maintain Containment. Several of the instrument tags listed have been revised to provide improved sensing range and to be aligned with the power supplies that will be available under the DC Loading Shedding strategy (described in 4.9 of this attachment). Note that the parameters listed under these FLEX Strategies in the Reference 1 FLEX response are not revised.

4.16 FLEX SFP Pump Discharge The Reference 1 FLEX response described the hardened makeup flowpath to Maintain Spent Fuel Pool Cooling as via the 21/2" ICW lines on the exterior east wall of each Fuel Handling Building (FHB). In lieu of providing missile protection for these lines, an alternate missile protected flow path will be provided. The alternate path is via a new FLEX connection on the suction of one of Spent Fuel Pool Pumps on each unit. These lines and their flow paths to the Spent Fuel Pools are within the missile protected interior of the FHB's. The 21/2" ICW lines remain the preferred hardpipe flowpath should they remain intact following the BDBEE. See new Figure 22.

L-2014-274 Enclosure Page 7 of 29 4.17 FLEX Strategy Internal Flooding Question 2 of audit document Order EA-12-049 Mitigation Strategies, Overall Integrated Plan Regulatory Audit Questions, St. Lucie 1 & 2, Rev. 1, Dated October 30, 2013, questioned the St. Lucie FLEX strategies address considerations for seismic hazards associated with large internal flooding sources that are not seismically robust. The FPL response was that internal flooding was a concern for access to the ECCS Pump rooms and that no AC power was required to access those rooms. In addition, internal flooding has been considered for FLEX Equipment deployment. The FLEX Strategy for RCS Makeup requires hose deployment to connections on the LPSI pump piping that is located behind the watertight doors to the ECCS Pump rooms.

Access into the watertight doors is via the -0.5 ft hallways whose design bases internal flood level (from non-seismic Unit 2 Holdup Tank ruptures) is above the watertight door thresholds. To facilitate hose deployment, a modification to the watertight doorways is to be implemented to allow insertion of a flood barrier. This limits the volume of water entering the LPSI pump rooms to that between the barriers and the doors.

4.18 FLEX Equipment +1 Spares PSL does not intent to have a complete set of spare hoses and cables but will accomplish +1 by having the greater of (1) 10% of the "N" required spares or (2) those sections of hose and cables required to replace the longest run of each hose or cable type and size needed for 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 1 Seismic re-evaluation of site and submit to NRC. Include Complete. PSL has screened out. FPL insights in development of the FLEX integrated plan Letter L-2014-215 (Ref. 15) 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 Complete. Staging areas have been radius) established with SAFER review.

4 Review FESB deployment routes for liquefaction Started 5 Determine RRC staging area location and develop Complete. Staging areas have been deployment routes to site established with SAFER review.

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

L-2014-274 Enclosure Page 8 of 29 Overall Integrated Plan Pending Actions Status 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 Started ELAP, identify additional required strategies/ modifications 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 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 l&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 UI 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:

within specified time period - 30 minutes (inverters)/one hour (balance); to be re-evaluated (see

L-2014-274 Enclosure Page 9 of 29 Overall Integrated Plan Pending Actions Status Action 26A below) 26A Time validation study for completing revised DC load shedding discussed in Section 4.9 within specified time Started period, to include any impact to required instrumentation and Control Room heat up 27 Time validation study for Control Room ventilation Complete 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 (M1-4 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

L-2014-274 Enclosure Page 10 of 29 Overall Integrated Plan Pending Actions Status Phase I 46 Time validation study for FLEX SFP pump Complete 47 Time validation study for refueling FLEX equipment Started 48 U1 & U2 Construct FLEX Equipment Storage Building Started Storage Building 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 1E 480 VAC Switchgear A&B for primary and alternate connection of 480 VAC Started FLEX DG 53 Ul & U2 Install transfer switches on load side charging Closed- Not Applicable. See Section 4.4 pumps and Class 1E battery chargers. Alternate connection.

