ML12107A029

Company'S Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12107A029
Person / Time
Site:	Palo Verde
Issue date:	04/02/2012
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06500-DCM/MAM/DLK, EA-12-051
Download: ML12107A029 (2)

Text

EA-1 2-051 L AM A subsidiaryof Pinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Senior Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Nuclear Regulatory and Oversight Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-06500-DCM/MAM/DLK April 02, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Arizona Public Service Company's Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an immediately effective order entitled Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (EA-1 2-051) to, inter alia, APS. The Order states that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Dai-ichi in March 2011, the NRC had decided to direct nuclear power plant licensees and construction permit holders to take certain actions. Specifically, the NRC is requiring additional defense-in-depth measures to address uncertainties associated with protection from beyond-design-basis external events. With respect to this Order, licensees are specifically directed to provide a reliable means of remotely monitoring "wide-range spent fuel pool levels" to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. Specific requirements are outlined in to the Order.

The Order requires submission of an overall integrated plan including a description of how compliance with the requirements described in Attachment 2 will be achieved to the NRC for review by February 28, 2013. In addition, the Order requires submission of an initial status report 60 days following issuance of the final interim staff guidance and at six month intervals following submittal of an overall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim staff guidance containing specific details on implementation of the requirements of this order in August 2012. Finally, the order requires full implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Comanche Peak

• Diablo Canyon 0 Palo Verde 0 San Onofre

• South Texas 0 Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 20-Day Answer to Order EA-1 2-051 Page 2 Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, APS hereby submits its answer to the Order. APS consents to the Order and does not request a hearing.

Based on information currently available, APS has not identified any circumstances of the type described in Sections IV.B.1 and IV.B.2 of the Order requiring relief at this time. In addition, APS has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever is earlier. APS will provide further responses as required by Section IV.C in accordance with the specified deadlines. However, given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of APS to comply with the specific compliance deadline dates based on the probable availability of that guidance, APS's future responses may include requests for schedule relief as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

No commitments are being made to the NRC by this letter. Should you need further information regarding this answer, please contact Mark McGhee, Operations Support Manager, Regulatory Affairs at (623) 393-4972.

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

Executed on ________

(Date)

Sincerely, DCM/MAM/DLK cc:

E. J. Leeds Director of Office of Nuclear Reactor Regulation E. E. Collins Jr. NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager for PVNGS L. K. Gibson NRC NRR Project Manager for PVNGS J. R. Hall NRC NRR Senior Project Manager M. A. Brown NRC Senior Resident Inspector for PVNGS