ML25100A253
| ML25100A253 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/10/2025 |
| From: | Dilorenzo M Arizona Public Service Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 102-08925-MDD/ARS, RIS 2025-01 | |
| Download: ML25100A253 (1) | |
Text
RIS 2025-01 A Member of STARS Alliance LLC Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek 102-08925-MDD/ARS April
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Reference:
Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2025-01, Pre-application Communication and Scheduling for Licensing Actions Related to Digital Instrumentation and Controls [Agencywide Documents Access and Management System (ADAMS) Accession No. ML25007A014]
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Response to NRC Regulatory Issue Summary 2025-01, Pre-application Communication and Scheduling for Licensing Actions Related to Digital Instrumentation and Controls This letter provides Arizona Public Service (APS) Companys voluntary response to the referenced NRC Regulatory Issue Summary (RIS) 2025-01 for Palo Verde Nuclear Generating Station. The attachment to this letter includes APS answers to the NRC questions in the RIS regarding Digital Instrumentation and Controls (DI&C) upgrades within the next two years.
No new commitments are being made to the NRC by this letter.
If you have any questions or require additional information, please contact Michael D.
DiLorenzo, Licensing Department Leader, at (623) 393-3495.
Sincerely, Michael D. DiLorenzo Department Leader Nuclear Regulatory Affairs - Licensing MDD/ARS/cmr : Response to Regulatory Issue Summary 2025-01 for Digital Instrumentation and Controls cc:
J. D. Monninger NRC Region IV Regional Administrator W. T. Orders NRC NRR Project Manager for PVNGS A. T. Tran Acting NRC Senior Resident Inspector for PVNGS Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7636 Tel: 623-393-3495 Dilorenzo, Michael D(Z99838)
Digitally signed by Dilorenzo, Michael D(Z99838)
Date: 2025.04.10 11:43:01 -07'00'
of 1 Response to Regulatory Issue Summary 2025-01 for Digital Instrumentation and Controls
Response to Regulatory Issue Summary 2025-01 for Digital Instrumentation and Controls The NRC seeks voluntary responses to the following questions:
- 1. Do you plan to submit a DI&C upgrade-related license application (e.g., license amendment)? If so, what is the estimated timeframe for such a submittal?
Yes, Arizona Public Service (APS) expects to submit multiple License Amendment Requests (LARs) related to Digital Instrumentation and Controls (DI&C) upgrades for Palo Verde Nuclear Generating Station (PVNGS). Project planning, including scoping, schedule, and platform selection for these efforts, is in early stages; therefore, timelines for LAR submittals have not been developed yet.
- 2. Do you plan to hold preapplication meetings with the NRC staff? If so, what is the estimated timeframe for the initial preapplication meeting?
Yes, APS expects to hold preapplication meetings with the NRC staff related to DI&C upgrades in accordance with DI&C-Interim Staff Guidance (ISG)-06 guidance. Project planning for these efforts is in the early stages; therefore, a timeframe for preapplication meetings has not been developed yet.
- 3. Which systems do you plan to upgrade?
Upgrades to the following systems, currently in planning phases, are included in the PVNGS Safety Related Modernization (SRM) Program:
x The existing Palo Verde Digital (Common Q) Core Protection Calculator (CPC) System is planned to be modified under 10 CFR 50.59 to support a Technical Specification Surveillance Requirement reduction LAR. This will be covered under Phase A of the SRM Program.
x The analog Reactor Protection System, Engineered Safety Features Actuation System, and Excore Nuclear Instrumentation System (currently known in the PVNGS Updated Final Safety Analysis Report as Excore Neutron Flux Monitoring) are planned to be upgraded to a digital platform. These are future phases currently being scoped.
- 4. What platform(s) will be used for the upgrade?
The CPC System upgrade as part of Phase A of the SRM Program is currently a Common Q platform system and will remain as Common Q. The platform(s) selection for upgrades under future phases is unknown at this time.
- 5. Do you plan to use DI&C-Interim Staff Guidance (ISG)-06, Revision 2, Licensing Process, issued December 2018 (ADAMS Accession No. ML18269A259), to prepare your application? If yes, which of the four processes (e.g., Tier 1) described in the ISG do you believe the NRC will use in its evaluation of the application based on the criteria provided in Section C of ISG-06?
Yes, APS expects to use DI&C-ISG-06, Revision 2, Licensing Process, to prepare applications for the PVNGS SRM Program. Technical details needed to determine the appropriate ISG processes are not known at this time, as the project planning for the SRM Program is under development.