54 U I & U2 Design cabling/disconnects for Class IE 4.16 Started (Installation would be performed KVAC busses A&B for Phase 3) 55 U I & U2 Install RCP low leakage seals Closed - Not Applicable. See Section 4.1 56 UI Install ADV seismic pneumatic backup and air pressure regulator, provide quick connects Started (Design Issued; EC 279190)

I Complete and acceptable; Operator actions 56A U I Time validation study for ADV Operator actions can be completed within 90 minutes post event 57 U 1 Install modifications for CST as required by tornado Not Started wind hazard analysis 58 U I & 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 I & U2 Qualify non-seismic CST cross-connect Complete 60 UI & U2 Install 2 connections per CST for refilling the Started (Design Issued; EC 279190 - Unit CSTs via FLEX CST pump 1; EC 279191 Unit 2) 61 U I & U2 Install 2 connections per CST for suction point for Started (Design Issued; EC 279190 - Unit FLEX SG pump 1; EC.279191 Unit 2) 62 U1 & 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 1 & U2 Install modifications for RWT as required by Closed - Not Required. See Section 4.7 tornado wind hazard analyses and 4.11

L-2014-274 Enclosure Page 11 of 29 Overall Integrated Plan Pending Actions Status 65 UI & 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 (Design Issued; EC 279190 - Unit for FLEX SG pump/FLEX CST Pump 1; EC 279191 Unit 2) 67 U 1 & U2 Install 2 connections per RWT for CST FLEX Started (Design Issued; EC 279190 - Unit pump discharge 1; EC 279191 Unit 2) 68 U l & U2 Install 2 connections on LPSI pump discharge Started (Design Issued; EC 279190 - Unit piping for RCS cold leg injection via FLEX pump 1; EC 279191 Unit 2) 69 UI & U2 Install 2 connections on LPSI pump suction piping Started (Design Issued; EC 279190 - Unit (Mode 6 with Rx head off/SG primary manways off) 1; EC 279191 Unit 2)

Closed - Not Required. See Section 4.11 70 U1Provide containment vent path to ensure sufficient RWT ( Review ed; Not wil Sec30"nEscap fow or RS maeup(Note:

gravty Reviewed; will now use 30" Escape gravity flow for RCS makeup Hatch) 71 Ul & U2 Missile protect ICW line I-2 '/1/2-CW-178 located Closed - Not Required. See Section 4.16 on the exterior of U1 & U2 FHBs 72 U1 & U2 Install ICW manifolds with hose connections and Started (Design Issued; EC 279190 - Unit isolation valves for LUHS 1; EC 279191 Unit 2) 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 comnmunications necessary for ingress and egress to plant areas for deployment of FLEX strategies Started 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

L-2014-274 Enclosure Page 12 of 29 Overall Integrated Plan Pending Actions Status 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 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 IB) 91 FSG: Guidance for SIT injection and isolation Started 92 FSG: Establish RWT gravity flow to RCS and criteria for Staed 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 Started generator 98 FSG: Deployment and operation of RRC pumping system 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 Closed_-_NtApplicale._SeeSction_4.1 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 4.9 104 Ul & U2 Install 1 connection on one SFP Pump suction line Started. See Section 4.16 for SFP FLEX pump discharge 105 Install two sets of secondary water supply connections from underground water main (Ft. Pierce Utilities) at north and Started. See Section 4.7 new south metering stations

L-2014-274 Enclosure Page 13 of 29 Overall Integrated Plan Pending Actions Status 106 Install removable flood barriers at watertight doors to ECCS Started. See Section 4.17 Pump Rooms.

Alpha suffixes and numbers above 100 indicate additional items beyond those identified in Reference 1 Draft Safety Evaluation Pending Items Status Draft NRC Safety Evaluation has not been received.j 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 have been received via Reference 13. Responses to the following two Open Items and 15 Confirmatory Items are in the process of being developed. Where responses have been developed though not completed or reviewed by the NRC, brief summary remarks are added to the Notes section with St. Lucie response white paper tracking number:

Open Items Item Number Description Notes 3.2.1.8.A Core Sub-Criticality - Confirm that St. Lucie will apply St. Lucie will apply the generic the generic resolution for boron mixing under natural requirement per Reference 16 circulation conditions potentially involving two-phase regarding conditions and timing flow, in accordance with the conditions provided in the for boron mixing. Response to be NRC's endorsement letter dated January 8, 2014, or included with Program alternately, justify the boric acid mixing assumptions that Document.

