ML17335A119

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Documentation of the Completion of Required Actions Taken in Response to the Lessons Learned from the Fukushima Dai Ichi Accident
ML17335A119
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 12/21/2017
From: Louise Lund
Division of Licensing Projects
To: Bement R
Arizona Public Service Co
Bernardo R
References
Download: ML17335A119 (27)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 21, 2017 Mr. Robert S. Bement Executive Vice President Nuclear/

Chief Nuclear Officer Arizona Public Service Company P.O. Box 52034, MS 7602 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - DOCUMENTATION OF THE COMPLETION OF REQUIRED ACTIONS TAKEN IN RESPONSE TO THE LESSONS LEARNED FROM THE FUKUSHIMA DAI-ICHI ACCIDENT

Dear Mr. Bement:

The purpose of this letter is to acknowledge and document that actions required by the U.S. Nuclear Regulatory Commission (NRC) in orders issued following the accident at the Fukushima Dai-ichi Nuclear Power Station have been completed for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). In addition, this letter acknowledges and documents that Arizona Public Service Company (APS, the licensee) has provided the information requested in the NRC's March 12, 2012, request for information under Title 1O of the Code of Federal Regulations (10 CFR), Section 50.54(f), related to the lessons learned from that accident. Completing these actions and providing the requested information, in conjunction with the regulatory activities associated with the Mitigation of Beyond-Design-Basis Events (MBDBE) rulemaking, implements the safety enhancements mandated by the NRC based on the lessons learned from the accident. Relevant NRC, industry, and licensee documents are listed in the reference tables provided in the enclosure to this letter. The NRC will provide oversight of these safety enhancements through the Reactor Oversight Process (ROP).

BACKGROUND In response to the events in Japan resulting from the Great Tohoku Earthquake and subsequent tsunami on March 11, 2011, the NRC took immediate action to confirm the safety of U.S.

nuclear power plants:

  • On March 18, 2011, the NRC issued Information Notice 2011-05, "Tohoku-Taiheiyou-Oki Earthquake Effects on Japanese Nuclear Power Plants" (Reference 1.1 ). The information notice was issued to inform U.S. operating power reactor licensees and applicants of the effects from the earthquake and tsunami. Recipients were expected to review the information for applicability to their facilities and consider actions, as appropriate.

Suggestions contained in an information notice are not NRC requirements; therefore, no specific action or written response was required.

  • On March 23, 2011, the NRC issued Temporary Instruction (Tl) 2515/183, "Followup to the Fukushima Daiichi Fuel Damage Event." The purpose of Tl 2515/183 was to provide NRC

R. Bement inspectors with guidance on confirming the reliability of licensees' strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following events that may exceed the design-basis for a plant. The results of the inspection for each licensee were documented in an inspection report (Reference 1.2).

  • On March 23, 2011, the Commission provided staff requirements memorandum (SRM)

COMGBJ-11-0002, "NRC Actions Following the Events in Japan." The tasking memorandum directed the Executive Director for Operations to establish a senior level agency task force, referred to as the Near-Term Task Force (NTTF), to conduct a methodical and systematic review of the NRC processes and regulations to determine whether the agency should make additional improvements to the regulatory system and make recommendations to the Commission within 90 days for its policy direction (Reference 1.3).

  • On April 29, 2011, the NRC issued Tl 2515/184, "Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs)." The purpose of Tl 2515/184 was to inspect the readiness of nuclear power plant operators to implement SAMGs. The results of the inspection were summarized and provided to the NTTF, as well as documented in a 2011 quarterly integrated inspection report for each licensee (Reference 1.4).
  • On May 11, 2011, the NRC issued Bulletin (BL) 2011-01, "Mitigating Strategies."

BL 2011-01 required licensees to provide a comprehensive verification of their compliance with the regulatory requirements 10 CFR 50.54(hh)(2), as well as provide information associated with the licensee's mitigation strategies under that section. In 10 CFR 50.54(hh)(2), it states, in part: "Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire ... " BL 2011-01 required a written response from each licensee (Reference 1.5).

  • On July 21, 2011, the NRC staff provided the NTTF report, "Recommendations for Enhancing Reactor Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to the Commission in SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan" (Reference 1.6).
  • On October 3, 2011, the staff prioritized the NTTF recommendations into three tiers in SECY-11-0137, "Prioritization of Recommended Actions To Be Taken in Response to Fukushima Lessons Learned." The Commission approved the staff's prioritization, with comment, in the SRM to SECY-11-0137 (Reference 1.7).

A complete discussion of the prioritization of the recommendations from the NTTF report, additional issues that were addressed subsequent to the NTTF report, and the disposition of the issues that were prioritized as Tier 2 or Tier 3 is provided in SECY-17-0016, "Status of Implementation of Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami" (Reference 12.10). A listing of the previous Commission status reports, which were provided semiannually, can be found in Table 12 in the enclosure to this letter.

R. Bement The NRG undertook the following regulatory activities to address the majority of the Tier 1 recommendations:

  • On March 12, 2012, the NRG issued Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

EA-12-050, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," and EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," and a request for information under 10 CFR 50.54(f)

(hereafter referred to as the 50.54(f) letter) to licensees (References 1.8, 1.9, 1.10, and 1.11, respectively).

  • On June 6, 2013, the NRG issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" (Reference 1.12), which superseded Order EA-12-050, replacing its requirements with modified requirements.
  • In addition to the three orders and the 50.54(f) letter, the NRG is considering a new regulation (1 O CFR 50.155, "Mitigation of Beyond-Design-Basis Events"). The draft final rule and supporting documentation were provided to the Commission for approval in SECY-16-0142, "Draft Final Rule - Mitigation of Beyond-Design-Basis Events (RJN 3150-AJ49)" (Reference 1.13). The MBDBE rulemaking would consolidate several of the recommendations from the NTTF report. The draft final rule, as provided to the Commission, contains provisions that make generically applicable the requirements imposed by Orders EA-12-049 and EA-12-051 and supporting requirements for the integrated response capability that includes staffing, communications, training, drills or exercises, and documentation of changes. The draft final rule also contains requirements for licensees to consider the effects of the reevaluated seismic and flooding hazard information identified in response to Enclosures 1 and 2 of the 50.54(f) letter. Three proposed regulatory guides (References 1.14, 1.15, and 1.16) were included to provide methods and procedures that the NRG staff considers acceptable for licensees to demonstrate compliance with the MBDBE rule, if approved by the Commission.

This letter acknowledges and documents that the actions required by the NRG in response to the orders, as well as the information provided in response to the March 12, 2012, 50.54(f) letter, have been completed for Palo Verde. However, the staff is not determining whether the licensee complies with the draft final MBDBE rule. Oversight of compliance with the draft final MBDBE rule at Palo Verde will be conducted through the ROP if the Commission approves the rule.

