ML14066A036

Palo Verde, Units 1, 2 and 3, Second 6-Month Status Report on Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14066A036
Person / Time
Site:	Palo Verde
Issue date:	02/28/2014
From:	Mims D C Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06840-DCM/MAM, EA-12-049
Download: ML14066A036 (14)

Text

EA-12-049 ,aps 102-06840-DCM/MAM February 28, 2014 DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory

& Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 5403 U.S. Nuclear Regulatory Commission ATrN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 2. APS Letter 102-06614, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012 3. APS Letter 102-06670, APS Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 4. NRC to APS Letter, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 -Request for Additional Information Regarding Overall Integrated Plan in Response to Commission Order EA-12-049 Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated June 20, 2013 5. APS Letter 102-06733, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated July 18, 2013 6. APS Letter 102-06758, APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

1) to Arizona Public Service Company (APS). Reference 1 was A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek 102-06840-DCM/MAM ATrN: Document Control Desk U.S. Nuclear Regulatory Commission APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies Page 2 immediately effective and directed APS to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance and an overall integrated plan (OIP) pursuant to Section IV, Condition C. Reference 2 provided the APS initial status report regarding mitigation strategies.

In Reference 3, APS provided the PVNGS OIP.After reviewing the PVNGS OIP for mitigation strategies, the NRC issued a request for additional information (RAI) to APS (Reference 4). On July 18, 2013, APS provided a response to the NRC RAI regarding the PVNGS OIP for mitigation strategies (Reference 5).Reference 1 also requires submission of a status report at 6-month intervals following submittal of the OIP. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, provides direction regarding the content of the status reports.Reference 6 provided the APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) pursuant to Section IV, Condition C.2, of Reference 1.The enclosure to this letter provides the Second 6-Month status report on the PVNGS OIP for mitigation strategies.

No commitments are being made to the NRC by this letter.Should you have any questions concerning the content of this letter, please contact Mark 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, X.4C DCM/MAM/hsc 102-06840-DCM/MAM ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies Page 3

Enclosure:

APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events cc: E. J. Leeds M. L. Dapas J. K. Rankin A. E. George M. A. Brown J. Boska L. M. Regner NRC Director Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager NRC NRR Project Manager NRC Senior Resident Inspector PVNGS NRC NRR/MSD Project Manager NRC NRR/JLD/JPMB Project Manager ENCLOSURE APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Arizona Public Service (APS) developed an Overall Integrated Plan (OIP) (Reference 2 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference

1. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief or relaxation and the basis for such changes, if any.2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP, and are current as of February 20, 2014: Develop Storage Plan: A location for the onsite FLEX equipment storage facility has been selected (See Open Item 1 [OI1] in Section 6 of this enclosure).

The storage facility will be a single, stand-alone structure and seismically designed to American Society of Civil Engineers (ASCE) 7-10, Minimum Design Loads for Buildings and Other Structures.

Contracts have been issued for building construction and storage facility design engineering is ongoing. The seismic basemat and tie-downs for FLEX equipment (N+ 1) will be completed in Fall 2014 at the completion of Unit 1 refueling cycle 18. Construction of the storage facility to shelter FLEX equipment from the environment will be completed in Fall 2015. Refer to the Milestone Schedule Status Table in Section 3 of this enclosure for significant milestones.

• The Pressurized Water Reactor Owners Group (PWROG) issued Nuclear Steam Supply System (NSSS)-specific guidelines:

The PWROG-approved Combustion Engineering (CE) NSSS generic FLEX Support Guidelines (FSGs) were transmitted to APS for implementation on May 17, 2013.3 Milestone Schedule Status The following table provides an update to Attachment 2 of the OIP. This section provides the status of each activity and changes to target completion dates. The provided dates are for planning purposes and are subject to change as design and implementation details are developed.