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 St. Lucie repowering and use of alternate approach relying on repowering one of three an installed charging pump as an installed charging pumps in each unit using a portable alternate coping strategy is 480 VAC FLEX generator. Justify how these installed currently being evaluated.

pumps will be capable of performing their mitigating Response to be included with strategies function following an undefined ELAP event, Program Document.

in contrast with using a portable FLEX pump.

L-2014-274 Enclosure Page 14 of 29 Confirmatory Items Item Number Description Notes 3.1.1.2.A Confirm that the routes for deployment of FLEX St. Lucie has ensured that the equipment provide for at least one connection point for FLEX equipment staged locations the FLEX equipment that will only require access and cable/hose routes are through seismically robust structures, consistent with protected from seismic events or consideration 2 of NEI 12-06, Section 5.3.2. allow for multiple placement locations/routes. Response to be included with Program Document.

3.1.1.4.A Confirm that the deployment routes and methods to be St. Lucie deployment routes and used will enable delivery of resources from the RRC methods have been reviewed by staging area to the site following a BDBEE. SAFER and enable delivery of off-site resources. Response to be included with Program Document.

3.2.1.A The NRC staff endorsed the PWROG position paper on St. Lucie ELAP analysis CENTS the use of the Combustion Engineering Nuclear Transient code results are used for non-(CENTS) code in the ELAP analysis for Combustion reflux boiling conditions.

Engineering plants, with the limitation that it can only be Response to be included with applied to the flow conditions prior to reflux boiling Program Document.

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 St. Lucie RCP seal leakage rates assumed for St. Lucie from time zero to the time when remain at 1 gprn/seal with early subcooling in the RCS cold-legs decreases to 50 CBO isolation included in SOE.

degrees F' and confirm the impact of these leakage Response to be included with rates on the plant-specific time constraints and Program Document.

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 St. Lucie RCP Seal leakage is <1 is less than 1 gpm per RCP during an ELAP before the gpm per seal up to CBO isolation.

controlled bleed off is isolated. Response to be included with Program Document.

L-2014-274 Enclosure Page 15 of 29 Item Number Description Notes 3.2.1.5.A Confirm that the Rosemount pressure transmitters Rosemount transmitters are credited in an ELAP event will continue to function in confirmed to be adequate for the anticipated environmental conditions. ELAP conditions. The FPL EQ Program shows that the environmental conditions that would exist during an ELAP event are enveloped by the type testing done under the program.

Other essential instruments, not located in a harsh environment are found acceptable based on vendor specification sheets.

Response to be included with Program Document.

3.2.1.9.A Justify the use of the NOTRUMP computer code to AFW integrated flow rate determine the integrated flow rate required to remove requirement revised to compare to decay heat and sensible heat. CENTS code output. Response to be included with Program Document.

3.2.1.9.B Confirm that the revised calculation for RCS makeup Flow supplied by AFW and SG flow demonstrates that the FLEX strategies and FLEX pumps confirmed to supply equipment can provide sufficient flow to accommodate adequate cooldown flow.

the sensible heat resulting from cooldown in the 2-6 Response to be included with hour time frame. Program Document.

3.2.1.9.C Confirm that the pump criteria and the associated Reduced flow provided by RRC analysis support the adequacy of the RRC-supplied supplied pump is confirmed to be pumps to re-establish Shutdown Cooling for Phase 3. adequate for reestablishing Shutdown Cooling. Response to be included with Program Document.

3.2.4.2.A Confirm that the electrical equipment room equipment Shed heat loads are being is analyzed for operation up to a temperature of 129 recalculated to lower temperature 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 profile and required equipment used to provide adequate room ventilation, confirmed to function for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Response to be included with Program Document.

3.2.4.4.A The NRC staff has reviewed the licensee Upgrades to the communications communications assessment (ADAMS Accession Nos. systems are currently being ML12307A116 and ML13057A033) and has implemented and are tracked determined that the assessment for communications is under their Engineering Change reasonable (ADAMS Accession No. ML13134A050). Packages with planned Confirm that upgrades to the site's communications completion in April 2015.

systems have been completed.

