L-2015-143, Status of Required Actions for EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Status of Required Actions for EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML15140A080
Person / Time
Site:	Saint Lucie
Issue date:	05/14/2015
From:	Costanzo C Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2015-143
Download: ML15140A080 (10)

Text

May 14, 2015 L-2015-143 10 CFR 2.202 FIPL.

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 St. Lucie Unit 1 Docket Nos. 50-335 Florida Power & Light/St. Lucie Unit 1 Status of Required Actions for EA- 12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

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. ML I 3242A274.

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

L-2015-143 Page 2 Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),

Accession No. ML14064A192.

9. FPL Letter L-2014-274 dated August 27, 2014, 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), Accession No. ML14253A184.

10. FPL Letter L-2015-049 dated February 23, 2015, Florida Power & Light (FPL)/St.

Lucie's Fourth 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. ML15071A265.

11. NRC Letter dated February 27, 2015, St. Lucie Plant, Units 1 and 2, Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0984, MF0985, MF0990, and MF0991), Accession No. ML15035A670.

12. NRC Letter dated March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, Accession No. ML12053A340.

13. FPL letter L-2014-345 dated November 20, 2014, FPL/St. Lucie Plant Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, Emergency Preparedness - Phase 2 Staffing Assessment.

14. NRC Letter to Nuclear Energy Institute dated September 26, 2014, Staff Assessment of National SAFER Response Centers Established in Response to Order EA- 12-049, Accession No. ML14265A107.

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 beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 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, 8, 9 and 10 provided the FPL/St. Lucie first, second, third and fourth six-month Overall Integrated Plan status report. Condition C.3 of the Order required all

L-2015-143 Page 3 Licensees to report to the Commission when full compliance with the requirements of the order is achieved.

This letter provides notification that FPL has completed the requirements of EA- 12-049 and is in full compliance with the Order for St. Lucie Unit 1. The attachments to this letter provide: 1) a summary of how the compliance requirements were met and 2) the completion status for all the FLEX Open Audit items in Reference 11.

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 V o-0,-- ,2015.

Respectfully submitted, Christopher R. Costanzo Site Vice President St. Lucie Plant CRC/KWF cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units I and 2 Attachments I. St. Lucie Plant, Unit 1 Order EA-12-049 Compliance Requirements Summary

2. St. Lucie Unit 1 FLEX Audit Open Item Closure Summary

L-2015-143 Attachment I Page 1 of 2 Attachment I St. Lucie Plant, Unit 1 Order EA-12-049 Compliance Requirements Summary STRATEGIES - COMPLETE St. Lucie Unit 1 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items requiring action by FPL. Attachment 2 of this correspondence provides the closure methods for all of the St. Lucie Unit 1 Audit open items discussed in the NRC Letter dated February 27, 2015, St.

Lucie Plant, Units I and 2, Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0984, MF0985, MF0990, and MF0991), Accession No. MLI5035A670.

MODIFICATIONS - COMPLETE The modifications required to support the FLEX strategies for St. Lucie Unit I have been fully implemented in accordance with the station design control process.

EQUIPMENT- PROCURED AND MAINTENANCE & TESTING - COMPLETE The equipment required to implement the FLEX strategies for St. Lucie Unit I has been procured and designed in accordance with NEI 12-06, Section 11.1 and 11.2, received at St. Lucie, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Subsequent maintenance and surveillance testing will be conducted through the use of the St.

Lucie Preventative Maintenance program such that equipment reliability is maintained.

PROTECTED STORAGE - COMPLETE The storage facility required to implement the FLEX strategies for St. Lucie Unit I has been completed and provides protection from the applicable site hazards. All the N and N+I equipment required to implement the FLEX strategies for St. Lucie Unit I are stored in this building.

PROCEDURES - COMPLETE FLEX Support Guidelines (FSGs), for St. Lucie Unit 1 have been developed, and integrated with existing procedures. The FSGs and affected existing procedures have been implemented in accordance with the site procedure control program.

L-2015-143 Attachment I Page 2 of 2 TRAINING - COMPLETE Training for St. Lucie Unit I has been completed. Training was developed and implemented in accordance with the systematic approach to training as recommended in NEI 12-06, Section 11.6.

