ML13246A008

First 6-Month Status Report on the PVNGS 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-12-051)

ML13246A008
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
102-06759-DCM/MAM/TLC, EA-12-051
Download: ML13246A008 (6)

Text

O-EA-12-051 DWIGHT C. MPIMS Regulatory

& Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 102-06759-DCM/MAM/TLC 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-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation, dated March 12, 2012 2. APS Letter 102-06613, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051), dated October 29, 2012 3. APS Letter 102-06669, APS 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-12-051), dated February 28, 2013 4. APS Letter 102-06728, Response to Request for Additional Information for the PVNGS 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-12-051), dated July 11, 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 in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool 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 was immediately effective and directs that PVNGS must have a reliable means of remotely monitoring wide-range spent fuel pool (SFP) levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway-Comanche Peak.Diablo Canyon.Palo Verde-San OnofreSouth Texas.Wolf Creek (Z- /

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for Reliable Spent Fuel Pool Level Instrumentation Page 2 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 reliable SFP level instrumentation.

In Reference 3, APS provided the PVNGS OIP.After reviewing the PVNGS OIP for SFP level instrumentation, the NRC issued a request for additional information (RAI) to APS. On July 11, 2013, APS provided a response to the NRC RAI regarding the PVNGS OIP for SFP level instrumentation (Reference 3).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 with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, 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 SFP level instrumentation 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-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool (SFP) Instrumentation DCM/MAM/TLC/hsc cc: E. J. Leeds NRC Director Office of Nuclear Reactor Regulation S. A. Reynolds NRC Region IV Regional Administrator J. K. Rankin NRC NRR Project Manager J. P. Reynoso NRC Senior Resident Inspector for PVNGS L. M. Regner NRR/JLD/PMB, NRC ENCLOSURE APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool (SFP) Instrumentation APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation 1 Introduction APS developed an Overall Integrated Plan (OIP) (Reference 2 in Section 8), documenting the requirements to install reliable spend fuel pool level instrumentation (SFP LI), in response to Reference

1. This enclosure 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.Engineering and design work for Units 1, 2, and 3 have been started. Design work is ongoing and scheduled for completion in the fourth quarter of 2013 (see the Section 3 Milestone Schedule Status Table).3 Milestone Schedule Status The following provides an update to the milestone schedule in support 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.

Additional changes in target completion dates will be noted in future 6-month status reports.Revised Target Activity Target Milestone Completion 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 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Modifications:

Modifications Evaluation Feb 2013 Complete Units 1, 2, and 3 Engineering and 4Q2013 Started Design Work I I I APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation Receipt of Unit 1 SFP Instruments 2Q2014 Not Started Receipt of Unit 2 SFP Instruments 2Q2015 Not Started Receipt of Unit 3 SFP Instruments 4Q2014 Not Started Unit 1 Implementation Outage Fall 2014 Not Started Unit 2 Implementation Outage Fall 2015 Not Started Unit 3 Implementation Outage Spring 2015 Not Started Procedures:

Create Procedures' Oct 2014 Started Training: Develop Training Plan Apr 2014 Not Started Complete Unit I SFP Instruments 3Q2014 Not Started Procedures

& Training Complete Unit 2 SFP Instruments 3Q2015 Not Started Procedures

& Training Complete Unit 3 SFP Instruments 1Q2015 Not Started Procedures

& Training Unit 1 SFP Instruments Operational Nov 20142 Not Started Unit 2 SFP Instruments Operational Nov 2015 2 Not Started Unit 3 SFP Instruments Operational May 201 52 Not Started Full Site SFP LI Implementation Dec 2015 Not Started Submit Completion Report Apr 2016 Not Started 1Includes maintenance procedures 2 Implementation for Unit I is prior to startup from 1R18 (Fall 2014), Unit 2 is prior to startup from 2R19 (Fall 2015), and Unit 3 is prior to startup from 3R18 (Spring 2015).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.2 APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation Overall Integrated Plan Open Item Status Started 011- Reference 1,Section VII, Arrangement, finalize Probe locations have not been primary and backup system probe locations for all finalized.

Detailed engineering three SFPs. and design work is ongoing with expected completion in 4Q2013.Draft Safety Evaluation Open Item' Status None 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.8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. NRC Order Number EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation, dated March 12, 2012.2. APS Letter 102-06669, APS Overall Integrated Plan in Response to March 12, 2012 Commission Order Modfying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051), dated February 28, 2013.3. APS Letter 102-06728, Response to Request for Additional Information for the PVNGS 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-12-051), dated July 11, 2013.4. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 3