L-2014-274 Enclosure Page 16 of 29 Item Number Description Notes 3.2.4.6.A Confirm that the-measures to provide main control Shed heat loads are being room ventilation under high ambient temperatures recalculated to lower temperature during an ELAP event are sufficient to mitigate room profile and confirm measures are heat-up and allow operators to perform their functions. sufficient for habitability.

Response to be included with Program Document.

3.2.4.7.A Confirm the availability of secondary sources of water New high wind missile separated to provide makeup to the CSTs/RWTs during Phase 2 2 nd potable water supply following a high wind missile event, connection ensure secondary source maintained for Phase 2.

Response to be included with Program Document.

3.2.4.10.A The revised battery load shed strategy is to initially Loads are being calculated to secure one battery, load shed and operate on the other confirm there is sufficient power battery, and return the secured battery to service before available. Response to be the first battery is depleted, thereby extending the included with Program available coping time. Confirm that this revised strategy Document.

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 considerations will be NEI 12-06 will be addressed, so that: A) a historical addressed in Program Document record of previous mitigating strategies and the basis for controlled under Appendix B QA changes will be maintained, and B) a mitigating program maintains FLEX strategies change process will be adopted which provides strategies current and future a documented engineering basis that ensures that any configuration. Response to be change in FLEX strategy continues to ensure the key included with Program safety functions are met; or provide an appropriate Document.

alternative.

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

L-2014-274 Enclosure Page 17 of 29 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. MLI3267A382, 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
14. FPL Letter L-2014-063 to NRC, 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 049), dated February 26, 2014
15. FPL Letter L-2014-215 to NRC, Florida Power & Light (FPL) Response to NRC 10 CFR 50.54(f) Request for Information Update Regarding Near-Term Task Force Recommendation 2.3, Seismic, dated June 30, 2014
16. Westinghouse Letter LTR-FSE-13-46, Rev. 0-A (DRAFT), Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owner's Group, June 11,2013

L-2014-274 Enclosure Page 18 of 29 SIMPLIFIED ONE-LINE DIAGRAM OF UNIT 1 CLASS 1E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM 4.16 SWGR 1A2 4.16 SWGR 1B2 UNIT 1 EDG EDG FLEX 1A 1B FLEX 41601DG 4160 DG SECONDARY PRIMARY STRATEGY STRATEGY 4.16 SWGR 1A3 U 4.16 SWGR lAB 416 SWGR 1 1A CCW IA LPSI 1c 1cIB cCCw 1B LPSI PUMP PUMP PUMP PUMP PUMP SBO COSSTIE TO UNIT 2 1 B2 SST CONNECTION CONNECTION PANEL FLEX DG FLEX DG PANE 1-I - .SECONDARY PRIMARY I480VACSWGR1A2 [S; STRATEGY STRATEGY 480VACSWGR1B2 1AA Battery charger L.1 400VAC SWGR IAB 1B Battery Charger MCC lAB 0 C100 11S A(atey25)6 CagrCHARGING CHARGING CHRGNG1BpBattery Figure 1 PSL FLEX Electrical Connections (Unit 1) (Rev OA)

L-2014-274 Enclosure Page 19 of 29 SIMPLIFIED ONE-LINE DIAGRAM OF UNIT 2 CLASS 1E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM Figure 2 PSL FLEX Electrical Connections (Unit 2) (Rev OA)

L-2014-274 Enclosure Page 20 of 29 Connection made on bonnets of abandoned check valves for FLEX CST Pump Discharge and FLEX SG Pump Suction via Temporary Wye Fitting Portion of Drawing 8770-G-080 Sh. 4 V09104 Branch connections for FLEX connections for FLEX CST Pump Discharge and FLEX SG Pump Suction via Temporary Wye Fitting Portion of Drawin2 2998-G-080 Sh. 2B Figure 1 Connections for CST FLEX Pump Suction on CSTs (Rev 1)

L-2014-274 Enclosure Page 21 of 29 Connection made on bonnets of abandoned check valves for FLEX CST Pump Discharge and FLEX SG Pump Discharge via Temporary Wye Fitting Portion of Drawing 8770-G-080 Sh. 4 V09 104 Branch connections for FLEX connections for FLEX CST Pump Discharge and FLEX SG Pump Discharge via Temporary Wye Fitting Portion of Drawing 2998-G-080 Sh. 2B Figure 12 Connections for CST/SG FLEX Pump Discharge for CST Fill (Rev 1)

L-2014-274 Enclosure Page 22 of 29 Install a 4" isolation valve and hose connection to the AFW pumplC(2C) discharge piping for Steam Generator Injection by using a FLEX pump.