DISCUSSION Mitigation Strategies Order Order EA-12-049, which applies to Palo Verde, requires licensees to implement a three-phase approach for mitigation of beyond-design-basis external events (BDBEE). It requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a BDBEE that results in a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink (LUHS). Phases 1 and 2 of the order use onsite equipment,

R. Bement while Phase 3 requires obtaining sufficient offsite resources to sustain those functions indefinitely.

In August 2012, the Nuclear Energy Institute (NEI) issued industry guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," as guidance to comply with the order. The NRC endorsed the guidance in Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) document 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" (Reference 2.1 ). Under the order, licensees were required to provide an overall integrated plan (OIP) to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 2.2). The NRC staff provided an interim staff evaluation (ISE) related to the OIP (Reference 2.3). The NRC concluded in the ISE that the licensee provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, including satisfactory resolution of the open and confirmatory items, would meet the requirements of Order EA-12-049 at Palo Verde. The NRC staff also conducted a regulatory audit of the licensee's strategies and issued a report which documented the results of the audit activities (Reference 2.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter and a final integrated plan (FIP) to the NRC (Reference 2.5). The FIP describes how the licensee is complying with the order at Palo Verde.

The NRC staff completed a safety evaluation (SE) of the licensee's FIP (Reference 2.6). The SE informed the licensee that its integrated plans, if implemented as described, provided a reasonable path for compliance with Order EA-12-049 at Palo Verde. The staff then evaluated the implementation of the plans through inspection, using Tl 2515/191, "Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communications/Staffing/Multi-Unit Dose Assessment Plans." An inspection report was issued to document the results of the Tl 2515/191 inspection (Reference 2.7). The NRC will oversee implementation of the mitigation strategies requirements under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

Phase 3 of Order EA-12-049 required licensees to obtain sufficient offsite resources to sustain the required functions indefinitely. There are two redundant National Strategic Alliance for FLEX Emergency Response (SAFER) Centers (NSRCs), one located in Memphis, Tennessee, and the other in Phoenix, Arizona, which have the procedures and plans in place to maintain and deliver the equipment needed for Phase 3 from either NSRC to any participating U.S. nuclear power plant when requested (Reference 2.8). The NRC staff evaluated and inspected the NSRCs and the SAFER program, plans, and procedures (References 2.9 and 2.10). The NRC concluded that licensees may reference the SAFER program and implement their SAFER response plans to meet the Phase 3 requirements of the order. The licensee's FIP (Reference 2.5) includes the plans for utilizing the NSRC equipment at Palo Verde. In its SE (Reference 2.6), the NRC staff concluded that the licensee has developed guidance that, if implemented appropriately, should allow utilization of offsite resources following a BDBEE consistent with NEI 12-06 guidance and should adequately address the requirements of the order.

Spent Fuel Pool Instrumentation Order Order EA-12-051, which applies to Palo Verde, required licensees to install reliable SFP level instrumentation with a primary channel and a backup channel, independent of each other, and with the capability to be powered independent of the plant's power distribution systems. The

R. Bement NEI issued NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051," as guidance to be used by licensees to comply with the order and the NRC endorsed the guidance in JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation" (Reference 3.1 ). The order required licensees to provide an OIP to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 3.2). The NRC issued an ISE, providing feedback on the OIP (Reference 3.3). The NRC staff conducted a regulatory audit of the licensee's strategies and issued a report that documented the results of the audit activities (Reference 3.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter to the NRC (Reference 3.5), describing how the licensee complied with the order at Palo Verde.

The NRC staff completed an SE of the actions taken by the licensee in response to the order (Reference 3.6). The SE informed the licensee that its integrated plan, if implemented as described, provided a reasonable path for compliance with Order EA-12-051 at Palo Verde.

The staff then evaluated the implementation of the plan through inspection, using Tl 2515/191.

An inspection report was issued to document the results of the Tl 2515/191 inspection (Reference 3.7). The NRC will oversee implementation of the SFP instrumentation requirements under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

Reliable Hardened Containment Vent Order Order EA-13-109 is only applicable to boiling-water reactors (BWRs) with Mark I and Mark II containments. Because the reactors at Palo Verde are pressurized water reactors (PWR) with large dry, ambient pressure containments, this order is not applicable to Palo Verde.

Request for Information Under 10 CFR 50.54(f)

The 50.54(f) letter requested licensees to:

  • reevaluate the seismic and flooding hazard at their sites using present-day NRC requirements and guidance, and identify actions that are planned to address plant-specific vulnerabilities associated with the reevaluated seismic and flooding hazard;
  • perform seismic and flooding walkdowns to verify compliance with the current licensing basis; verify the adequacy of current strategies and maintenance plans; and identify degraded, nonconforming, or unanalyzed conditions related to seismic and flooding protection; and
  • provide an assessment of their current emergency communications and staffing capabilities to determine if any enhancements are needed to respond to a large-scale natural emergency event that results in an extended loss of ac power to all reactors at the site, and/or impeded access to the site.

In COMSECY-14-0037, "Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluat[i]on of Flooding Hazards" (Reference 6.11 ), the NRC staff described issues related to the implementation of Order EA-12-049 and the related MBDBE rulemaking, and the completion of flooding reevaluations and assessments. In the SAM to COMSECY-14-0037 (Reference 6.12), the Commission directed the NRC staff to ensure that licensees of operating nuclear power plants address the reevaluated hazard within their

R. Bement mitigation strategies for BDBEE. The SRM also directed the NRC staff to provide a plan for achieving closure of the flooding hazard assessments to the Commission for review and approval. The plan was provided in COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants" (Reference 6.13}, and approved by the Commission in the SRM to COMSECY-15-0019 (Reference 6.14).

Hazard Reevaluations (Enclosures 1 and 2 of the 50.54(f) letter)

Each licensee followed a similar two-phase process to respond to the hazard reevaluations requested by the 50.54(f) letter. In Phase 1, licensees submitted hazard reevaluation reports using NRG-endorsed, industry-developed guidance. The guidance specified that a licensee should determine if interim protection measures were needed while a longer-term evaluation of the impacts of the hazard was completed. The NRC staff reviewed the reevaluated hazard information. Using the reevaluated hazard information and a graded approach, the NRC identified the need for, and prioritization and scope of, plant-specific assessments. For those plants that were required to perform a flooding integrated assessment or a seismic probabilistic risk assessment (SPRA), Phase 2 decisionmaking (as described in a letter dated September 16, 2016 (Reference 5.16)) would determine whether additional plant-specific regulatory actions were necessary. In addition, as discussed in COMSECY-15-0019 and the draft final MBDBE rule, each licensee performed a mitigation strategies assessment (MSA) to confirm that the licensee had adequately addressed the reevaluated hazards within their mitigation strategies developed for BDBEEs.

