ML13246A007

Palo Verde, Units 1, 2 and 3 - First 6-Month Status Report on the PVNGS Overall Integrated Plan

ML13246A007
Person / Time
Site:	Palo Verde
Issue date:	08/28/2013
From:	Mims D C Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, 102-06758/DCM/MAM/TLC
Download: ML13246A007 (9)

Text

T EA-12-049 DWIGHT C. MIMS a ps Senior Vice President, Nuclear Regulatory

& Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 102- 06758- DCM/MAM/TLC Mail Station 7605 Tel 623 393 5403 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: 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. 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

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 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)

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

1) to Arizona Public Service Company (APS). Reference 1 was immediately effective and directs APS to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway -Comanche Peak -Diablo Canyon -Palo Verde.San Onofre°South Texas.Wolf Creek 5/l'\,Zc ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies Page 2 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. On July 18, 2013, APS provided a response to the NRC RAI regarding the PVNGS OIP for mitigation strategies (Reference 4).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. The enclosure to this letter provides the first 6-month status report on the PVNGS OIP for mitigation strategies pursuant to Section IV, Condition C.2, of Reference 1.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,

Enclosure:

APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events DCM//MAM/TLC/hsc cc: E. J. Leeds S. A. Reynolds J. K. Rankin J. P. Reynoso J. A. Kratchman E. E. Bowman NRC Director Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS NRR/JLD/PMB, NRC NRR/DPR/PGCB, NRC ENCLOSURE APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction 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, if any.2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP, and are current as of July 31, 2013.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 I refueling cycle 18. 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." 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 activity status of each item and whether the expected completion date has changed. The provided dates are for planning purposes and subject to change as design and implementation details are developed.

The 6-month status report dates on the table in Attachment 2 of the OIP were inadvertently shown as occurring one month earlier than required.

These report dates have been corrected in this update. 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 procedural requirements during development of modification packages.

Procedural requirements and instructions will be aligned with modifications and staffing analysis.

During and after planned training activities, 1 APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events desktop simulation and plant walk-throughs will be performed for FLEX equipment connections and tie-ins to validate the mitigation strategies.

The revised milestone target completion dates do not impact the order implementation date.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 Not Started Feb 2014 Update 3 Jul 2014 Not Started Aug 2014 Update 4 Jan 2015 Not Started Feb 2015 Update 5 Jul 2015 Not Started Aug 2015 Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Implementation Preparation:

Develop Strategies Feb 2013 Started Dec 2013 Walk-throughs or Demonstrations 2 Aug 2014 Not Started Perform Staffing Analysis May 2014 Not Started Modifications:

Modifications Evaluation Feb 2013 Complete Units 1, 2, and 3 Design May 2014 Started Engineered May_201_Starte Unit 1 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

-Not Started Fall 2014 Installed Storage Facility Complete -Not Started Fall 2015 FLEX Equipment:

Procure On-Site Equipment Dec 2015 Started Regional Response Center (RRC) Nov 2014 Not Started Aug 2014 Operational Install Offsite Delivery Station (if Aug 2014 Not Started Necessary)

Procedures:

PWROG issues NSSS-specific May 2013 Complete guidelines Develop FSGs 3 Nov 20134 Started 2 APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date Create Maintenance Procedures Sep 2014 Started Training: Develop Training Plan Mar 2014 Not Started Implement Training Sep 2014 Not 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 Full Site FLEX Implementation Dec 2015 Not Started Submit Completion Report Apr 2016 Not Started 1The first 6-month update is complete with this submittal.

The milestone schedule dates in Attachment 2 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 pending resolution of a generic concern relating to the approach and limitation of the FLEX capabilities in Modes 5 & 6 (See Section 6, 014 of this enclosure).

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.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 Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.Overall Integrated Plan Open Item Status Complete OIl- A storage location for FLEX equipment needs to Location has been selected for be selected.

FLEX equipment storage facility.

The storage facility will be located true west of the new 3 APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Overall Integrated Plan Open Item Status 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).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 There are no updates. All Loss of All Site AC Guideline during an ELAP. activities are moving toward Additionally, a program and procedural control completion as scheduled and process is under development and will be noted, as applicable, on the implemented to meet the requirement of NEI 12-06 Milestone Schedule Status Table (Reference 4). in Section 3 of this enclosure.

Started 013- Structure, content, and details of the regional Contract agreement is issued and response center (RRC) playbook, and location of the a playbook template with offsite staging area will be determined.

PVNGS-specific information will be used. The Phoenix RRC will be the primary offsite equipment staging location.Started The approach and limitation of the FLEX capabilities in Modes 014- Additional strategies to maintain containment t 6 hasabideties a conditions during Modes 5 and 6 ELAP will be evaluated.

generic concern (Reference 3).The Nuclear Energy Institute (NEI) will be coordinating with the NRC on the schedule for resolution.

Draft Safety Evaluation Open Item' Status None J A Safety Evaluation has not been received from the NRC.7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.4 APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 8 References The following references support the updates to the PVNGS Overall Integrated Plan 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, 2012.2. 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, 2013.3. 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, 2013.4. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 5 APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 9 Figure Location Selected for the FLEX Equipment Storage Facility 6