Additional changes in target completion dates will be noted in future 6-month status reports.Validation

-Walk-throughs or Demonstration(s):

Phases 2 and 3 connection points will be validated using applicable configuration management procedure requirements during development of modification packages.Procedural requirements and instructions will be aligned with modifications and staffing analysis.

During and after planned training activities, desktop simulation and plant walk-throughs will be performed for FLEX equipment connections and tie-ins to validate the mitigation strategies.

I APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events The revised milestone target completion dates do not impact the order implementation date. The Milestone Schedule Status Table below lists the design status of the modifications by project identification number and design modification work order (DMWO) package numbers.Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates: Update 1 Jul 2013 Complete Aug 2013 Update 2 Jan 2014 Complete Feb 20141 Update 3 Jul 2014 Not Started Aug 2014 Update 4 Jan 2015 Not Started Feb 2015 Update 5 Jul 2015 Not Started Aug 2015 Implementation Preparation:

Develop Strategies Feb 2013 Started April 2014 Walk-throughs or Aug 2014 Not Started Demonstrations2 Perform Staffing Analysis May 2014 Started Modifications:

Modifications Evaluation Feb 2013 Complete Units 1, 2, and 3 Engineering Design Work (Mod Design May 2014 Started Status)AF-1626 Steam Generator March 2014 Started Injection via Auxiliary Feedwater (AF) System (DMWO 4345882)AF-1633 Equipment Hatch Feb 2014 Complete Opening to "A" AF Room for Access and Ventilation (DMWO 4345887)CH- 1624 Reactor Water Tank Dec 2013 Complete Tie-In (DMWO 4345884)CT- 1625 Condensate Storage Dec 2013 Complete Tank Tie-In (DMWO 4345885)DG- 1634 Fuel Oil Day Tank Aug 2013 Complete Gravity Drain (DMWO 4345888)PB-1630 Electrical April 2014 Started Connection to 4160kV and 480V (DMWO 4304157)I 2 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date PB- 1648 Electrical May 2014 Started Connection to 4160kV Calvert Bus (DMWO 4491931)PC-1629 Pool Cooling Jan 2014 Complete Electrical, Spent Fuel Pool Remote Fill, and Alternate Gas for Gate Seals (DMWO 4345883)SI- 1627 Reactor Coolant Jan 2014 Complete System Makeup via High Pressure Safety Injection (DMWO 4304156)Unit I Implementation Outage Fall 2014 Not Started Unit 2 Implementation Outage Fall 2015 Not Started Unit 3 Implementation Outage Spring 2015 Not Started Onsite Storage: Develop Storage Plan Jul 2013 Complete Seismic Basemat and Tie-downs Fall 2014 Started Installed Storage Facility Complete Fall 2015 Not Started FLEX Equipment:

Procure On-Site Equipment Dec 2015 Started Unit 1 and N+I Started Fall 2014 Unit 2 Started Fall 2015 Unit 3 Started Spring 2015 Regional Response Center (RRC) Nov 2014 Started Sept 2014 Operational No_21_SateSp

_2 _Install Offsite Delivery Station (if Aug 2014 Started Necessary)

Procedures:

PWROG issues NSSS-specific May 2013 Complete guidelines May_20____omplete Develop FSGs 3 Nov 2013 Started May 2014 4 Create Maintenance Procedures Sep 2014 Started Training: Develop Training Plan Mar 2014 Started Implement Training Sep 2014 Started Full Implementation:

Unit 1 FLEX Implementation Nov 2014 Not Started Unit 2 FLEX Implementation Nov 2015 Not Started Unit 3 FLEX Implementation May 2015 Not Started 3 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date Full Site FLEX Implementation Dec 2015 Not Started Submit Completion Report Apr 2016 Not Started 1 The Second 6-Month update is complete with this submittal.

The milestone schedule dates in Attachment 2 of the Order required updating as described in Section 3.2 Desktop simulation and plant walk-throughs 3 Includes Basis Document and Procedures 4 Shutdown mode FSGs are addressed consistent with the resolution of the generic concern documented in Reference 4 (See Section 6, 014 of this enclosure).

