Letter Sequence Supplement |
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CAC:MF6576, Provide RISK-INFORMED Extended Completion Times - RITSTF Initiative 4B, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed) |
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MONTHYEARML15065A0312015-02-27027 February 2015 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO Project stage: Request ML15218A3002015-07-31031 July 2015 License Amendment Request to Revise Technical Specifications to Adopt TSTF-505-A, Revision 1, Risk-Informed Completion Times Project stage: Request ML15303A0982015-11-0909 November 2015 Acceptance Review Letter, License Amendment Request, Adopt Technical Specification Task Force (TSTF)-505, Revision 1, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b Project stage: Acceptance Review ML16060A0022016-02-26026 February 2016 NRR E-mail Capture - Palo Verde, Units 1, 2, and 3: Draft Request for Additional Information Amendment to Adopt TSTF-505 (CAC Nos. MF6576 MF6577 and MF6578) Project stage: Draft RAI ML16064A4972016-03-0707 March 2016 Request for Additional Information, Adopt Technical Specification Task Force (TSTF)-505, Revision 1, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b Project stage: RAI NL-17-0447, Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times2017-04-14014 April 2017 Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Project stage: Response to RAI ML17307A1882017-11-0303 November 2017 License Amendment Request Supplement for Risk-Informed Completion Times Project stage: Supplement ML18074A0202018-03-20020 March 2018 Fpra FAQ 16-0011 Closure Memo Project stage: Request ML18094B1122018-04-0404 April 2018 NRR E-mail Capture - Palo Verde 1, 2, and 3 - Final RAIs for TSTF-505 (Initiative 4b) LAR (CAC Nos. MF6576, MF6577, and MF6578: EPID L-2015-LLA-0001) Project stage: RAI ML18124A0112018-05-0303 May 2018 NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official Eeob RAIs for TSTF-505 (4b) LAR (CAC Nos. MF6576, MF6577, and MF6578; EPID L-2015-LLA-0001) Project stage: RAI ML18138A4802018-05-18018 May 2018 Response to Request for Additional Information for Risk-Informed Completion Times Project stage: Response to RAI ML18152B8742018-06-0101 June 2018 Response to Electrical Engineering Operating Reactor Branch (Eeob) Request for Additional Information for Risk-Informed Completion Times Project stage: Request ML18221A5102018-08-23023 August 2018 Request for Additional Information License Amendment Request to Adopt Risk-Informed Completion Times (CAC Nos. MF6576, MF6577, and MF6578; EPID: L-2015-LLA-0001) Project stage: RAI ML18264A3182018-09-21021 September 2018 Response to Request for Additional Information for Risk-Informed Completion Times Project stage: Response to RAI ML18278A2952018-10-0505 October 2018 Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Project stage: Supplement ML18275A2752018-10-10010 October 2018 Summary of September 14, 2018, Clarification Call with Arizona Public Service to Discuss the Incomplete Responses in the May 18, 2018, Letter the Adoption of Rict (CAC Nos. MF6576, MF6577, MF6578; EPID L-2015-LLA-0001) Project stage: Other ML19085A5252019-05-29029 May 2019 Issuance of Amendments Nos. 209, 209, and 209 - Regarding Adoption of Risk Informed Completion Times in Technical Specifications (CAC Nos. MF6576, MF6577, and MF6578; EPID L-2015-LLA-0001) Project stage: Approval 2018-10-05
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Category:Letter
MONTHYEARML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24 ML24019A1362024-01-18018 January 2024 Inservice Inspection Request for Information ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24010A1532024-01-10010 January 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection ML23341A0062023-12-21021 December 2023 Project Manager Assignment IR 05000528/20230112023-12-18018 December 2023 License Renewal Inspection Report 05000528/2023011 ML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1602023-11-17017 November 2023 Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20234032023-11-13013 November 2023 NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report) ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20230032023-10-17017 October 2023 Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003 ML23270B9232023-09-28028 September 2023 Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information ML23251A2332023-09-13013 September 2023 Notification of Post Approval Site Inspection for License Renewal and Request for Information Inspection (05000528/2023011) ML23241B0182023-09-13013 September 2023 Use of Honeywell Mururoa V4F1 and MTH2 Supplied Air Suits within