Seismic Hazard Reevaluation (Enclosure 1 of the 50.54(f) letter) of the 50.54(f) letter requested each operating reactor licensee to complete a reevaluation of the seismic hazard that could affect their sites using updated seismic hazard information and present-day regulatory guidance and methodologies to develop a ground motion response spectrum (GMRS). The licensee was asked to compare their results to the safe shutdown earthquake (SSE) ground motion and then report to the NRC in a seismic hazard screening report. To provide a uniform and acceptable industry response, the Electric Power Research Institute (EPRI) developed a technical report, EPRI 1025287, "Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," and the NRC endorsed the guidance in a letter dated February 15, 2013 (Reference 5.1 ). Between November 2012 and May 2014, the NRC and the industry provided guidance for the performance of the reevaluated hazard reviews (References 5.2-5.6). The licensee provided a seismic hazard screening report for Palo Verde (Reference 5.7). In response to NRC requests for additional information, the licensee provided two supplements to the seismic hazard screening report (Reference 5.8).

If the new GMRS was not bound by the current design basis (COB) SSE, more detailed evaluations of the impact from the hazard were requested. Also, the licensee was requested to evaluate whether interim protection measures were needed while the more detailed evaluation was completed. The NEI provided a proposed path forward and schedules in a letter from NEI dated April 9, 2013. The NRC endorsed this approach in a letter dated May 7, 2013. The guidance to perform the interim protective measures evaluation, EPRI report 300200704, "Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," was provided as Attachment 1 to the NEI letter (Reference 5.3). This expedited seismic evaluation process (ESEP) is a screening, evaluation, and equipment modification process conducted by licensees to provide additional seismic margin and expedite plant sf).fety enhancements for certain core cooling and containment

R. Bement components while the more detailed and comprehensive plant seismic risk evaluations are being performed. Palo Verde was not required to perform an ESEP (Reference 5.11) since the SSE envelopes the reevaluated GMRS at most frequencies above 1 Hertz (Hz) region. Minor exceedances were noted at approximately 1.2 Hz and at greater than 35 Hz. These exceedances are considered "de minimis" (too minor to merit consideration), as noted in Reference 5.9.

By letter dated May 13, 2015 (Reference 5.10), the NRG informed licensees of the initial screening and prioritization results for the western US sites based on a review of the licensees' seismic hazard screening reports. The NRG provided the final determination of required seismic evaluations in a letter dated October 27, 2015 (Reference 5.11 ). These evaluations could consist of an SPRA (Reference 5.1, SPID, Section 6.1.1 ), limited scope evaluations (High Frequency (Reference 5.12) and/or SFP (Reference 5.13)), or a relay chatter evaluation (Reference 5.4). If an SPRA was required, then additional Phase 2 regulatory decisionmaking would be required (References 5.14 and 5.15). Palo Verde was screened out from any further assessments.

The NRG staff completed and documented its review of the licensee's reevaluated seismic hazard in a staff assessment (Reference 5.9). Compared to the SSE, the staff determined that the GMRS was approximately 2 percent higher at 1.2 Hertz (Hz) and approximately 1O percent higher at greater than 35 Hz. The staff determined that these small GMRS exceedances of the SSE were not significant, and that the licensee did not need to complete additional seismic risk evaluations, an SFP evaluation or a high frequency confirmation. The NRG staff determined that the licensee provided sufficient information in response to Enclosure 1 of the 50.54(f) letter.

The staff acknowledges that all seismic hazard reevaluation activities requested by Enclosure 1 of the 50.54(f) letter have been completed for Palo Verde. No further information related to the reevaluated seismic hazard is required.

Flooding Hazard Reevaluation (Enclosure 2 of the 50.54(f) letter) of the 50.54(f) letter requested each operating reactor licensee to complete a reevaluation of applicable flood-causing mechanisms at their site using updated flooding hazard information and present-day regulatory guidance and methodologies. Licensees were asked to compare their results to the COB for protection and mitigation from external flood events. The NRG developed guidance to conduct the reevaluations (References 6.1 through 6.6). The licensee submitted a flood hazard reevaluation report (FHRR) for Palo Verde (Reference 6.7) to the NRG as requested by the 50.54(f) letter. No interim actions were deemed necessary in response to the reevaluated flood hazard. A regulatory audit to support the review of the FHRR was performed and the results documented in an audit report (Reference 6.8). The NRG staff reviewed the FHRR and provided an interim hazard letter (Reference 6.1 O) to provide feedback on the staff's review of the flooding hazard reevaluations. The interim hazard letter was used by the licensee to complete the flood hazard MSA and other flood hazard evaluations. Separately, the NRG staff documented the technical bases for its conclusions in the interim hazard letters by issuing a staff assessment (Reference 6.11 ).

In COMSECY-14-0037 (Reference 6.13), the NRG staff requested Commission direction to more clearly define the relationship between Order EA-12-049, the related MBDBE rulemaking, and the flood hazard reevaluations and assessments. Because the NRG was reevaluating its approach to the flooding evaluations, the NRG provided an extension of the due dates for any integrated assessments in a letter dated November 21, 2014 (Reference 6.12). In the SRM to COMSECY-14-0037 (Reference 6.14), the Commission affirmed that licensees of operating

R. Bement nuclear power plants need to address the reevaluated flooding hazard within their mitigation strategies. The Commission also directed the NRC staff to provide a plan for achieving closure of the flooding portion of NTTF Recommendation 2.1 to the Commission for its review and approval. On May 26, 2015, the NRC deferred, until further notice, the date for submitting the integrated assessment reports (Reference 6.15). On June 30, 2015, the NRC staff provided a plan to the Commission in COMSECY-15-0019 (Reference 6.16). On July 28, 2015, the Commission approved the plan in the SRM to COMSECY-15-0019 (Reference 6.17). On September 29, 2015, the NRC issued a letter to licensees to describe the graded approach to the flood hazard reevaluations approved by the Commission (Reference 6.18).

The COMSECY-15-0019 action plan required the NRC staff to develop a graded approach to identify the need for, and prioritization and scope of, plant-specific integrated assessments and evaluation of plant-specific regulatory actions. The NRC staff's graded approach enabled a site with hazard exceedance above its COB to demonstrate the site's ability to cope with the reevaluated hazard through appropriate protection or mitigation measures which are timely, effective, and reasonable. Integrated assessments were focused on sites with the greatest potential for additional safety enhancements. New guidance for performing the integrated assessments and focused evaluations was developed for this graded approach. The guidance also provided schedule information for submission of any required integrated assessment. On July 18, 2016, the staff issued JLO-ISG-2016-01, "Guidance for Activities Related to Near-Term Task Force Recommendation 2.1, Flooding Hazard Reevaluation, Focused Evaluation and Integrated Assessment" (Reference 6.19). The ISG provided the guidance for Phase 1 flooding assessments, as described in COMSECY-15-0019, and endorsed industry guidance provided in NEI 16-05, "External Flooding Integrated Assessment Guidelines" (Reference 6.19). If an integrated assessment was necessary, then Phase 2 regulatory decisionmaking was required (References 6.23 and 6.24).