4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP.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 is requested at this time.6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open and confirmatory items documented in the OIP and the Interim Staff Evaluation (ISE) and the status of each item for the Palo Verde Nuclear Generating Station (PVNGS).Overall Integrated Plan Open Items Status OIl -A storage location for FLEX equipment needs to Complete be selected.Location has been selected for FLEX equipment storage facility.

The storage facility will be located true west of the new Protected Area (PA) warehouse (outside of the PA but inside the Security Owner Controlled Area)and true east of the helicopter pad (See Section 9 Figure).4 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Overall Integrated Plan Open Items Status 012- PVNGS FSG is currently a draft document and Started will need to be finalized.

Existing site EOPs will need to be updated to direct use of the PVNGS Extended All activities are moving toward Loss of All Site AC Guideline during an ELAP. completion as scheduled and Additionally, a program and procedural control noted, as applicable, on the process is under development and will be Milestone Schedule Status Table implemented to meet the requirement of NEI 12-06 in Section 3 of this enclosure.(Reference 3).013- Structure, content, and details of the regional Started response center (RRC) playbook, and location of the offsite staging area will be determined.

Contract agreement is issued and a Response Plan template with PVNGS-specific information will be used. The Phoenix RRC will be the primary offsite equipment staging location.Complete 014- Additional strategies to maintain containment The Nuclear Energy Institute conditions during Modes 5 and 6 ELAP will be (NEI) generic guidance evaluated.(Reference

4) will be incorporated in FSG's.Interim Staff Evaluation Status Open Items'3.1.1 .2.A -Means to move equipment.

Evaluation in progress.In its Integrated Plan, APS has identified that there is a time constraint of 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> to install portable 500 kW 480 V generators in order to recharge batteries.

APS has not identified a means to move the generators along with the concomitant method for reasonable protection of that means from the identified hazards applicable to PVNGS as would be required to conform to the guidance of NEI 12-06, Section 5.3.2, consideration 5 and Section 9.3.2.3.2.1.2.A

-RCP Seal Leakage Rate Evaluation in progress.The licensee was requested to provide RCP seal leakage testing data applicable to ELAP conditions for Palo Verde and show the following:

5 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Interim Staff Evaluation Open ItemsI Status (a) the calculated maximum RCP seal leakage of 17 gpm/seal exceeds the RCP seal leakage rate obtained from the RCP seal testing data, and (b) the assumed maximum seal gap increase of 0.01 inches exceeds the seal gap increase obtained from the RCP seal testing data. The testing data used to support the calculated maximum leakage rate and the assumed maximum increase in the seal gap should be applicable to Palo Verde seals (with respect to the seal design and material, and seal cooling system), and ELAP conditions (in terms of the maximum temperature and pressure conditions) for an extended testing period consistent with the ELAP coping time.3.2.1.2.B

-Operating Conditions Evaluation in progress.To determine whether the licensee adequately addressed the information discussed in Section 3.2.1.2 of this evaluation relating to Section 4.4.2 of WCAP- 17601, the NRC staff requested the licensee to provide the following information.(a) Confirm whether an instruction step is available or not for the operator to maintain the subcooled margin which is credited for an ELAP event. If the procedure step is not available, provide justification.(b) Justify the following statement that was used to satisfy criterion (b) discussed in Section 3.2.1.2 of this evaluation:

"... the temperature must reach 460 OF at the inlet of the third stage seal prior to posing a pop open concern." An Interim Staff Evaluation has been received from the NRC (Reference 5).Interim Staff Evaluation Status Confirmatory Items'3.1.1.4.A

-Utilization of offsite resources.