Respiratory Protection Program IR 05000528/20243012023-09-0606 September 2023 Notification of NRC Initial Operator Licensing Examination 05000528/2024301; 05000529/2024301; 05000530/2024301 IR 05000528/20230102023-08-22022 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000528/2023010, 05000529/2023010 and 05000530/2023010 IR 05000528/20230052023-08-21021 August 2023 Updated Inspection Plan for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Report 05000528/2023005 and 05000529/2023005 and 05000530/2023005) ML23222A2762023-08-10010 August 2023 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX175 and AMZDFX176 and Vertical Concrete Cask Identification Numbers AMZDNE175, and AMZDNE176 ML23199A2942023-08-0909 August 2023 Issuance of Amendment Nos. 221, 221, and 221, to Revise Technical Specifications to Adopt TSTF-107, Separate Control Rods That Are Untrippable Versus Inoperable IR 05000528/20230022023-08-0808 August 2023 Integrated Inspection Report 05000528/2023002 and 05000529/2023002 and 05000530/2023002 ML23207A2482023-07-26026 July 2023 License Renewal Pressurizer Surge Line Inspection ML23188A1872023-07-0707 July 2023 Fourth 10-Year Interval, Second Period Owners Activity Report Number 2R24 ML23166B0832023-07-0505 July 2023 Independence Spent Fuel Storage Installation - Issuance of Exemption ML23181A1602023-06-30030 June 2023 2 to Updated Final Safety Analysis Report, and Revision 3 to Operations Quality Assurance Program Description ML23180A2222023-06-29029 June 2023 Application to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) - Operating, TS 3.5.2, Safety Injection Tanks (Sits) - Shutdown, and TS 3.6.5, Containment Air Temperature ML23181A0772023-06-29029 June 2023 Program Review - Simulator Testing Methodology ML23157A1292023-06-0101 June 2023 Annual Report of Guarantee of Payment of Deferred Premium ML23144A3722023-05-24024 May 2023 Response to Regulatory Issue Summary (RIS) 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23143A3912023-05-23023 May 2023 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements ML23145A2772023-05-17017 May 2023 10-PV-2023-05 Post-Exam Comments ML23132A3392023-05-12012 May 2023 Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls IR 05000528/20230012023-05-0808 May 2023 and Independent Spent Fuel Storage Installation - Integrated Inspection Report 05000528/2023001 and 05000529/2023001 and 05000530/2023001 and 07200044/2023001 ML23128A0692023-05-0808 May 2023 Notification of Biennial Problem Dentification and Resolution Inspection and Request for Information ML23122A1822023-04-29029 April 2023 Transmittal of Technical Specification Bases Revision 76 ML23122A1912023-04-29029 April 2023 Unit 1 Core Operating Limits Report Revision 32, Unit 2 Core Operating Limits Report Revision 25, Unit 3 Core Operating Limits Report Revision 31 ML23116A2772023-04-26026 April 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2022 ML23115A4012023-04-26026 April 2023 Review of the 2022 Steam Generator Tube Inspections During Refueling Outage 23 ML23115A4982023-04-25025 April 2023 2022 Annual Environmental Operating Report IR 05000528/20230122023-04-19019 April 2023 Notification of Commercial Grade Dedication Inspection (05000528/2023012, 05000529/2023012, and 05000530/2023012) and RFI ML23108A0342023-04-18018 April 2023 NRC Initial Operator Licensing Examination Approval 05000528/2023301; 05000529/2023301; 05000530/2023301 ML23103A4642023-04-13013 April 2023 Annual Radiological Environmental Operating Report 2022 ML23103A4312023-04-13013 April 2023 Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2022 IR 05000528/20224012023-04-13013 April 2023 Cyber Security Inspection Report 05000528/2022401 and 05000529/2022401 and 05000530/2022401 ML23102A3292023-04-12012 April 2023 Application for Authorized Use of Mururoa Single-Use, Supplied Air Suits, Models V4F1 and MTH2 ML23102A3242023-04-12012 April 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable ML23089A4002023-03-30030 March 2023 Consolidated Decommissioning Funding Status Report - 2022 ML23088A4012023-03-30030 March 2023 Project Manager Assignment IR 05000528/20234022023-03-29029 March 2023 and 3 - NRC Security Inspection Report 05000528-2023402, 05000529-2023402, and 05000530-2023402, (Cover Letter Only) ML23080A3002023-03-21021 March 2023 Present Levels of Financial Protection 2024-01-19