As noted in the interim hazard response letter (Reference 6.10), the reevaluated flood hazard result for local intense precipitation was not bound by the COB. The NRC staff used a graded approach to determine if this site would be subject to an integrated assessment for the reevaluated flooding hazard, or if a more focused evaluation can be performed in lieu of the integrated assessment. Based on the graded approach, Palo Verde completed a focused evaluation (Reference 6.20} to ensure appropriate actions are identified and taken to protect the plant from the reevaluated flood hazard. The NRC staff conducted a regulatory audit (Reference 6.22), completed its review of the focused evaluation and concluded in the staff assessment (Reference 6.21) that the licensee provided sufficient information in response to the 50.54(f) letter. No further regulatory actions are required related to the flood hazard reevaluations.

The NRC staff reviewed the information provided by the licensee and has concluded that sufficient information was provided to be responsive to Enclosure 2 of the 50.54(f) letter. The staff acknowledges that all flooding hazard reevaluation activities requested by Enclosure 2 of the 50.54(f) letter have been completed for Palo Verde. No further information related to the reevaluated flood hazard is required.

Mitigation Strategies Assessment In addition to the closure plan for NTTF Recommendation 2.1, the action plan approved by the Commission in the SRM to COMSECY-15-0019 (Reference 7.4) identified the staff efforts to ensure licensees would address the reevaluated hazard information in their mitigation

R. Bement strategies. Performance of the MSA is necessary to support compliance with the final MBDBE rule, if approved by the Commission.

The objective of the MSA is to determine whether the mitigation strategies developed for Order EA-12-049 can still be implemented given the reevaluated hazard levels. If it was determined that the mitigation strategies could not be implemented for the reevaluated hazard levels, the MSA could provide other options such as performing additional evaluations, modifying existing mitigation strategies, or developing alternate mitigation strategies or targeted mitigation strategies to address the reevaluated hazard levels at Palo Verde. The process used to develop the MSAs was provided in Appendices G and H of NEI 12-06, as endorsed by the NRC in JLD-ISG-2012-01 (Reference 7.5).

Both a flood hazard MSA (Reference 7.6) and a seismic hazard MSA (Reference 7.8) were provided by the licensee. A regulatory audit was not required (Reference 7.10). The NRC staff reviewed the MSA submittals, and issued staff assessments (References 7.7 and 7.9) documenting its review. The NRC staff concluded that the licensee has demonstrated that the mitigation strategies appropriately address the reevaluated hazard conditions. Oversight of any changes to existing mitigation strategies, or new strategies, resulting from the MSAs will be included in the longer-term oversight of mitigation strategies through the ROP.

Walkdowns (Enclosures 3 and 4 of the 50.54(f) letter)

Enclosures 3 and 4 of the 50.54(f) letter requested that licensees perform plant walkdowns to verify compliance with the current licensing basis as it pertains to seismic and flood protection.

Technical Report EPRI 1025286, "Seismic Walkdown Guidance" (Reference 8.1 ), was provided as guidance to licensees for conducting the seismic walkdowns and the NRC endorsed that guidance by letter dated May 31, 2012 (Reference 8.2). The NEI issued NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (Reference 9.1 ), as guidance to licensees for conducting the flooding walkdowns and the NRC endorsed that guidance by letter dated May 31, 2012 (Reference 9.2). The licensee provided a report for both the seismic and flooding walkdowns at Palo Verde (References 8.3 and 9.3). Onsite inspections were conducted per Tl 2515/188, "Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns" (Reference 8.4) and Tl 2515/187, "Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns" (Reference 9.4), and the inspection results were documented in a quarterly integrated inspection report. The NRC staff issued staff assessments for both the seismic and flooding walkdowns (References 8.5 and 9.5). If any items were inaccessible during the initial licensee seismic walkdowns, the licensee submitted a subsequent seismic walkdown report after accessing the areas (Reference 8.5). The NRC documented its review of the subsequent walkdown reports in a letter dated September 25, 2015 (Reference 8. 7).

The NRC staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosures 3 and 4 of the 50.54(f) letter. The staff acknowledges that all seismic and flooding walkdown activities requested by the 50.54(f) letter have been completed for Palo Verde.

Communications and Staffing (Enclosure 5 of the 50.54(f) letter) of the 50.54(f) letter requested licensees to assess their means to power equipment needed to communicate onsite and offsite during a prolonged station blackout event and to identify and implement enhancements to ensure that communications can be maintained during

R. Bement such an event. Also, licensees were requested to assess the staffing required to fill all necessary positions to respond to a multi-unit event with impeded access to the site, or to an extended loss of all ac power for single unit sites. Licensees were requested to submit a written response to the information requests within 90 days, or provide a response within 60 days and describe an alternative course of action and estimated completion dates. The licensee proposed an alternative course of action and schedule for Palo Verde (Reference 10.2), which included a 90-day partial response (Reference 10.3). The NRG acknowledged the schedule changes in a letter dated July 26, 2012 (Reference 10.4).

The communications and staffing evaluation reports were developed using NRG-endorsed, industry-developed guidance (Reference 10.1 ). Guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," was endorsed by the NRG in a letter dated May 15, 2012. The licensee provided the communications assessment and implementation schedule for Palo Verde (Reference 10.5),

and the NRG completed a staff assessment of the licensee's communications assessment (Reference 10.6).

Licensees responded to the staffing portion of the 50.54(f) letter in two phases to account for the implementation of mitigation strategies. Phase 1 staffing assessments were based on the existing station blackout coping strategies with an assumption of all reactors at the site being affected concurrently. The Phase 1 staffing assessment is required for multiunit sites and was completed for Palo Verde (Reference 10.7). In Phase 2, all licensees assessed the staffing necessary to carry out the mitigation strategies (Reference 10.9). The NRG staff issued staffing assessment response letters (References 10.8 and 10.10) for each submittal. An onsite inspection using Tl 2515/191 was conducted to verify that the emergency communications and staffing plans at Palo Verde have been implemented as described by the licensee (Reference 10.11 ).

The draft final MBDBE rule would make generically applicable the staffing and communications requirements to support the mitigation strategies. Regulatory Guide 1.228 (Reference 1.16) is expected to endorse, with clarifications, NEI 12-01, NEI 13-06, "Enhancements to Emergency Response Capabilities for Beyond-Design-Basis Events and Severe Accidents" (Reference 11.17), and NEI 14-01, "Emergency Response Procedures and Guidelines for Beyond-Design-Basis Events and Severe Accidents" (Reference 11.7), to provide acceptable methods for implementing the MBDBE rule requirements, if approved. The NRG will oversee the communications and staffing requirements, and a periodic drill or exercise, under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

The NRG staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosure 5 of the 50.54(f) letter. The staff acknowledges that all emergency preparedness communications and staffing activities requested by Enclosure 5 of the 50.54(f) letter have been completed for Palo Verde. No further information related to the communications and staffing assessments is required.

