ML14246A210

Palo Verde, Units 1, 2, and 3, Third 6-Month Status Report on the Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-05

ML14246A210
Person / Time
Site:	Palo Verde
Issue date:	08/28/2014
From:	Mims D C Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06933-DCM/MAM/PJH, EA-12-051
Download: ML14246A210 (13)

Text

EA-12-051 DWIGHT C. MIMSSenior Vice President, NuclearRegulatory

& Oversight Palo VerdeNuclear Generating Station102-06933-DCM/MAM/PJH P.O. Box 52034August 28, 2014 Phoenix, AZ 85072Mail Station 7605Tel 623 393 5403U.S. Nuclear Regulatory Commission ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3Docket Nos. STN 50-528, 50-529, and 50-530APS Third 6-Month Status Report on the PVNGS OverallIntegrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool Level Instrumentation (Order Number EA-12-051)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference

1) to Arizona Public Service Company (APS). Reference 1 wasimmediately effective and directed that PVNGS must have a reliable means ofremotely monitoring wide-range spent fuel pool (SFP) levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 ofReference 1.Reference 1 required submission of an initial status report 60 days following issuanceof the final interim staff guidance and an overall integrated plan (OIP) pursuant toSection IV, Condition C. Reference 2 provided the APS initial status report regarding reliable SFP level instrumentation.

In Reference 3, APS provided the PVNGS OIP.After reviewing the PVNGS OIP for SFP Level Instrumentation, the NRC issued arequest for additional information RA T) to APS (Reference 4). On July 11, 2013, APSprovided a response to the NRC RAI regarding the PVNGS OIP for SFP LevelInstrumentation (Reference 5).Reference 1 also requires submission of a status report at 6-month intervals following submittal of the OIP. NEI 12-02, Industry Guidance for Compliance withNRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel PoolInstrumentation, Revision 1, provides direction regarding the content of the statusreports.Reference 6 provided the APS First 6-Month status report on the PVNGS OIP for SFPLevel Instrumentation pursuant to Section IV, Condition C.2, of Reference 1.Reference 8 provided the APS Second 6-Month status report.A member of the STARS (Strategic Teaming and Resource Sharing)

AllianceCallaway

-Comanche Peek -Diablo Canyon -Palo Verde -Wolf Creek 102-06933-DCM/MAM/PJH ATTN: Document Control DeskU.S. Nuclear Regulatory Commission APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Page 2The NRC issued the Interim Staff Evaluation and RAI on the PVNGS OIP on October29, 2013 (Reference 7).The enciosure to this letter provides the Third 6-Month status report on the PVNGSOIP for SFP level instrumentation.

No commitments are being made to the NRC by this letter.Should you have any questions concerning the content of this letter, please contactMark McGhee, Department Leader, Regulatory

Affairs, at (623) 393-4972.

I declare under penalty of perjury that the foregoing is true and correct.Executed on(Date)Sincerely, DCM/MAM/PJH/hsc

Enclosure:

APS Third 6-Month Status Report on the Overall Integrated Plan for SpentFuel Pool Level Instrumentation cc: W. M. DeanM. L. DapasB. K. SingalM. M. WatfordM. A. BrownL. M. RegnerNRC Director Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager for PVNGSNRC NRR Project ManagerNRC Senior Resident Inspector PVNGSNRC NRR/JLD/JPMB Project Manager

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses withRegard to Reliable Spent Fuel Pool Level Instrumentation, datedMarch 12, 20122. APS Letter 102-06613, Initial Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051),

dated October 29, 2012 102-06933-DCM/MAM/PJH ATTN: Document Control DeskU.S. Nuclear Regulatory Commission APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Page 33. APS Letter 102-06669, APS Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regardto Reliable Spent Fuel Pool Level Instrumentation (Order NumberEA-12-051),

dated February 28, 20134. NRC letter, Palo Verde Nuclear Generating

Station, Units 1, 2, and3 -Request for Additional Information Regarding Overail integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel PoolInstrumentation,"

dated June 10, 20135. APS Letter 102-06728, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regardto Reliable Spent Fuel Pool Level Instrumentation (Order NumberEA-12-051),

dated July 11, 20136. APS Letter 102-06759, APS First 6-Month Status Report on thePVNGS Overall Integrated Plan in Response to March 12, 2012Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Level Instrumentation (Order Number EA-12-051),