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle ML23048A3202023-02-17017 February 2023 Response to NRC Requests for Additional Information Regarding 2022 Unit 1 Steam Generator Tube Inspections ML22090A0802022-03-31031 March 2022 Response to NRC Requests for Additional Information Regarding 2021 Unit 3 Steam Generator Tube Inspections ML22053A2122022-02-22022 February 2022 Response to Requests for Confirmation of Information for Exemption from Certain Requirements of 10 CFR 50.62(c)(1) Using Risk-Informed Process for Evaluations ML21173A3602021-06-22022 June 2021 Response to Request for Additional Information for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML21061A1562021-02-26026 February 2021 Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses ML21005A2712020-12-29029 December 2020 102-08208 PVNGS Communication Required by Confirmatory Order EA-20-054 ML20090L9442020-03-30030 March 2020 APS Response to Request for Additional Information- Relief Request 65 Unit 2, COVID-19, Request for Relief from Bottom Mounted Instrumentation Nozzles and a Pressurizer Nozzle to Surge ML20073R7532020-03-13013 March 2020 Independent Spent Fuel Storage Installation (ISFSI) - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements ML20054A2692020-02-19019 February 2020 Response to Request for Additional Information - Relief Request 64 - Unit 1 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19340B2142019-12-0606 December 2019 Response to NRC Request for Additional Information Regarding 2019 Steam Generator Tube Inspections ML19331A3612019-11-26026 November 2019 Supplemental Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19277J4572019-10-0404 October 2019 Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19165A1402019-06-14014 June 2019 Response to Request for Additional Information - Relief Request 63 - Unit 3 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19137A1182019-05-17017 May 2019 Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome High Thermal ML19074A1382019-03-14014 March 2019 Response to Request for Additional Information - Relief Request 62 - Third and Fourth 10-Year Inservice Inspection Intervals, Proposed Alternative - Pressurizer Heater Sleeve Repairs ML19031C9052019-01-31031 January 2019 Supplemental License Amendment Request to Revise Technical Specifications Regarding Response Time Testing of Pressure Transmitters and Request for Additional Information Response ML18296A4662018-10-18018 October 2018 Supplemental Information Regarding License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel ML18278A2952018-10-0505 October 2018 Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 ML18264A3182018-09-21021 September 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18194A9142018-07-13013 July 2018 Supplemental Response to Request for Additional Information 3.a for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML18152B8742018-06-0101 June 2018 Response to Electrical Engineering Operating Reactor Branch (Eeob) Request for Additional Information for Risk-Informed Completion Times ML18138A4802018-05-18018 May 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18129A4482018-05-0909 May 2018 APS Response to Request for Additional Information for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML17272B0332017-09-29029 September 2017 Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests ML17153A3732017-06-0202 June 2017 Response to NRC Staff Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Next Generation Fuel ML17144A3762017-05-24024 May 2017 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML17002A0012017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML17066A1842017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML16358A7152016-12-23023 December 2016 Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Diesel Generator Completion Time ML16340A9882016-12-0101 December 2016 Addendum to Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors ML17167A2152016-11-23023 November 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised ... ML16321A0022016-11-0909 November 2016 Response to RAI, Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 ML16300A1562016-10-26026 October 2016 Response to NRC Electrical Engineering Branch Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay ... ML16286A2422016-10-0606 October 2016 Westinghouse Electric Company, WCAP-18030-NP Review, Suggested Response to Request for Additional Information ML16286A2402016-10-0606 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML16257A5442016-09-0909 September 2016 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16203A3812016-07-21021 July 2016 Response to NRC Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16182A5192016-06-30030 June 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Critical Safety Analysis ML16147A0922016-05-20020 May 2016 Response to Request for Additional Information Regarding Relief Request 54, Alternative to Flaw Removal ML16133A6212016-05-12012 May 2016 ISFSI - Response to Request for Additional Information Regarding Proposed Changes to Emergency Action Levels ML16102A4632016-04-11011 April 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505 ML16029A5062016-01-29029 January 2016 Response to Request for Additional Information Regarding the Request to Change the Quality Assurance Program Description ML15273A4702015-09-30030 September 2015 IR 05000528/2015004, 05000529/2015004, and 05000530/2015004; 11/16/2015 - 11/20/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Notification of NRC Triennial Heat Sink Performance Inspection ML15258A8482015-09-15015 September 2015 Response to Request for Additional Information Regarding Exigent License Amendment Request to Amend Technical Specification Surveillance Requirement 3.1.5.3 ML15223A2062015-08-0606 August 2015 Response to Request for Additional Information Associated with Seismic Hazard and Screening Report ML16133A3262015-05-0101 May 2015 Response to NRC Request for Flood Hazard Reevaluation Model Files ML18192A3891975-12-31031 December 1975 Public Service Company of New Mexico 1974 Annual Report, as Response to Request for Additional Financial Information ML18192B2781975-10-21021 October 1975 Response to NRC Liquefaction Questions. Review of Liquefaction Analysis in Parallel with the Site Dewatering Program 2024-01-12
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10 CFR 50.90 Qaps MARIA L. LACAL Senior Vice President Nuciear Reguiatory and Oversight Palo Verde 102-07801-MLL/MDD Nuclear Generating Station P.O. Box 52034 October 5, 2018 Phoenix, AZ 85072 Mail station 7605 Tel 623.393.6491 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
References:
- 1. Arizona Public Service Company (APS) Letter 102-07060, License Amendment Request to Revise Technical Specifications to Adopt TSTF-505-A, Revision 1, Risk-Informed Completion Times, dated July 31, 2015 [Agencywide Documents Access and Management System (ADAMS) Accession number ML15218A300]
- 2. APS Letter 102-07587, License Amendment Request Supplement for Risk-Informed Completion Times, dated November 3, 2017 (ADAMS Accession number ML17307A188)
- 3. APS Letter 102-07691, APS Response to Request for Additional Information for Risk-Informed Completion Times, dated May 18, 2018 (ADAMS Accession number ML18138A480)
- 4. APS Letter 102-07796, Response to Request for Additional Information for Risk-Informed Completion Times, dated September 21, 2018 (ADAMS Accession number ML18264A318)
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 On Juiy 31, 2015, as supplemented by letter dated November 3, 2017, APS submitted a iicense amendment request (LAR) to modify the Palo Verde Nuclear Generating Station (PVNGS) Technical Specification requirements to permit the use of risk-informed compietion times in accordance with Risk-Informed Technical Specification Task Force Initiative 4b, References 1 and 2, respectiveiy.
During the week of February 20, 2018, the NRC staff conducted an audit at PVNGS to gain an understanding of the pianned risk-informed compietion time program at PVNGS and to review the probabiiistic risk assessment modei that will be used by APS for this risk-informed LAR. The NRC staff communicated that additional Information was required to complete their review and APS responded to the request for additional information (RAI) in Reference 3. Following conference calls with the NRC staff on August 7, and September 14, 2018, APS agreed to provide supplemental information regarding four of the RAIs that were originally responded to in Reference 3. Two of the four (RAI 11 and RAI 16) were responded to in Reference 4, which also included A member of the STARS Alliance, LLC Callaway
102-07801-MLL/MDD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS Response to RAIs for Risk-Informed Completion Times Items 17.f and 21 Page 2 responses to NRC questions provided by NRC letter dated August 23, 2018. The enclosure to this letter provides the additional information for the remaining two RAIs (RAI 17.f and RAI 21) as described in Reference 4.
APS has reviewed the information supporting a finding of no significant hazards consideration previously provided to the NRC in Reference 1. APS has concluded that the information provided in this response does not affect the basis for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92.
No new commitments are being made to the NRC by this letter.
Should you need further information regarding this letter, please contact Michael D.
DiLorenzo, Nuclear Regulatory Affairs, at (623) 393-3495.
By copy of this letter, this RAI response is being forwarded to the Arizona Department of Health Services in accordance with 10 CFR 50.91(b)(1).