APS Actions Complete.APS has provided information regarding its use of the APS will use the Phoenix offsite resources through the industry SAFER Arizona Regional Response program, and identified the local staging area, but Center (RRC) facility as the needs to provide details on transportation to the site local (offsite) staging area and 6 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Interim Staff Evaluation Confirmatory Items' Status following a seismic event. the SAFER Team will supply the transport vehicles to move the RRC equipment to the PVNGS site.3.2.2.A -SFP cooling makeup flow rates. Complete Table A of Reference 18 identifies a performance The value of 110 gpm in Table A criterion of 110 gpm for the identified SFP makeup of Reference 18 is incorrect.

SFP pumps. This flow rate is lower than the identified makeup FLEX pump and minimum flow rate to compensate for boil off due to delivery system is designed to the design basis heat load and postulated losses due to provide 200 gpm.leakage, which total 131 gpm. The licensee stated they would change this to provide at least 200 gpm The OIP is Reference 18 of the per pump. Confirm this change. APS response cited in this RAI and was provided to the NRC by Reference 2 of this enclosure.

3.2.3.A -Containment Functions Strategies.

Evaluation in progress.Consistent with the resolution of Open Item 3.2.1.2.A, ensure that the finalized containment analysis properly utilizes the correct RCP seal leakage values and the mass/energy values consistent with the approved CENTS analysis.3.2.4.2.A

-Ventilation of main control room. Evaluation in progress.In its Integrated Plan, APS has presented insufficient information for the NRC staff to conclude that the habitability limits of the control room will be maintained in all phases of an ELAP.3.2.4.8.A

-Portable equipment instrumentation.

Evaluation in progress.In its Integrated Plan, APS stated that instrumentation will be provided for portable equipment operation.

The NRC staff requested the licensee to describe the instrumentation that will be used to monitor portable/FLEX electrical power equipment including their associated measurement tolerances/accuracy in order to support a conclusion that the equipment will be capable of being operated in a manner to protect installed equipment from adverse electrical interactions in conformance with the guidance of NEI 7 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events Interim Staff Evaluation Confirmatory ItemsI Status 12-06, Section 3.2.2, guideline (13), as endorsed by JLD-ISG-2012-01.

The licensee committed to provide this in a future update.3.2.4.10.A

-Battery Duty Cycle. APS Action Complete.During the audit process, the licensee stated that the APS has implemented NEI FLEX strategy station battery run-time was calculated position paper entitled EA-12-in accordance with the IEEE- 485 methodology using 049 Mitigating Strategies manufacturer discharge test data applicable to the Resolution of Extended Battery licensee's FLEX strategy as outlined in the NEI Duty Cycles Generic Concern, position paper entitled "EA-12-049 Mitigating ADAMS Accession No.Strategies Resolution of Extended Battery Duty ML 13241A 186.Cycles Generic Concern," ADAMS Accession No.ML 13241A 186. The NRC staff will evaluate a licensee's application of the guidance (calculations and supporting data) in its development of the final Safety Evaluation documenting compliance with NRC Order EA- 12-049.'An Interim Staff Evaluation has been received from the NRC (Reference 5).7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.8 References The following references support the updates to the PVNGS OIP described in this enclosure:

1. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

2. APS Letter 102-06670, APS Overall Integrated Plan in Response to March 12, 2012 Commission Order Modeifyng Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (ML13136A022)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 4. NEI APC 13-27, NRC Endorsement of Flex Generic Open Item for Shutdown/Refueling Modes, including Attachment 1, entitled, Position Paper: Shutdown / Refueling Modes, and Attachment 2, NRC letter dated September 30, 8 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events 2013 (ML 13267A3 82), which documents that the position paper provides an acceptable approach, dated October 2, 2013 5. NRC Letter, Palo Verde Nuclear Generating Station, Units 1, 2, and 3- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049-Mitigation Strategies (TAC NOS. MF0829, MF0830, MF0831.), dated November 25, 2013 (ML13308C153) 9 APS Second 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events 9 Figure Helicopter Pad Location Selected for the FLEX Equipment Storage Facility 10