Additional Industry Commitments Update and Maintain Severe Accident Management Guidelines The staff provided the proposed MBDBE rule to the Commission on April 30, 2015, in SECY-15-0065, "Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49)" (Reference 11.1) and the Commission issued the SRM to SECY-15-0065 on

R. Bement August 27, 2015 (Reference 11.2). The Commission approved publication of the proposed rule subject to removal of the proposed requirements pertaining to the SAMGs. The Commission also directed the staff to update the ROP to explicitly provide periodic oversight of industry's implementation of the SAMGs. By letter dated October 26, 2015 (Reference 11.3), NEI described the industry initiative, approved by the Nuclear Strategic Issues Advisory Committee as mandatory for all NEI members, to update and maintain the SAMGs. Specifically, each licensee will perform timely updates of their site-specific SAMGs based on revisions to generic severe accident technical guidelines. Licensees will also ensure that SAMGs are considered within plant configuration management processes. As noted in the NEI letter, the licensee provided a letter (Reference 11.4) to establish a site-specific regulatory commitment for Palo Verde.

In a letter to NEI dated February 23, 2016 (Reference 11.5), the staff outlined its approach for making changes to the ROP in accordance with the Commission direction. The staff engaged NEI and other stakeholders to identify the near-term and long-term changes to the ROP, consistent with the Commission direction and the licensees' near-term and long-term SAMG commitments. The staff then revised Inspection Procedure 71111.18, "Plant Modifications" (Reference 11.6), to provide oversight of the initial inclusion of SAMGs within the plant configuration management processes to ensure that the SAMGs reflect changes to the facility over time.

Multiunit/Multisource Dose Assessments In COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (Reference 11.13), the staff requested Commission approval to implement the NTTF recommendation concerning multiunit/multisource dose assessments by having licensees document their commitment to obtain multiunit/multisource dose assessment capability by the end of 2014, rather than by issuing an order. Multiunit dose assessment capabilities would be made generically applicable through subsequent rulemaking. The Commission approved the staff's requests in the SRM to COMSECY-13-0010, dated April 30, 2013 (Reference 11.14). The licensee commitments are documented in References 11.8 through 11.11.

The NRC staff included the multiunit/multisource dose assessment requirement in the proposed MBDBE rulemaking (Reference 11.1 ). However, in response to a public comment concerning the 10 CFR 50.109 backfitting justification for the proposed multiple source term dose assessment requirements, the staff determined that this requirement did not meet the criteria for imposition under 10 CFR 50.109(a)(4)(ii). The NRC staff also concluded that this could not be justified as a compliance backfit or as a substantial safety improvement whose costs, both direct and indirect, would be justified in light of the potential safety gain. Therefore, these requirements were removed from the draft final rule (Reference 11.16).

The licensee provided the requested information and stated that Palo Verde will have multiunit/multisource dose assessment capabilities (Reference 11.11) by December 31, 2014.

The NRC acknowledged the licensee's submittal (Reference 11.12), verified the implementation of these dose assessment capabilities through inspection per Tl 2515/191, and issued an inspection report (Reference 11.15).

R. Bement CONCLUSION The NRC staff concludes that APS, the licensee, has implemented the NRG-mandated safety enhancements resulting from the lessons learned from the Fukushima Dai-ichi accident through its implementation of Orders EA-12-049, EA-12-051, and its response to the 50.54(f) letter at Palo Verde. No further regulatory decisionmaking is required for Palo Verde related to the Fukushima lessons-learned.

A listing of the applicable correspondence related to the Fukushima lessons-learned activities for Palo Verde is included as an enclosure to this letter.

If you have any questions, please contact Robert Bernardo of my staff at 301-415-2621 or by electronic mail at Robert.Bernardo@nrc.gov.

Sincerely, Louise Lund, Director Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos. 50-528, 50-529, 50-530

Enclosure:

Documents Related to Required

Response

cc w/encl: Distribution via Listserv

Palo Verde Nuclear Generating Station, Units 1, 2 and 3 Reference Documents Related to Required Response to the Lessons Learned from the Fukushima Dai-ichi Accident TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Tohoku Earthquake. and Subsec uent Tsunami

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1.1 NRC Information Notice 2011-05 March 18, 2011 ML110760432 1.2 NRC Follow-up to the Fukushima Dai-ichi ,;  ; ,\t{~;(:!\'i " ,* ~

Fuel Damaoe Event Temporary Instruction (Tl) 2515/183 March 23, 2011 ML11077A007 NRC Tl 2515/183 Inspection Report May 13, 2011 ML11133A328 2011-006 1.3 NRC Tasking Memorandum, Staff March 23, 2011 ML110820875 Requirements Memorandum (SRM) to COMGBJ-11-0002 1.4 NRC Availability and Readiness Inspection ,.

of SAMG NRC Availability and Readiness April 29, 2011 ML11115A053 Inspection of SAMG - Tl 2515/184 NRC Integrated Inspection Report August 11 , 2011 ML112240044 2011-003 (Tl 2515/184 inspection results)

NRC Tl 2515/184 Inspection May 26, 2011 ML111470264 Results, Reoion 4 Summary NRC Summary of Tl 2515/184 June 6, 2011 ML11154A109 Results 1.5 NRC Bulletin 2011-01 , "Mitigation Strateoies"

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NRC Bulletin 2011-01 May 11 , 2011 ML111250360 Licensee 30 day response to June 10, 2011 ML11173A060 BL 2011-01 Licensee 60 day response to July 11, 2011 ML11200A313 BL 2011-01 NRC Request for Additional November 30, 2011 ML113110205 Information (RAI) regarding Licensee 60 day response to BL 2011-01 Licensee response to RAI December 29, 2011 ML 1201 OA028 NRC Closeout of BL 2011-01 for June 26, 2011 ML12171A419 Palo Verde 1.6 NRC NTTF Report (SECY-11-0093) July 21 , 2011 ML11186A950 1.7 NRC SECY-11 -0137, Prioritization of Recommended Actions To Be Taken in Response to Fukushima Lessons Learned I NRC SECY-11-0137 October 3, 2011 ML11272A111 SRM-SECY-11-0137 December 15, 2011 ML113490055 1 Agencywide Documents Access and Management System (ADAMS)

Enclosure

Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Tohoku Earth uake and Subse uent Tsunami ADAMS 1Aeceeaion No.