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: October 5. 2018 (Date)
Sincerely, MLL/MDD/PJH/sma
Enclosure:
APS Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 cc: K. M. Kennedy NRC Region IV Regional Administrator M. D. Orenak NRC NRR Project Manager for PVNGS C. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Department of Health Services - Bureau of Radiation Control (ADHS)
ENCLOSURE APS Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Attachment 1 - Updated PVNGS RICT PRA Implementation Items
Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Introduction On July 31, 2015, as supplemented by letter dated November 3, 2017, Arizona Public Service Company (APS) submitted a license amendment request (LAR) to modify the Palo Verde Nuclear Generating Station (PVNGS) Technical Specification (TS) requirements to permit the use of risk-informed completion times (RICT) in accordance with Risk-Informed Technical Specification Task Force (RITSTF) Initiative 4b [Agencywide Documents Access and Management System (ADAMS) Accession numbers ML15218A300 and ML17307A188].
During the week of February 20, 2018, the NRC staff conducted an audit at PVNGS to gain an understanding of the risk-informed completion time program at PVNGS and to review the probabilistic risk assessment (PRA) model that will be used by APS for this risk-informed LAR. The NRC staff communicated that additional information was required to complete their review and APS responded by letter numbers 102-07691, 102-07716, and 102-07796 dated May 18, June 1, and September 21, 2018 respectively (ADAMS Accession numbers ML18138A480, ML18152B874, and ML18264A318).
Following conference calls with the NRC staff on August 7, and September 14, 2018, APS agreed to provide supplemental information regarding four of the RAIs that were originally responded to in the APS letter dated May 18, 2018. Two of the four RAIs (RAI 11 and RAI 16) were responded to in the APS letter dated September 21, 2018, which also included responses to NRC questions from an August 23, 2018 letter to APS. This enclosure provides the additional information for the remaining two RAIs (RAI 17.f and RAI 21) as described in APS letter number 102-07796, dated September 21, 2018.
The APS response is provided after each RAI.
RAI 17 APLA - Fire PRA Methods
- f. Please confirm that the manual suppression probabilities are consistent with NUREG/CR-6850, EPRI [Electric Power Research Institute]/NRC-RES [Office of Nuclear Regulatory Research] Fire PRA Methodology for Nuclear Power Facilities," Volume 2, Appendix P (ADAMS Accession No. ML050940189), in that these are not less than the 0.001 floor.
APS Response to RAI 17.f The manual suppression rates are updated with the mean values provided in NUREG-2169, Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database, January 2015, Table 5-1, Probability Distribution for Rate of Fires Suppressed per Unit Time. A floor value of 0.001 is hard-coded into the calculations of manual non-suppression probability.
Therefore, the manual suppression probabilities are not less than the 0.001 floor, and in that respect the fire PRA model is consistent with NUREG/CR-6850. The estimated core damage frequency (CDF) and large early release frequency (LERF) values in the RAI 21 response reflect this change.
This item is complete; therefore, it is not reflected in Attachment 1, Table 1-1 as a future implementation action.
Page 1
Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 RAI 21 APLA - Total CDF and LERF LAR Attachment 9, Table A9-1 provides the total baseline CDF and LERF. Completing the actions in the NRC staff's RAIs may impact the CDF and LERF values. After completing the actions in the other RAIs, please identify changes made to the PRA in response to RAIs, and provide the estimated CDF and LERF values that incorporate all changes and modifications. Also, please propose a plan to incorporate those changes that affect total baseline CDF and LERF values prior to implementation of the RICT program.
APS Response to RAI 21 The following changes were made to the PRA model in response to RAIs:
Internal Events
- The reactor coolant pump (RCP) seal leakage model from the internal fire PRA (FPRA) was incorporated in the internal events PRA model [Response to RAI 16 in ML18138A480]
Internal Fire
- Incorporated the updated fire ignition frequencies, manual suppression rates and non-suppression probabilities (NSP) provided in NUREG-2169, Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database [Response to RAI 17.c, 17.d and 17.f in ML18138A480]
- Incorporated the updated electrical cabinet heat release rates provided in NUREG-2178, Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire (RACHELLE-FIRE) [Response to RAI 17.c and 17.d in ML18138A480]
- Incorporated updated oil fire split fractions (counting) per NRC position, item 3, Recent Fire PRA Methods Review Panel Decisions and EPRI1022993, Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires (ADAMS Accession Number ML12171A583) [Response to RAI 17.c in ML18138A480]
- Updated the KERITE cable type per FAQ 08-0053, Revision 1, Kerite-FR Cable Failure Thresholds (ADAMS Accession Number ML121440155) [Response to RAI 17.C in ML18138A480]
- Incorporated the methodology and results with respect to breaker coordination in Report 0001-0013-001-003, Revision 1, PVNGS Fire PRA Common Power Supply Associated Circuits Calculation [Response to RAI 17.b in ML18138A480]
- Incorporated additional guidance on modeling treatment for sensitive electronics per FAQ 13-0004, Revision 1, Clarification on Treatment of Sensitive Electronics (ADAMS Accession Number ML13322A085) [Response to RAI 17.C in ML18138A480]
- Incorporated the guidance in FAQ 16-0011, Revision 1, Cable Tray Ignition, for determining fire propagation through a cable tray arrangement for specific scenarios (ADAMS Accession Number ML18074A020) [Response to f^I 17.c in ML18138A480]
- Incorporated modeling for fire-induced Anticipated Transients Without Scram (ATWS) [Response to EICB-RAI-2 in ML16102A463]
Page 2
Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Seismic Incorporated the updated 2016 Seismic Hazard Analysis for PVNGS [Response to RAI 9 in ML18138A480]
Table 1 provides an estimate of the total Unit 1/2/3 baseline CDF and LERF values with these changes reflected.
