ML14246A210

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-12-051)

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. MIMS Senior Vice President, Nuclear Regulatory

& Oversight Palo Verde Nuclear Generating Station 102-06933-DCM/MAM/PJH P.O. Box 52034 August 28, 2014 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 5403 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 APS Third 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 directed 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-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 RA T) to APS (Reference 4). On July 11, 2013, APS provided a response to the NRC RAI regarding the PVNGS OIP for SFP Level Instrumentation (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 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.Reference 6 provided the APS First 6-Month status report on the PVNGS OIP for SFP Level 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) Alliance Callaway -Comanche Peek -Diablo Canyon -Palo Verde -Wolf Creek 102-06933-DCM/MAM/PJH ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Page 2 The NRC issued the Interim Staff Evaluation and RAI on the PVNGS OIP on October 29, 2013 (Reference 7).The enciosure to this letter provides the Third 6-Month status report on the PVNGS OIP 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 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, DCM/MAM/PJH/hsc

Enclosure:

APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation cc: W. M. Dean M. L. Dapas B. K. Singal M. M. Watford M. A. Brown L. M. Regner NRC Director Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager for PVNGS NRC NRR Project Manager NRC Senior Resident Inspector PVNGS NRC NRR/JLD/JPMB Project Manager

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 102-06933-DCM/MAM/PJH ATTN: Document Control Desk U.S. Nuclear Regulatory Commission APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Page 3 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. NRC letter, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 -Request for Additional Information Regarding Overail integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation," dated June 10, 2013 5. 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 6. APS Letter 102-06759, 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), dated August 28, 2013 7. NRC Letter, Interim Staff Evaluation and Request for Additional information Regarding Order EA-12-051 Reliable Spent Fuel Pool Instrumentation, dated October 29, 2013 8. APS Letter 102-06841, APS Second 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), dated February 28, 2014 ENCLOSURE APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation 1 Introduction Arizona Public Service (APS) developed an Overall Integrated Plan (OIP) (Reference 2 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI), in response to Reference

1. This enclosure provides an update of milestone accomplishments since submittal of the OIP, 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 01P, and are 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 Schedule Status Table for Units 2 & 3).3 Milestone Schedule Status The following table provides an update to the milestone schedule in support of implementation 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.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.g t Revised M s Target Activity Target Milestone DCompletion Status Completion Date Date Submit 60 Day Status Report Oct 2012 Completi Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates: _Update 1 Aug 2013 Complete Aug 2013 Update 2 Feb 2014 Complete Feb 2014 Update 3 Aug 2014 Complete Aug 2014'Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started 1 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Target Revised Tilestone Completion Activity Target M tC e Status Completion Date Date Modifications:

Modifications Evaluation Feb 2013 Complete Units 1, 2, and 3 Engineering and 4Q2013 Complete 2Q2014 Design Work 1. PC-1631 Spent Fuel Pool Remote Level Instrumentation Apr 2014 Complete (DMWO 4304155)2. PC-1639 Spent Fuel Pool Remote Pool Level Electrical Apr 2014 Complete Power (DMWO 4345889)Receipt of Unit 1 SFP Instruments 2Q2014 Complete Receipt of Unit 2 SFP Instruments 2Q2015 Not Started 4Q2014 Receipt of Unit 3 SFP Instruments 4Q2014 Not Started 4Q2014 Unit 1 Implementation Online Fall 2014 Started Unit 2 Implementation Online Fall 2015 Not Started Unit 3 Implementation Online Spring 2015 Not Started Procedures:

Create Procedures 2 Oct 2014 Started Training: Develop Training Plan Apr 2014 Complete Issue Unit 1 SFP Instruments Procedures

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

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

& Complete Training 1Q2015 Not Started Unit 1 SFP Instruments Operational Nov 20143 Started Unit 2 SFP Instruments Operational Nov 2015" Not Started Unit 3 SFP Instruments Operational May 20153 Not Started Full Site SFP LI Implementation Dec 2015 Not Started Submit Completion Report Apr 2016 Not Started The Third 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 Includes maintenance procedures 3 Implementation for Unit 1 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 OIP.2 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent 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 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 items documented in the OIP and the Interim Staff Evaluation (ISE) and the status of each item.Overall Intelrated Plan Open Item Status Oil- Reference 1,Section VII, Arrangement, finalize Complete primary and backup system probe locations for all three SFPs. Probe locations have been finalized.