Date NRC Order EA-12-049 March 12, 2012 ML12054A735 NRC Order EA-12-050 March 12, 2012 ML12054A694 NRC Order EA-12-051 March 12, 2012 ML12054A679 NRC Request for Information Under March 12, 2012 ML12053A340 10 CFR 50.54 f the 50.54 f letter 1.12 NRC Order EA-13-109 June 6, 2013 ML13143A321 1.13 NRC SECY-16-0142, "Draft Final Rule: December 15, 2016 ML16301A005 Miti ation of Be ond-Desi n-Basis Events" 1.14 Regulatory Guide 1.226, Flexible Mitigation November 2016 ML16301A128 Strategies for Beyond-Design-Basis Events Draft Final Version 1.15 Regulatory Guide 1.227, Wide Range November 2016 ML16211A167 Spent Fuel Pool Level Instrumentation Draft Final Version 1.16 Regulatory Guide 1.228 - Integrated November 2016 ML16218A236 Response Capabilities for Beyond-Design-Basis Events (Draft Final Version Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 2 Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events - EA-12-049 2.1 At . ' ';:tt Guidance for Compliance with EA-12-049 -

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Industry Guidance on Diverse and August 21, 2012 ML12242A378 Flexible Coping Strategies (FLEX)

NEI 12-06, Revision O NRC endorsement of NEI 12-06, August29,2012 ML12229A174 Revision O - JLD-ISG-2012-01, Revision O Industry Guidance on Diverse and December 2015 ML16005A625 Flexible Coping Strategies (FLEX)

NEI 12-06, Revision 2 NRC endorsement of NEI 12-06, January 22, 2016 ML15357A163 Revision 2 - JLD-ISG-2012-01, Revision 1 2.2 Licensee Overall lnteQrated Plan (OIP)

Licensee OIP submittal February 28, 2013 ML130700342 OIP 1st six month status report August 28, 2013 ML13246A007 OIP 2nd six month status report February 28, 2014 ML14066A036 01 P 3rd six month status report AUQUSt 28, 2014 ML14246A211 OIP 4th six month status report February 27, 2015 ML15065A032 OIP 5th six month status report August 14, 2015 ML15232A028 2.3 NRC Interim Staff Evaluation of OIP November ..

25, 2013 ML13308C153 2.4 NRC audit of EA-12-049 OIP NRC Notification of Audit of EA-12-049 AUQUSt 28, 2013 ML13234A503 NRC Site Specific Audit Plan March 19, 2014 ML14069A516 NRC Audit Report September 8, 2014 ML14239A181 2.5 Licensee Final Integrated Plan (FIP)

Licensee Compliance Letter for December 17, 2015 ML15351A449 EA-12-049 Licensee Fl P for EA-12-049 December 24, 2015 ML15364A034 2.6 NRC Safety Evaluation of Implementation of July 20, 2016 ML16088A261 EA-12-049 2.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Preparedness Information '*

NRC Temporary Instruction 2515/191 October 6, 2014 ML14273A444 NRC Tl 2515/191 Inspection Report January 3, 2017 ML17004A044 2016-009 2.8 Industry White Paper - National SAFER September 11, ML14259A221 Response Centers (NSRC) 2014 2.9 NRC Staff Assessment of NSRCs September 26, ML14265A107 2014 Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 2 Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events - EA-12-049 ADAMS Ref Document Acce8eion No.

2.10 NRC Inspection of Implementation of n-.... '"*

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EA-12-049 Reqardinq the use of NSRC NRC Inspection Procedure (IP) 43006 September 30, ML16273A318 2016 NRC Vendor Inspection of the Phoenix January 12, 2017 ML17012A186 NSRC Report No. 99901013/2016-201 NRC Vendor Inspection of the Memphis May 5, 2017 ML17117A576 NSRC Report No. 99901013/2017-201 Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 3 Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation -

EA-12-051 ...

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Date, Accession No.

3.1 Guidance for Compliance with EA-12-051 -

Spent Fuel Pool Instrumentation Industry Guidance for Compliance with August 2012 ML12240A307 EA-12-051 - NEI 12-02, Revision 1 NRC endorsement of NEI 12-02, August29, 2012 ML12221A339 Revision 1 - JLD-ISG-2012-03, Revision O 3.2 Licensee Overall lnteqrated Plan (OIP)

Licensee 01 P February 28, 2013 ML13070A077 01 P 1st six month status report Auqust28,2013 ML13246A008 OIP 2nd six month status report February 28, 2014 ML14065A039 OIP 3rd six month status report August 28, 2014 ML 14246A21 O OIP 4th six month status report February 27, 2015 ML15065A033 OIP 5th six month status report Auqust 14, 2015 ML15232A027 3.3 NRC Interim Staff Evaluation of OIP October 29, 2013 ML13296A006 3.4 NRC Audit of EA-12-051 NRC Notification of Audit of EA-12-051 March 26, 2014 ML14083A620 NRC Audit Report of Westinghouse August 18, 2014 ML14211A346 SFPI desiqn specifications NRC Site Specific Audit Plan March 19, 2014 ML14069A516 NRC Audit Report September 8, 2014 ML14239A181 3.5 Licensee Compliance Letter for EA-12-051 December 17, 2015 ML15351A449 3.6 NRC Safety Evaluation of Implementation of July 20, 2016 ML16088A261 EA-12-051 3.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency '

Preparedness Information I'*

NRC Temporary Instruction 2515/191 October 6, 2014 ML14273A444 NRC Tl 2515/191 Inspection Report January 3, 2017 ML17004A044 2016-009 Note: TABLE 4 RELATES TO THE HARDENED CONTAINMENT VENT SYSTEM AND IS NOT APPLICABLE TO PALO VERDE Palo Verde Nuclear Generating Station, Units 1, 2 and 3

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TABLE 5 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54(f) Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation

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Industry Guidance (SPID) - November 2012 ML12333A170 EPRI 1025287 NRC letter endorsinQ SPID February 15, 2013 ML12319A074 5.2 NRC guidance for performing a Seismic November 16, 2012 ML12286A029 Margin Assessment (SMA) -

JLD-ISG-2012-04 5.3 Expedited Seismic Evaluation Process *j;>:;; *< "~,

(ESEP)

Industry Letter - Proposed path April 9, 2013 ML13101A345 forward for NTTF Recommendation 2.1: Seismic Industry Guidance - Expedited April 2013 ML13102A142 Seismic Evaluation Process (ESEP) -

EPRI 3002000704 NRC letter endorsing the ESEP May 7, 2013 ML13106A331 approach and extension of due date to 3/31/14 (Central and Eastern U.S.)