A review was conducted of incorporated changes into the estimate model to determine which of these changes were upgrades and if any of the upgrades were significant to meeting the Regulatory Guide (RG) 1.174 risk limits. Table 2 of this enclosure provides a summary of the identified PRA upgrades. None of the upgrades identified in Table 2 were determined significant to meeting the risk limits in RG 1.174.
The upgrades identified in Table 2 will undergo a focused scope peer review in accordance with NEI 05-04 and any findings will be resolved prior to implementation of the RICT program. Attachment 1, Table 1-1, Item 5 identifies the PRA upgrades that are required to be completed prior to implementation of the RICT program.
Attachment 1 also contains a partial revision to Table 1-1 for the PVNGS, Units 1, 2 and 3 RICT PRA implementation items, documented in APS letter number 102-07691, dated May 18, 2018, APS Response to Request for Additionai Information for Risk-Informed Compietion Times (ADAMS Accession Number ML18138A480). This partial revision incorporates item 6 associated with a revision to procedure 40EP-9E001, Standard Post Trip Actions, as described in Table 1 below.
Table 1 Estimated Total Unit 1/2/3 Baseline CDF/LERF Hazard CDF (per reactor-yr)
Internal Events 5.1E-6 1.7E-7 Internal Flooding 4.6E-7 2.1E-8 Seismic 1.7E-5 2.2E-6 Internal Fire* 4.9E-5 5.2E-6 Total 7.2E-5 7.6E-6
- Table 1 credits a change to procedure 40EP-9EO0]L, Standard Post Trip Actions, which is in process and not yet implementeid. The change adds a contingency operator action to locally trip motor gerlerator sets power supply breakers NGN-L03C4 and NGN-L10C4. PVNGS will irnplement this change as described in Attachment 1, Table 1-1, item 6.
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Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Table 2 - Identified PVNGS PRA Model Upgrades Significant to I meeting RG 1 Impact Upgrade Upgrade Description Description 1.174 Risk 1 ID Type 1 imil-s? '
Capability PRA model change may No 2017-2021 Closure of F&O AS-03, loss of coolant accident (LOCA) Change impact significant accident modeling success criteria sequences and significant justification accident progression sequences Methodology Human-induced flooding may No 2017-2026 Closure of Internal Flooding F&O 1-2, Human-Induced Change involve a new methodology Flooding (Linked with that has not previously been Impact 2018-2526) applied in the PVNGS PRA 2017-2028 Methodology Implemented a different No Closure of F&O SHA-E2-01, Updated Seismic Hazard Change methodology for seismic Analysis hazard evaluation than previously applied 2017-2029 Capability Additional relays were No Closure of F&O SFR-F3-01, Resolve Seismic Fragility of Change included in the SPRA model Unaddressed Relays which impacted significant accident sequences and risk insights 2018-2526 Closure of Internal Flooding Methodology Human-induced flooding may No F&O IFEV-A7-01, Human- Change involve a new methodology Induced Flooding (Linked that has not previously been with Impact 2017-2026) applied in the PVNGS PRA 2018-2531 Capability More robust HRA approach No Closure of F&O SPR-B8-01, Post-Seismic Event Ex- Change may impact significant Control Room Operator accident sequences and risk Actions Alternate Paths insights Various Modeling of Fire-Induced Capability Model change to fire-induced No ATWS Change ATWS which impacted significant accident sequences and risk insights Page 4
Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Attachment 1 Updated PVNGS RICT PRA Implementation Items Page 5
Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Attachment 1 Updated PVNGS RICT PRA Implementation Items The following tables are partial revisions (e.g. adds information) to Table 1-1 and Table 1-2 from the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3 RICT PRA implementation items, identified in APS letter number 102-07691, dated May 18, 2018, APS Response to Request for Additional Information for Risk-Informed Completion Times (ADAMS Number ML18138A480). The items identified below will be addressed prior to implementation of the RICT program. Table 1-2 reflects the addition of this letter to the proposed license condition.