STAFFING - COMPLETE The staffing study for St. Lucie has been completed in accordance with 10 CFR5 0.54(f),

"Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012, as documented in FPL letter L-2014-345 dated November 20, 2014, "FPL/St. Lucie Plant Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, Emergency Preparedness - Phase 2 Staffing Assessment." As stated below, the staffing study was validated and no changes to the submitted study are necessary.

NATIONAL SAFER RESPONSE CENTERS - COMPLETE St. Lucie has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support St. Lucie with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

VALIDATION - COMPLETE St. Lucie has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions, and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) / Final Integrated Plan (FIP) for Order EA-12-049.

FLEX PROGRAM DOCUMENT - ESTABLISHED The NextEra Fleet and St. Lucie Unit I FLEX Program Documents have been developed in accordance with the requirements of NEI 12-06.

L-2015-143 Attachment 2 Page 1 of 5 Attachment 2 St. Lucie Unit 1 FLEX Audit Open Item Closure Summary Audit Item Subject NRC Request Required Action FPL Response Reference ISE Cl 3.2.4.2.A Electrical Equipment The licensee indicated that the Complete FPL064-CALC-007, Rev Calculation FPL064-CALC-007, Revision 2, Room Heat-up Analyses electrical equipment room and control 2, Electrical Equipment Room uploaded to ePortal for NRC review.

room heat-up analyses are being Heatup and upload to NRC ePortal. Revision 2 incorporates the new FLEX revised. The staff requests that the strategy to start existing electrical licensee provide the revised analyses equipment room (EER) fans at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> on the ePortal for review. following the Extended Loss of AC Power (ELAP). The calculation concludes all EER temperatures remain below 120°F for the duration of the ELAP event.

ISE Cl 3.2.4.6.A Control Room Heat-up The licensee indicated that the Upload FPL064-CALC-008, Rev 2, Calculation FPL064-CALC-008, Revision 2, Analyses electrical equipment room and control Control Room Heatup During Station uploaded to ePortal for NRC review. Case 2 room heat-up analyses are being Blackout, to NRC ePortal. requires 13,500 cfm of portable ventilation revised. The staff requests that the to be provided at 90 minutes following the licensee provide the revised analyses Extended Loss of AC Power (ELAP). The on the ePortal for review. main control room temperature decreases, resulting in a peak temperature of 110.9°F.

ISE Cl 3.2.4.10.A Battery Load Shed The revised battery load shed strategy Upload 1-FSG Appendix B, Procedure 1-FSG Appendix B, ELAP is to initially secure one battery, load ELAP Extended Load Shedding, R 0 Extended Load Shedding, uploaded to shed and operate on the other battery, to NRC ePortal ePortal for NRC review and return the secured battery to service before the first battery is depleted, thereby extending the available coping time. The staff requests that the licensee provide a revised procedure that shows when they plan to swap batteries and/or how they will determine when to swap batteries (i.e., periodically monitor voltage).

L-2015-143 Attachment 2 Page 2 of 5 Audit Item Subject NRC Request Required Action FPL Response Reference AQ 14 SFP Ventilation The staff requests that the license Provide response. The FLEX Strategies for St. Lucie Unit 1 provide an evaluation justifying the Spent Fuel Pool (SFP) cooling include required time frame to vent steam and opening doors and deploying hoses in condensate coming off the SFP or Phase 1 prior to habitability in the Fuel identify an alternate venting approach. Handling Building (FHB) being degraded.

The L-Shaped door opening time without power was estimated to be excessive compared to the available time, so the opening of the personnel doors at the operating (62 ft.) and ground (19.5 ft.)

elevations was selected to allow for air flow and steam venting. The two doors at the 62 ft. elevation have 3 ft. x 7 ft. openings. One is northwest of the SFP surface elevation that is also 62 ft. The other door is south of the SFP on the new fuel storage area south wall that is open to the SFP via a normally open sliding doorway that has a 5.3 ft. x 30 ft. opening. The double door at the 19.5 ft.

elevation has an 18 ft. x 15 ft. opening.

Steam will be vented out of the FHB via these openings if boiling occurs in the Spent Fuel Pool. The timing for the opening of the three personnel doors is provided in the timeline as occurring between 1 and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following an ELAP.