5.4 Industry letter on relay chatter review October 3, 2013 ML13281A308 5.5 NRC letter with guidance on the content of February 20, 2014 ML14030A046 seismic reevaluation submittals (includes operability and reportability discussions) 5.6 NRC background paper - Probabilistic seismic May 20, 2014 ML14140A648 hazard analysis Seismic Hazard Screening Report

5. 7 Licensee Seismic Hazard ScreeninQ Report March 10, 2015 ML15076A073 5.8 Supplemental Responses Supplemental Information Regarding the April 10, 2015 ML15105A076 Seismic DesiQn and LicensinQ Basis Response to RAI associated with Seismic August 6, 2015 ML15223A206 Hazard and Screening Report 5.9 NRC Staff Assessment of Reevaluated September 13, ML16221A604 Seismic Hazard Information 2016 Screening and Prioritization Results 5.1 O NRC Letter - Seismic screening and May 13, 2015 ML151138344 prioritization results for Western U.S. plants 5.11 NRC Final Determination of Required Seismic October 27, 2015 ML15194A015 Evaluations Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 5 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54(f) Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation ADAMS Re{ L: ~*, &;1:"l~,* * **

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5.12 High Frequency Program Application Guidance Industry HF Application Guidance - EPRI July 30, 2015 ML15223A095 3002004396 NRC letter endorsing HF Application September 17, ML15218A569 Guidance 2015 5.13 Spent Fuel Pool Evaluation Guidance Industry SFP evaluation guidance - February 23, 2016 ML16055A017 EPRI 3002007148 NRC letter endorsing SFP evaluation March 17, 2016 ML15350A158 guidance 5.14 NRC Letter - Treatment of Seismic and September 29, ML15127A401 Flooding Hazard Reevaluations in the Design 2015 and Licensinq Basis 5.15 NRC Guidance for Regulatory September 21, ML16237A103 Decisionmaking of reevaluated flooding and 2016 seismic hazards Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 6 Request for Information Pursuant to Title 10 of the Code Of Federal Regulations 50.54(0 Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation

. ADAMS.

Ref ;Doeoment v: J*!<': ,Date: ,,, *

,No.

6.19 Floodinq Assessment Guidance NEI 16-05, "External Flooding April 2016 ML16165A178 Assessment Guidelines" NRC endorsement of NEI 16 July 11, 2016 ML16162A301 JLD-ISG-2016-01 6.20 Licensee Focused Evaluation for flooding June 29, 2017 ML17181A515 6.21 NRC Staff Assessment of Focused Evaluation November 17, 2017 ML17299A041 6.22 NRC Generic FE and IA Requlatory Audit Plan July 18, 2017 ML17192A452 6.23 NRC Letter - Treatment of Seismic and September 29, ML15127A401 Flooding Hazard Reevaluations in the Design 2015 and Licensing Basis 6.24 NRC Guidance for Regulatory Decisionmaking September 21, ML16237A103 of reevaluated floodinq and seismic hazards 2016 TABLE 7 Mitigating Strategies Assessments (MSA)

ADAMS Ref Document 1

  • oate, Accession No.

7.1 NRC COMSECY-14-0037, Integration of November 21, 2014 ML14309A256 Mitigating Strategies with Hazard Reevaluations 7.2 NRC SRM-COMSECY-14-0037 March 30, 2015 ML15089A236 7.3 NRC COMSECY-15-0019, Closure Plan for June 30, 2015 ML15153A104 Floodinq Hazard Reevaluations 7.4 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 7.5 Process for Mitigating Strategies Assessments .:,,-*.X if,: .. *

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Industry Guidance for performing December 2015 ML16005A625 MSAs - NEI 12-06, Revision 2, including Appendices E, G, & H NRC endorsement of NEI 12-06, January 22, 2016 ML15357A163 Revision 2 - JLD-ISG-2012-01, Revision 1 7.6 Licensee's MSA submittal - Flooding December 8, 2016 ML163438070 7.7 NRC Staff Assessment of MSA - Floodinq March 27, 2017 ML17069A092 7.8 Licensee's MSA submittal - Seismic January 31, 2017 ML17031A185 7.9 NRC Staff Assessment of MSA - Seismic February 7, 2017 ML170370257 7.10 NRC MSA Audit Plan December 6, 2016 ML16259A189 Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 8 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54(0 Enclosure 3: Recommendation 2.3 Seismic .. Walkdown l' i..'. .:~i\\ "'* *, r '

ADAMS Ref ..ent ., - ~11:; Acceasion No.

8.1 Industry Seismic Walkdown Guidance with May 31, 2012 ML12188A031 NRC endorsement letter - EPRI 1025286 8.2 NRC letter endorsinq EPRI 1025286 Mav 31, 2012 ML12145A529 8.3 Licensee Seismic Hazard Walkdown Reports ki '"* (*1"'11,1:,;,;2" **~ .,. ,'";:.*r't ,,* .

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Licensee Seismic Hazard Walkdown November 27, 2012 ML12341A319 Report (Unit 1)

Supplement to walkdown report (U1) Januarv 14, 2014 ML14022A054 Licensee Seismic Hazard Walkdown November 27, 2012 ML12339A196 Report (Unit 2)

Supplement to walkdown report (U2) Auqust30, 2013 ML13252A109 Licensee Seismic Hazard Walkdown November 27, 2012 ML12340A475 Report (Unit 3)

Response to RAls (Units 1, 2 and 3) December 12, 2013 ML13352A008 8.4 NRC Inspection of Seismic Walkdowns NRC Tl 2515/188 Julv 6, 2012 ML12156A052 NRC Integrated Inspection Report February 7, 2013 ML13038A565 2012-005 (Tl 2515/188 results) 8.5 Licensee subsequent seismic walkdown report Subsequent seismic walkdown report April 30, 2014 ML14126A636 (Unit 3 onlv) 8.6 NRC Staff Assessment of Seismic Walkdown April 11, 2014 ML14087A188 Report 8.7 NRC review of seismic subsequent walkdown September 25, ML15268A477 reports 2015 TABLE 9 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54 f Enclosure 4: Recommendation 2.3 Floodin Walkdown ADAMS Accession No.

Industry Flooding Walkdown Guidance - NEI ML12173A215 12-07 9.2 ML12144A142 9.3 November 27, 2012 ML12334A416 9.4 June 27, 2012 ML12129A108 NRC Integrated Inspection Report February 7, 2013 ML13038A565 2012-005 (Tl 2515/187 inspection results 9.5 NRC Staff Assessment of Flooding Walkdown May 20, 2014 ML14120A072 Re ort Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE10 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54(f) Enclosure 5: Recommendation 9.3 Emergency Preparedness Communications and Staffing

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Industry Guidance for Emergency May 2012 ML12125A412 Preparedness staffing and communications - NEI 12-01 NRC letter endorsinQ NEI 12-01 May 15, 2012 ML12131A043 10.2 Palo Verde 60 day response and May 11, 2012 ML12139A324 proposed alternative course of action 10.3 Palo Verde 90 day response to June 8, 2012 ML12171A202 communications and staffing information requests 10.4 NRC letter - status of 90-day response July 26, 2012 ML12200A106 10.5 Licensee communications assessment October 31, 2012 ML 1231 OA368 and implementation schedule Communications assessment October 31, 2012 ML 1231 OA368 Supplement to communications February 22, 2013 ML13063A034 assessment 10.6 NRC staff assessment of licensee's June 6, 2013 ML13149A055 communications assessment 10.7 Licensee Phase 1 staffinQ assessment April 30, 2013 ML13128A014 10.8 NRC Phase 1 staff assessment response October 23, 2013 ML13233A183 10.9 Licensee Phase 2 staffing assessment } '{

response Licensee Phase 2 staffing June 11, 2014 ML14167A397 assessment for functions related to mitiQatinQ strateQies 10.10 NRC Phase 2 staff assessment response September 29, ML14262A296 2014

