ML25188A210
| ML25188A210 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/03/2025 |
| From: | William Orders NRC/NRR/DORL/LPL4 |
| To: | Dilorenzo M Arizona Public Service Co |
| Orders W, NRR/DORL/LPL4 | |
| References | |
| EPID L-2025-LLA-0069 | |
| Download: ML25188A210 (1) | |
Text
1 From: William Orders To: Michael.Dilorenzo@aps.com
Subject:
Request For Additional Information Re: License Amendment Request to revise the Emergency Plan for the Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR).
Date: July 3, 2025 Mr. Dilorenzo, By letter dated April 8, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25098A330), Arizona Public Service Company (APS, the licensee),
requested U.S. Nuclear Regulatory Commission (NRC) approval of a proposed license amendment request (LAR) to revise the Emergency Plan for the Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes to the PVNGS Emergency Plan would revise the staffing requirement for the Shift Manager/Emergency Coordinator position in the PVNGS Emergency Plan along with staff augmentation times (120 minutes for both normal and off normal timeframes). In order for NRC staff to complete the review of the LAR, the NRC staff requests additional information concerning the issues listed in the attached draft Request for Additional Information (RAI).
Please advise me within 5 business days of this e-mail if you request a clarification call to address the items in the draft RAI. If you choose not to request a clarification call, please provide your response to the RAI within 30 days of this e-mail.
Should APS desire NRC feedback regarding the acceptability of your response, a public meeting will be scheduled to allow the public the ability to participate and ask questions of the staff.
A publicly available version of this communication will be placed in ADAMS, the NRCs official document repository system. Please contact me if you have any questions concerning this request.
William T. Orders Senior Project Manager Plant Licensing Branch 4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-3329 Willam.Orders@nrc.gov
2 DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNIT NOS. 1, 2, AND 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. STN 50-528, 50-529, 50-530, and 72-44 By application dated April 8, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25098A330), Arizona Public Service Company (APS, the licensee),
requested U.S. Nuclear Regulatory Commission (NRC) review and prior approval of a proposed license amendment request (LAR) to revise the Emergency Plan for the Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes to the PVNGS Emergency Plan would revise the staffing requirement for the Shift Manager/Emergency Coordinator position in the PVNGS Emergency Plan along with staff augmentation times (120 minutes for both normal and off normal timeframes).
The following requests for additional information (RAI) is needed for the NRC staff to complete its review.
RAI 1: Command and Control Function - Emergency Coordinator Responsibilities Regulatory Requirement:
Issue Summary:
The proposed Emergency Plan revisions appear to allow the Control Room Supervisor (CRS) to perform initial emergency assessments in the absence of the Shift Manager/Emergency Coordinator (SM/EC). However, the Emergency Coordinator role includes non-delegable responsibilities, such as timely emergency classification and protective action recommendations.
The documentation does not clarify how these non-delegable duties are preserved when the SM/EC is temporarily absent or not immediately available. Specifically, Section 3.1.1 EP [emergency plan] Function: Command-and-Control (formerly Emergency Direction and Control), states in part, allow for the Control Room Supervisor to stand in for the Shift Manager in the event the Shift Manager may be out of the affected unit Control Room. That includes promptly assessing the plant during the initial stages of an emergency.
That functional capability is periodically assessed during Licensed Operations Continuing Training (LOCT) to ensure a timely assessment and declaration of an
3 emergency capability is maintained. [emphasis added]
The PVNGS technical evaluation section 3.1.1, states, The elimination of the two Shift Managers from the available on shift relief and replacing them with a qualified Emergency Coordinator [EC] with a senior reactor operator level of knowledge ensures adequate relief for the Shift Manager/Emergency Coordinator during the augmentation period (120 minutes).
The other qualified Emergency Coordinator may have other collateral duties as long as they are not part of the Technical Specification required positions.
Section 4.2.1.2 Control Room Supervisor of the proposed emergency plan states:
The Control Room Supervisor (CRS) located in the unit control rooms, reports to the EC. The CRS performs initial assessment and evaluation of any abnormal or emergency conditions. In the absence of the Shift Manager/EC, the Control Room Supervisor will perform the initial assessment of the emergency plan and perform any required actions. After the EC declares an emergency, the CRS maintains the normal duties of directing the Nuclear Operators and assisting the EC.
Further, Section 4.2.1.1, Emergency Coordinator (EC), of the proposed PVNGS Emergency Plan states in part, At the onset of an incident, the EC has the following responsibilities:
The information provided by PVNGS appears to delegate the duties of the Emergency Coordinator function which are non-delegable to the Control Room Supervisor. The provided justification and proposed emergency plan changes do not specify what actions will be taken to ensure the emergency coordinator will declare an emergency in a timely manner.