dated August 28, 20137. NRC Letter, Interim Staff Evaluation and Request for Additional information Regarding Order EA-12-051 Reliable Spent Fuel PoolInstrumentation, dated October 29, 20138. APS Letter 102-06841, APS Second 6-Month Status Report on thePVNGS Overall Integrated Plan in Response to March 12, 2012Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Level Instrumentation (Order Number EA-12-051),

dated February 28, 2014 ENCLOSURE APS Third 6-Month Status Report on the Overall Integrated Planfor Spent Fuel Pool Level Instrumentation APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation 1 Introduction Arizona Public Service (APS) developed an Overall Integrated Plan (OIP) (Reference 2in Section 8), documenting the requirements to install reliable spent fuel pool levelinstrumentation (SFP LI), in response to Reference

1. This enclosure provides an updateof milestone accomplishments since submittal of the OIP, including any changes to thecompliance method, schedule, or need for relief or relaxation and the basis for suchchanges, if any.2 Milestone Accomplishments The following milestone(s) have been completed since the development of the 01P, andare current as of August 10, 2014:Engineering and design work for Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 has been completed.

Installation work is ongoing and scheduled for completion in October 2014 for Unit 1 (see the Section 3 Milestone ScheduleStatus Table for Units 2 & 3).3 Milestone Schedule StatusThe following table provides an update to the milestone schedule in support ofimplementation of the OIP. This section provides the activity status of each item andwhether the expected completion date has changed.

The provided dates are for planningpurposes and subject to change as design and implementation details are developed.

Additional changes in. target completion dates will be noted in future 6-month statusreports.The Milestone Schedule Status Table below lists the design status of the modifications byproject identification number and design modification work order (DMWO) packagenumbers.g t RevisedM s Target Activity TargetMilestone DCompletion Status Completion Date DateSubmit 60 Day Status Report Oct 2012 CompletiSubmit Overall Integrated Plan Feb 2013 CompleteSubmit 6 Month Updates:

_Update 1 Aug 2013 Complete Aug 2013Update 2 Feb 2014 Complete Feb 2014Update 3 Aug 2014 Complete Aug 2014'Update 4 Feb 2015 Not StartedUpdate 5 Aug 2015 Not StartedUpdate 6 Feb 2016 Not StartedUpdate 7 Aug 2016 Not Started1 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Target RevisedTilestone Completion Activity TargetM tC e Status Completion Date DateModifications:

Modifications Evaluation Feb 2013 CompleteUnits 1, 2, and 3 Engineering and 4Q2013 Complete 2Q2014Design Work1. PC-1631 Spent Fuel PoolRemote Level Instrumentation Apr 2014 Complete(DMWO 4304155)2. PC-1639 Spent Fuel PoolRemote Pool Level Electrical Apr 2014 CompletePower (DMWO 4345889)Receipt of Unit 1 SFP Instruments 2Q2014 CompleteReceipt of Unit 2 SFP Instruments 2Q2015 Not Started 4Q2014Receipt of Unit 3 SFP Instruments 4Q2014 Not Started 4Q2014Unit 1 Implementation Online Fall 2014 StartedUnit 2 Implementation Online Fall 2015 Not StartedUnit 3 Implementation Online Spring 2015 Not StartedProcedures:

Create Procedures 2 Oct 2014 StartedTraining:

Develop Training Plan Apr 2014 CompleteIssue Unit 1 SFP Instruments Procedures

& Complete Training 3Q2014 Started Nov 2014Issue Unit 2 SFP Instruments Procedures

& Complete Training 3Q2015 Not StartedIssue Unit 3 SFP Instruments Procedures

& Complete Training 1Q2015 Not StartedUnit 1 SFP Instruments Operational Nov 20143 StartedUnit 2 SFP Instruments Operational Nov 2015" Not StartedUnit 3 SFP Instruments Operational May 20153 Not StartedFull Site SFP LI Implementation Dec 2015 Not StartedSubmit Completion Report Apr 2016 Not StartedThe Third 6-Month update is complete with this submittal.

The milestone schedule datesin Attachment 2 of the Order required updating as described in Section 3.2 Includes maintenance procedures 3 Implementation for Unit 1 is prior to startup from 1R18 (Fall 2014), Unit 2 is prior tostartup from 2R19 (Fall 2015), and Unit 3 is prior to startup from 3R18 (Spring 2015).4 Changes to Compliance MethodThere are no changes to the compliance method as documented in the OIP.2 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation APS expects to comply with the order implementation date and no relief or relaxation isrequested at this time.6 Open Items from Overall Integrated Plan and Interim StaffEvaluation The following tables provide a summary of the open items documented in the OIP andthe Interim Staff Evaluation (ISE) and the status of each item.Overall Intelrated Plan Open Item StatusOil- Reference 1,Section VII, Arrangement, finalize Completeprimary and backup system probe locations for allthree SFPs. Probe locations have beenfinalized.

