ML130700342

APS 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)

ML130700342
Person / Time
Site:	Palo Verde
Issue date:	02/28/2013
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06670-DCM/MAM, EA-12-049
Download: ML130700342 (2)

Text

EA-1 2-049 DWIGHT C. MIMS r,')

apsSenior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station 102-06670-DCM/MAM P.O. Box 52034 February 28, 2013 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 5403 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

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

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

3.

NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 21, 2012

4. APS Letter 102-06614, 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 29, 2012

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 APS 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)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Arizona Public Service Company (APS). Reference 1 was immediately effective and directs APS 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 of Reference 1.

Reference 1 requires submission of an overall integrated plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this overall integrated plan.

A member of the STARS (strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak - Diablo Canyon ° Palo Verde - San Onofre - South Texas ° Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Page 2 On October 29, 2012, APS provided the initial status report for PVNGS regarding mitigation strategies (Reference 4), as required by Reference 1.

The purpose of this letter is to provide an overall integrated plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms APS has received Reference 2 and has an overall integrated plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events.

The information in the enclosure provides the PVNGS Overall Integrated Plan for mitigation strategies that incorporates the guidance from Reference 3. The enclosed overall integrated plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month updates required by Reference 1.

No commitments are being made to the NRC by this letter.

Should you have any questions concerning the content of this letter, 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, Enclosure - APS 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 DCM/MAM/DKE/hsc cc:

E. J. Leeds, E. E. Collins Jr.

J. K. Rankin M. A. Brown J. A. Kratchman E. E. Bowman NRC Director, Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS NRR/JLD/PMB, NRC NRR/DPR/PGCB, NRC