The increase in Spent Fuel Pool temperature is less than 8°F during this time frame (>30 days after shutdown).

L-2015-143 Attachment 2 Page 3 of 5 Audit Item Subject NRC Request Required Action FPL Response Reference AQ 42 SG FLEX Pump Time The licensee described the portable Upload V&V of SG FLEX Pump to SG FLEX Pump Verification and Validation Validation diesel driven pump (SG FLEX pump) ePortal. report uploaded to ePortal for NRC review being deployed for injection into the which provides the time and resource SGs in the event that the TDAFW validation.

pump fails. The licensee indicted that the time and resources to make connections of the SG FLEX pump will be validated. The staff requests that the licensee provide the time and resource validation on the ePortal once it's completed.

Licensee Identified WCAP-17601-P The licensee identified an action to Confirm adherence without gaps. Attachment 11B in the first St. Lucie Unit 1 Open Item 25 Deviations include in its six-month updates the FLEX six month update along with the 3 technical basis for any WCAP-1 7601-P subsequent updates, confirm there were no deviations. The staff indicated that this gaps between the St. Lucie Unit 1 FLEX item is being left as an open item, strategy and WCAP-17601-P. Based on since the staffs review is ongoing and current evaluations and analyses, it is the licensee's strategy may change. confirmed there are no gaps between the St. Lucie Unit 1 FLEX strategy and WCAP-17601-P.

L-2015-143 Attachment 2 Page 4 of 5 Audit Item Subject NRC Request Required Action FPL Response Reference SE Review Item 1 RCS Venting The NRC staff requests that the Upload FPL064-CALC-009, Rev. 2, Uploaded Calculation FPL064-CALC-009, licensee provide updated cooldown St. Lucie Unit 1 Reactivity Rev. 2, St. Lucie Unit 1 Reactivity which procedures to (a) avoid injection of determines the RCS pressure that prevents nitrogen into the RCS and (b) avoid Upload 1-FSG-01, Long Term nitrogen injection into the RCS and also repressurization of the RCS through Inventory Control calculates SDM boration requirements.

the use of charging pumps. The NRC Upload 1-FSG-05, FLEX Also uploaded applicable sections of FLEX staff also requests that the licensee Implementation implementing guidelines 1-FSG-01, 1-FSG-provide updated SDM calculations that Upload 1-FSG-08, Alternate RCS 05, 1-FSG-08 and 1-FSG-99, Appendix X align with the updated operating to ePortal for NRC review. These FLEX procedures, to provide assurance that guidelines include the RCS pressure limits sufficient SDM will remain available in Upload 1-FSG-99, Appendix X, to observe during cooldown to prevent the cooldown to Mode 5. Initial ELAP RCS Cooldown nitrogen injection into the RCS, steps to avoid RCS repressurization during the use of a charging pump, and provide minimum boration requirements needed to maintain a 1% SDM.

SE Review Item 8 FLEX Equipment The NRC staff considers the St. Lucie Store all N and N+1 FLEX Prior to entry into Mode 2, FPL confirms Storage Buildings FLEX storage configuration not being equipment in the FLEX Equipment that all N and N+1 equipment for St. Lucie consistent with guidance contained in Storage Building. Unit 1 is located in a hardened structure per NEI 12-06. The staff requests that the requirements of NEI-12-06, Rev. 0.

licensee propose the configuration as an alternative to the guidance of NEI 12-06, accompanied with appropriate justification.

L-2015-143 Attachment 2 Page 5 of 5 Audit Item Subject NRC Request Required Action FPL Response Reference' ISE CI 3.2.1.8.8 RCS Inventory The licensee indicated that makeup None Required N/A needed for boration prior to Mode 5 cooldown and depressurization will be provided by repowering one of two positive displacement charging pumps, which can draw from either the boric acid makeup tank or the RWT, and can inject into either the normal charging path or the high pressure safety injection (HPSI) header. The discharge header of the HPSI pumps serves as a common point in these flow paths, though one side can be isolated from the other. At this time, the staff has no additional questions and is currently reviewing the information provided.

AQ 43 Containment Analysis The staff is currently reviewing the None Required N/A licensee's containment analysis FPL-CALC-003,"MAAP Containment Analysis."