Final locations areselected based on guidanceprovided in Reference 3.Detailed engineering and designwork is documented in DMWOL_ 4304155.Interim Staff Evaluation Requests for Additional StatusInformation (RAIs)lRAI #1 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) A description of how the other structures in the Alliance website e-portal.

vicinity of the SFPs (cask loading pit, transfer canalsand gates) shown in Figure 2, "Spent Fuel PoolGeometry and Dimensions" are connected to theSFPs.b) If additional structures, other than the SFPs in eachunit, are used for fuel storage, describe in detail theirusage, operation, and provide justifications for notinstalling separate level instrumentation in otherstructures used for fuel storage.RAI #2 CompletePlease provide your plant-specific performance APS response has been providedevaluation result and a brief summary of the proposed for NRC review in the STARSwireless technology that will be used in the primary Alliance website e-portal.

and backup measurement systems to address the3 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional StatusInformation (RAIs)Scriteria summarized in Section 3.1 of NEI 12-02.RAI #3 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) The final locations/placement of the primary and Alliance website e-portal.

back-up SFP level sensor.b) Additional information describing how theproposed arrangement of the sensor probe assemblyand routing of the cabling between the sensor probeassembly and the electronics in the Auxiliary Building meets the Order requirement to arrange theSFP level instrument channels in a manner thatprovides reasonable protection of the level indication function against missiles that may result from damageto the structure over the SFP.RAI #4 CompletePlease provide the analyses verifying that the seismic APS response has been providedtesting of the sensor probe assembly and the for NRC review in the STARSelectronics units, and the licensee's analysis of the Alliance website e-portal.

combined maximum seismic and hydrodynamic forces on the sensor probe assembly exposed to thepotential sloshing

effects, show that the SFPinstrument design configuration will be maintained during and following the maximum seismic groundmotion considered in the design of the SFP structure.

RAI #5 CompleteFor each of the mounting attachments required to APS response has been providedattach SFP Level equipment to plant structures, for NRC review in the STARSplease describe the design inputs, and the Alliance website e-portal.

methodology that was used to qualify the structural integrity of the affected structures/equipment.

RAI #6 CompletePlease provide analysis of the maximum expected APS response has been providedradiological conditions (dose rate and total integrated for NRC review in the STARSdose) to which the equipment located within the Alliance website e-portal.

control building or AB will be exposed.

Also, please4 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional StatusInformation (RAIs)1 Statusprovide documentation indicating the radiological dosage amount that the electronics for this equipment is capable of withstanding.

Please discuss the timeperiod over which the analyzed total integrated dosewas applied.RAI #7 CompletePlease provide information indicating a) the APS response has been providedtemperature ratings for all system electronics for NRC review in the STARS(including sensor electronics, system electronics, Alliance website e-portal.

transmitter, receiver and display) and whether theratings are continuous duty ratings; and, b) what willbe the maximum expected temperature and relativehumidity conditions in the room(s) in which thesensor electronics will be located under BDBconditions in which there will be no ac poweravailable to run Heating Ventilation and AirConditioning (HVAC) systems.RAI #8 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) information describing the evaluation of the sensor Alliance website e-portal.

electronics design, the shock test method, test results,and forces applied to the sensor electronics applicable to its successful tests demonstrating that the testingprovides an appropriate means to demonstrate reliability of the sensor electronics under the effectsof severe shock.b) information describing the evaluation of the sensorelectronics design, the vibration test method, testresults, the forces and their frequency ranges anddirections applied to the sensor applicable to itssuccessful tests, demonstrating that the testingprovides an appropriate means to demonstrate reliability of the sensor electronics under the effectsof high vibration.

RAI #9 CompletePlease provide analysis of the seismic testing results APS response has been providedand show that the instrument performance reliability, for NRC review in the STARSfollowing exposure to simulated seismic conditions Alliance website e-portal.

representative of the environment anticipated for the5 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional StatusInformation (RAIs)1SFP structures at Palo Verde, has been adequately demonstrated.