-' * " 't9 " M!

'-r" LV*

T ~ '0=S Portion of Drawing 8770-G-:08 Sh. 4 Portion of Drawinq 2998-G-080 Sh. 2B Figure 13 Connections for SG FLEX Pump Discharge to AFW Pump Discharge Lines (Rev OA)

L-2014-274 Enclosure Page 23 of 29 Install primary and secondary 3" isolation valves & hose connections on the LPSI 1A/1B Pumps common discharge piping. For RCS cold leg injection with FLEX SG Pump drawing suction from the RWT.

LOWPBLSMRE SM" R4JCMf PUMtA F-S1 SW-LM qnLi LOWPWOURE SUM INJECTDNFM 18 Portion of Drawing 8770-G-078 Sh. 130B Install 3" isolation valves and hose connections on each of the LPSI 2A & 2B Pumps discharge piping.

For RCS cold leg injection with FLEX SG Pump drawing suction from the RWT.

Sw-I Portion of Drawing 2998-G-078 Sh. 130B Figure 14 Connections for SG FLEX Pump Discharge to LPSJ Pump Discharge Lines (Rev 1)

L-2014-274 Enclosure Page 24 of 29 WATER INTAKECANAL Figure 17 Connections for RRC LUHS Pumping System (Unit 1) (Rev OA)

L-2014-274 Enclosure Page 25 of 29 INTAKE SRITUC11.E st42ed 24" FMane with onnectons fn HRCP=VSP MR21165 DR21211 2 1/7- DR DR N

INTAKE COOUNG WATER INTAKE CMIXIGWATER PUMP 2A PUMP 2C Figure 18 Connections for RRC LUHS Pumping System (Unit 2) (Rev OA)

L-2014-274 Enclosure Page 26 of 29 PRIMARYWATER STORAGE TANKI 150.000 GALCAPACIYY 4 4 8 PRIMARY WATER PUMP2 Figure 21 Connections for CST/SG FLEX Pump Suction From PWSTs (Unit 2, Unit I Similar) (Rev OA)

L-2014-274 Enclosure Page 27 of 29 Install a 3" isolation valve and hose connection on SFP Pumps 1A & 2A Suction piping. For SFP Hardened Makeup from FLEX SFP Pump FLEX (A)

TI FUELP0 Portion of Drawing 8770-G-078 Sh. 140 Figure 22 Connection for SFP FLEX Pump Discharge to Fuel Pool Pump (Unit 1, Unit 2 Similar) (Rev 0)

L-2014-274 Enclosure' Page 28 of 29 COWOt FOR PORTA8LE FLEX PUUP, FLEX PLUP.

FLEX Connections for FLEX SFP Pump Suction and FLEX CST Pump Suctions I-iO In COMNFOR?

  • f~-PORTABLE FLEX PUiIP.

- -- EX" F C e no I'-' --3PORTAB,.E CONN FOR

" * *"" "* FLEX PUMP.

  • VI5???

r -- ----,LXone t onorF E 6"X5" CONN FOR fo FLE FLEXConnctios *_

I CST Pump Suctions V15???

I I

  • I6*X5 CONN FOR PUMP.

ji '* "* -FLEX PORT.ABLE L[ý..

FT. PIERCE WTR. SUPPTy I V15???

LSTORAGE EQUIPMENT BUILDINGJ Portions of Drawing 8770-G-084 Sh 1A Figure 23 Connections for Secondary Water Sources (Ft. Pierce Utilities) for SFP FLEX Pump Suction and FLEX CST Pump Suctions (Rev. 0)

L-2014-274 Enclosure Page 29 of 29 1126I I U U

LO Lo V17206 DIESEL OIL '

'ANSFER PUMP 2A 6I I-

.1 Vi 7215 V17216 DIESEL OIL ANSFER PUMP 28 i

Portion of 2998-G-086 Sh. 1 Figure 24 Connections for Diesel Oil Gravity Drain Connections from Unit 2 Diesel Oil Storage Tanks (Rev 0)