Partial Revision to Table 1-1 PVNGS RICT PRA Implementation Items Description Resolution
- 5. Seven PRA model upgrades were identified Conduct a focused scope peer review for the from a review of all PRA model changes not following PRA model upgrades:
reviewed by peer reviews:
PRA model impact 2017-2021: Closure a. PRA model impact 2017-2021: Closure of a.
of F&O AS-03, LOCA modeling success F&O AS-03, LOCA modeling success criteria criteria justification justification
- b. PRA model impact 2017-2026: Closure PRA model impact 2017-2026: Closure of of Internal Flooding F&O 1-2, Human- Internal Flooding F&O 1-2, Human-Induced Induced Flooding (Linked with Impact Flooding (Linked with Impact 2018-2526) 2018-2526) c. PRA model impact 2017-2028: Closure of PRA model impact 2017-2028: Closure F&O SHA-E2-01, Updated Seismic Hazard of F&O SHA-E2-01, Updated Seismic Analysis Hazard Analysis d. PRA model impact 2017-2029: Closure of
- d. PRA model impact 2017-2029: Closure F&O SFR-F3-01, Resolve Seismic Fragility of of F&O SFR-F3-01, Resolve Seismic Unaddressed Relays Fragility of Unaddressed Relays e. PRA model impact 2018-2526: Closure of
- e. PRA model Impact 2018-2526: Closure Internal Flooding F&O IFEV-A7-01, Human-of Internal Flooding F&O IFEV-A7-01, Induced Flooding (Linked with Impact Human-Induced Flooding (Linked with 2017-2026)
Impact 2017-2026) PRA model impact 2018-2531: Closure of PRA model impact 2018-2531: Closure F&O SPR-B8-01, Post-Seismic Event Ex-of F&O SPR-B8-01, Post-Seismic Event Control Room Operator Actions Alternate Ex-Control Room Operator Actions Paths Alternate Paths g- Modeling of Fire-Induced ATWS g- Modeling of Fire-Induced ATWS This condition is described, in response to NRC These actions are indicated in response to NRC RAI RAI 21, in APS letter 102-07801, dated 21, in APS letter 102-07801, dated October 5, October 5, 2018. 2018.
- 6. Revise procedure 40EP-9E001, Standard Post Implement change to procedure 40EP-9E001, Trip Actions, to credit operator action to locally Standard Post Trip Actions, to credit operator action trip NGN-L03C4 and NGN-L10C4. to locally trip NGN-L03C4 and NGN-L10C4.
This condition is described in the response to RAI This action is indicated in response to RAI 21, in APS 21, in APS letter 102-07801, dated October 5, letter 102-07801, dated October 5, 2018.
2018.
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Enclosure APS Response to RAIs for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 Attachment 1 Updated PVNGS RICT PRA Implementation Items Table 1-2 Additional Conditions Amendment Additional Conditions Implementation Number Date Arizona Public Service Company (APS) is approved to implement the risk-informed completion time (RICT) program specified in license amendment [NUMBER] dated
[DATE].
The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC. If the licensee wishes to use a newly developed method, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval, via a license amendment.
[NUMBER] APS will complete the implementation items listed in the Prior to implementation of Enclosure of APS letter 102-07587, dated November 3, RICT program.
2017, to the NRC and in Attachment 1, Table 1-1 of APS letter 102-07691, dated May 18, 2018, as updated by APS letter 102-07801, dated October 5, 2018, prior to implementation of RICTs. All issues identified will be addressed and any associated changes will be made, focused scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the RICT program.
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