Include information describing thedesign inputs and methodology used in any analysesof the mountings of electronic equipment onto plantstructures, as requested in RAI #5 above.RAI #10 CompletePlease provide the NRC staff with the final APS response has been providedconfiguration of the power supply source for each for NRC review in the STARSchannel so that the staff may conclude that the two Alliance website e-portal.

channels are independent from a power supplyassignment perspective.

RAI #11 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) A description of the electrical ac power sources Alliance website e-portal.

and capabilities for the primary and backup channels.

b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient tomaintain the level indication function until offsiteresource availability is reasonably assured.RAI #12 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) An estimate of the expected instrument channel Alliance website e-portal.

accuracy performance under both (a) normal SFPlevel conditions (approximately Level 1 or higher)and (b) at the BDB conditions (i.e., radiation, temperature,

humidity, post-seismic and post-shock conditions) that would be present if the SFP levelwere at the Level 2 and Level 3 datum points.b) A description of the methodology that will be usedfor determining the maximum allowed deviation fromthe instrument channel design accuracy that will beemployed under normal operating conditions as anacceptance criterion for a calibration procedure to6 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional StatusInformation (RAIs)1flag to operators and to technicians that the channelrequires adjustment to within the normal condition design accuracy.

RAI #13CompletePlease provide the following:

a) A description of the capability and provisions theproposed level sensing equipment will have to enableperiodic testing and calibration, including how thiscapability enables the equipment to be tested in-situ.b) A description of how such testing and calibration will enable the conduct of regular channel checks ofeach independent channel against the other, andagainst any other permanently-installed SFP levelinstrumentation.

c) A description of how functional checks will beperformed, and the frequency at which they will beconducted.

Describe how calibration tests will beperformed, and the frequency at which they will beconducted.

Provide a discussion as to how thesesurveillances will be incorporated into the plantsurveillance program.d) A description of what preventive maintenance tasks are required to be performed during normaloperation, and the planned maximum surveillance interval that is necessary to ensure that the channelsare fully conditioned to accurately and reliablyperform their functions when needed.APS response has been providedfor NRC review in the STARSAlliance website e-portal.

RAI #14 CompletcFor the SFP level instrumentation back up display APS response has been providedplease describe the evaluation used to validate that for NRC review in the STARSthe display location can be accessed without Alliance website e-portal.

unreasonable delay following a BDB event. Includethe time available for personnel to access the displayas credited in the evaluation, as well as the actualtime (e.g., based on walk-throughs) that it will takefor personnel to access the display.

Additionally, 7

APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Information (RAIs)'Statusplease include a description of the radiological andenviromnental conditions on the paths personnel might take. Describe whether the display locationremains habitable for radiological, heat and humidity, and other environmental conditions following a BDBevent. Describe whether personnel are continuously stationed at the display or monitor the displayperiodically.

RAI #15 CompletePlease provide a list of the procedures addressing APS response has been providedoperation (both normal and abnormal response),

for NRC review in the STARScalibration, test, maintenance, and inspection Alliance website e-portal.

procedures that will be developed for use of the spentSFP instrumentation.

The licensee is requested toinclude a brief description of the specific technical objectives to be achieved within each procedure.

RAI #16 CompletePlease provide the following:

APS response has been providedfor NRC review in the STARSa) Further information describing the maintenance Alliance website e-portal.

and testing program the licensee will establish andimplement to ensure that regular testing andcalibration is performed and verified by inspection and audit to demonstrate conformance with designand system readiness requirements.

Include adescription of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the levelmeasurement system and its supporting equipment.

b) A description of the in-situ calibration process atthe SFP location that will result in the channelcalibration being maintained at its design accuracy.

An Interim Staff Evaluation with RAIs has been received from the NRC (Reference 4).7 Potential Interim Staff Evaluation ImpactsThere are no potential impacts to the Interim Staff Evaluation identified at this time.8 APS Third 6-Month Status Report on the Overall Integrated Plan forSpent Fuel Pool Level Instrumentation 8 References The following references support the updates to the Overall Integrated Plan described inthis enclosure

1. NRC Order Number EA- 12-051, Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Level Instrumentation, dated March 12, 2012 (ML12054A679)

2. APS Letter 102-06669, APS Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool Level Instrumentation (Order Number EA-12-051),

dated February 28, 2013(ML13070A077)

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 20124. NRC Letter, Interim Staff Evaluation and Request for Additional Information Regarding Order EA-12-051 Reliable Spent Fuel Pool Instrumentation, datedOctober 29, 2013 (ML13296A006) 9