Request:
Please clarify how APS will ensure the Emergency Coordinator retains responsibility for timely emergency classification and declaration, especially in situations where the SM/EC is not present in the control room. Describe procedural or organizational measures that ensure this non-delegable duty is fulfilled.
RAI 2: Use of Shift Technical Advisor in Emergency Coordinator Role Issue Summary:
The LAR states that Shift Technical Advisors (STAs) are trained to the Emergency Coordinator (EC) level. However, the plan does not clarify whether STAs are expected to assume EC responsibilities, nor does it provide an analysis of their ability to do so. This creates ambiguity
4 regarding on-shift command and control function responsibilities. The deletion of EP Table 1 footnote and historical reduction from three to two STAs also raises concerns about the capacity of STAs to support emergency functions without conflicting responsibilities or reduced capability for communicator duties. Specifically, Section 3.1.2 of the PVNGS technical evaluation states, Additional resources to support the following functions remain on-shift at all times:
o Command-and-Control:
Augmented Command-and-Control assistance to the affected Unit Shift Manager in the form of a second qualified Emergency Coordinator. [emphasis added]
Shift Managers, Control Room Supervisors and Shift Technical Advisors are all trained to the Emergency Coordinator position.
In the proposed LAR, the technical justification section 3.1.2 identifies that the Shift Technical Advisors are trained to the Emergency Coordinator position. The information provided by PVNGS appears to allow the duties of the Emergency Coordinator to be performed by the Shift Technical Advisor, however, there is no technical analysis or justification provided in the PVNGS proposed plan that addresses the use of the affected unit Shift Technical Advisor as Emergency Coordinator.
Additionally, the previous March 19, 2004, LAR referenced in section 3.1.2 (ML040860125) approved the reduction in shift technical advisors (STAs) from three to two, based on one STA for the unit in the emergency and one STA for the remaining unaffected units. The deletion of footnote 1 to EP Table 1 removed the provision that an STA can perform the STSC communicator function before augmentation of the on-shift personnel. Based on this footnote, the staff concluded that the EP change to reduce the number of on-shift STAs required from 3 to 2 would in addition further reduce the staff available to perform the on-shift communicator function.
2.a Request:
Does the PVNGS Emergency Plan intend to assign the second qualified Emergency Coordinator responsibilities to the Shift Technical Advisor (STA)? If so, please provide a technical analysis supporting this assignment, demonstrating that it does not conflict with previous NRC safety evaluations (e.g., March 19, 2004, ADAMS Accession No.: ML040860125), particularly regarding STA staffing and communicator responsibilities.
2.b Request:
If APS does not intend to assign second qualified Emergency Coordinator duties to the Shift Technical Advisor or Unit Supervisor, please identify the position(s) that will perform this function and provide sufficient detail to ensure alignment with NRC regulatory expectations for on-shift staffing and non-delegable command functions.
5 RAI 3: Augmentation time from 60 to 120 minutes Regulatory Requirement:
Issue Summary:
The proposed PVNGS Emergency Plan, section 3.1.2 EP Function: Emergency Response Organization Staff Augmentation, references previously approved license amendment requests in its justification for increasing the augmentation time from 60 to 120 minutes, however, the information provided by PVNGS does not provide justification for how the functions currently augmenting within 60 minutes of an Alert or Greater emergency classification are maintained or how relief is provided for those positions assigned as collateral duties shown in Table B-1 of the PVNGS Emergency Plan.
Request:
RAI 3.a:
Please provide objective evidence or analysis that demonstrates how the functions and capabilities, in accordance with NUREG 0654, Revision 2, Table B-1, are maintained from 60 to 120 minutes for the positions designated as collateral duties.
RAI 3.b:
Please provide objective evidence or analysis that demonstrates how the proposed change for the Electrician, Mechanic, and I&C Maintenance Technicians will maintain the capability to provide support for the time period between 60 and 120 minutes for the emergency core cooling system (ECCS) equipment, event mitigation and equipment repair capabilities in accordance with NUREG 0654, revision 2.
RAI 3.c:
In addition, the PVNGS Proposed Emergency Plan Table B-1 states that the on-shift Mechanical, Electrical and I&C Maintenance are Technicians and are collateral duties of Auxiliary Operators. Please provide clarification or objective evidence that demonstrates that the Mechanical, Electrical and I&C Maintenance Auxiliary Operators are qualified Technicians equivalent in qualifications to the Mechanical, Electrical and I&C Maintenance technicians responding within 60 minutes of an Alert or Greater Emergency classification.