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10.11 NRC Inspection of Licensee Responses t*

to EA-12-049, EA-12-051, and EmerQency Preparedness Information NRC Temporary Instruction October 6, 2014 ML14273A444 2515/191 NRC Tl 2515/191 Inspection January 3, 2017 ML17004A044 Report 2016-009 Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 11 Additional Licensee Commitments - SAMGs and Multisource Dose Assessments U date and Maintain SAMGs 11.1 SECY-15-0065: Proposed Rulemaking: April 30, 2015 ML15049A201 Mitigation of Beyond-Design-Basis Events RIN 3150-AJ49 11.2 SRM-SECY-15-0065 Au ust 27, 2015 ML15239A767 11.3 NEI Letter describing industry initiative to October 26, 2015 ML15335A442 u date and maintain SAMGs 11.4 Site Specific Commitment to Maintain December 15, 2015 ML153498042 SAMGs 11.5 NRC letter to NEI describing approach to February 23, 2016 ML16032A029 SAMG oversi ht 11.6 NRC Inspection Procedure 71111.18, November 17, 2016 ML16306A185 "Plant Modifications" (Effective Date Janua 1, 2017 11.7 NEI 14-01, "Emergency Response February 2016 ML16224A619 Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 1 Multisource Dose Assessments 11.8 NEI Letter: Industry survey and plan for January 28, 2013 ML13028A200 multiunit dose assessments 11.9 NRC Letter to request additional February 27, 2013 ML13029A632 information from NEI on multiunit dose assessment ca abilit 11.10 NEI Letter: Commitment for March 14, 2013 ML13073A522 Implementation of Multiunit Dose Assessment Ca abilit 11.11 Licensee Response Regarding the June 28, 2013 ML13189A131 Capability to Perform Offsite Dose Assessment During an Event Involving Multi le Release Sources 11 .12 NRC Acknowledgement of Licensee January 29, 2014 ML13233A205 Dose Assessment Submittals 11.13 COMSECY-13-0010 ML12339A262 11.14 SRM-COMSECY-13-0010 ML13120A339 11.15 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Erner enc Pre aredness Information NRC Temporary Instruction October 6, 2014 ML14273A444 2515/191 NRC Tl 2515/191 Inspection January 3, 2017 ML17004A044 Re ort 2016-009 11.16 Draft Final Rule: Mitigation of December 15, 2016 ML16301A005 Beyond-Design-Basis Events NRC SECY-16-0142, Packa e Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE11 Additional Licensee Commitments - SAMGs and Multisource Dose Assessments ADAMS Aa:esaion o.

11.17 NEI 13-06, "Enhancements to Emergency February 2016 ML16224A618 Reponses Capabilities for Beyond Design Basis Accidents and Events, Revision 1 Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE12 NRC Semi-Annual Status Reports to the Commission l:'.,.L.:

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12.1 SECY-12-0025, Enclosure 8, "Proposed February 17, 2012 ML12039A103 Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami" 12.2 SECY-12-0095 - Enclosure 1: Six-Month July 13, 2012 ML12165A092 Status Update On Charter Activities -

February 2012 - July 2012 12.3 SECY-13-0020 -Third 6-Month Status Update February 14, 2013 ML13031A512 On Response To Lessons Learned From Japan's March 11, 2011, Great Tohoku Earthquake And Subsequent Tsunami 12.4 SECY-13-0095 - Fourth 6-Month Status September 6, 2013 ML13213A304 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.5 SECY-14-0046 - Fifth 6-Month Status Update April 17, 2014 ML14064A520 on Response to Lessons Learned From Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.6 SECY-14-0114 - Sixth 6-Month Status Update October 21, 2014 ML14234A498 on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.7 SECY-15-0059 - Seventh 6-Month Status April 9, 2015 ML15069A444 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.8 SECY-15-0128: Eighth 6-Month Status October 14, 2015 ML15245A473 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.9 SECY-16-0043: Ninth 6 Month Status Update April 5, 2016 ML16054A255 on Response to Lessons Learned from

~

Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami 12.10 SECY-17-0016: Status of Implementation of January 30, 2017 ML16356A084 Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami Palo Verde Nuclear Generating Station, Units 1, 2 and 3 TABLE 6 Request for Information Pursuant to Title 1O of the Code Of Federal Regulations 50.54(f) Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation

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Initial Guidance Documents 6.1 NRC prioritization of plants for completing May 11, 2012 ML12097A509 flood hazard reevaluations 6.2 NRG-issued guidance for performing an November 30, 2012 ML12311A214 integrated assessment for external flooding (JLD-ISG-2012-05) 6.3 NRC letter to industry describing when an December 3, 2012 ML12326A912 integrated assessment is expected 6.4 NRG-issued guidance for performing a January 4, 2013 ML12314A412 tsunami, surge, or seiche hazard assessment (JLD-ISG-2012-06) 6.5 NRC letter to industry with guidance on the March 1, 2013 ML13044A561 content of floodinQ reevaluation submittals 6.6 NRG-issued guidance for assessing flooding July 29, 2013 ML13151A153 hazards due to dam failure (JLD-ISG-2013-01)

Flood Hazard Reevaluation Report 6.7 Licensee FHRR Submittal December 12, 2014 ML14350A466 6.8 FHRR Reaulatorv Audit NRC FHRR Site Specific Audit Plan July 7, 2015 ML15177A149 NRC FHRR Audit Report May 18, 2016 ML16112A021 6.9 NRC Inspection of licensee interim actions Not Required Not Required 6.10 NRC Interim Staff Response to Reevaluated Flood Hazards NRC Interim Staff Response to September 28, ML15268A413 Reevaluated Flood Hazards 2015 Correction to Interim Staff Response October 8, 2015 ML15280A022 6.11 NRC Staff Assessment of FHRR November 14, 2016 ML16306A444 Modified Approach to Flood Hazard Reevaluations 6.12 NRC extension of due dates for Integrated November 21, 2014 ML14303A465 Assessment reports 6.13 NRC COMSECY-14-0037, "Integration of November 21, 2014 ML14309A256 Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards" 6.14 NRC SRM for COMSECY-14-0037 March 30, 2015 ML15089A236 6.15 NRC letter on second extension of due date May 26, 2015 ML15112A051 for floodinQ inteQrated assessment reports 6.16 NRC COMSECY-15-0019 "Closure Plan for June 30, 2015 ML15153A104 the Reevaluation of FloodinQ Hazards" 6.17 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 6.18 NRC letter describing the graded approach to September 1, 2015 ML15174A257 flood hazard reevaluation directed by SRM-COMSECY-14-0037

ML17335A119 *via e-mail OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA* NRR/DLP/PBEB/BC (A) NRR/DLP/PBMB/BC NAME RBernardo Slent* TBrown MShams DATE 12/1/17 8/25/17 12/5/17 12/10/17 OFFICE NRR/DLP/D NAME Llund DATE 12/21/17

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