Final locations are selected based on guidance provided in Reference 3.Detailed engineering and design work is documented in DMWO L_ 4304155.Interim Staff Evaluation Requests for Additional Status Information (RAIs)l RAI #1 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) A description of how the other structures in the Alliance website e-portal.vicinity of the SFPs (cask loading pit, transfer canals and gates) shown in Figure 2, "Spent Fuel Pool Geometry and Dimensions" are connected to the SFPs.b) If additional structures, other than the SFPs in each unit, are used for fuel storage, describe in detail their usage, operation, and provide justifications for not installing separate level instrumentation in other structures used for fuel storage.RAI #2 Complete Please provide your plant-specific performance APS response has been provided evaluation result and a brief summary of the proposed for NRC review in the STARS wireless technology that will be used in the primary Alliance website e-portal.and backup measurement systems to address the 3 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Status Information (RAIs)S criteria summarized in Section 3.1 of NEI 12-02.RAI #3 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) The final locations/placement of the primary and Alliance website e-portal.back-up SFP level sensor.b) Additional information describing how the proposed arrangement of the sensor probe assembly and routing of the cabling between the sensor probe assembly and the electronics in the Auxiliary Building meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.RAI #4 Complete Please provide the analyses verifying that the seismic APS response has been provided testing of the sensor probe assembly and the for NRC review in the STARS electronics 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 the potential sloshing effects, show that the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure.

RAI #5 Complete For each of the mounting attachments required to APS response has been provided attach SFP Level equipment to plant structures, for NRC review in the STARS please 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 Complete Please provide analysis of the maximum expected APS response has been provided radiological conditions (dose rate and total integrated for NRC review in the STARS dose) to which the equipment located within the Alliance website e-portal.control building or AB will be exposed. Also, please 4 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Status Information (RAIs)1 Status provide documentation indicating the radiological dosage amount that the electronics for this equipment is capable of withstanding.

Please discuss the time period over which the analyzed total integrated dose was applied.RAI #7 Complete Please provide information indicating a) the APS response has been provided temperature 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 the ratings are continuous duty ratings; and, b) what will be the maximum expected temperature and relative humidity conditions in the room(s) in which the sensor electronics will be located under BDB conditions in which there will be no ac power available to run Heating Ventilation and Air Conditioning (HVAC) systems.RAI #8 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) 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 testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of severe shock.b) information describing the evaluation of the sensor electronics design, the vibration test method, test results, the forces and their frequency ranges and directions applied to the sensor applicable to its successful tests, demonstrating that the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of high vibration.

RAI #9 Complete Please provide analysis of the seismic testing results APS response has been provided and show that the instrument performance reliability, for NRC review in the STARS following exposure to simulated seismic conditions Alliance website e-portal.representative of the environment anticipated for the 5 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Status Information (RAIs)1 SFP structures at Palo Verde, has been adequately demonstrated.

Include information describing the design inputs and methodology used in any analyses of the mountings of electronic equipment onto plant structures, as requested in RAI #5 above.RAI #10 Complete Please provide the NRC staff with the final APS response has been provided configuration of the power supply source for each for NRC review in the STARS channel so that the staff may conclude that the two Alliance website e-portal.channels are independent from a power supply assignment perspective.

RAI #11 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) 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 to maintain the level indication function until offsite resource availability is reasonably assured.RAI #12 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) An estimate of the expected instrument channel Alliance website e-portal.accuracy performance under both (a) normal SFP level 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 level were at the Level 2 and Level 3 datum points.b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to 6 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Status Information (RAIs)1 flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.RAI #13 Complete Please provide the following:

a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability 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 of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

c) A description of how functional checks will be performed, and the frequency at which they will be conducted.

Describe how calibration tests will be performed, and the frequency at which they will be conducted.

Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.APS response has been provided for NRC review in the STARS Alliance website e-portal.RAI #14 Completc For the SFP level instrumentation back up display APS response has been provided please describe the evaluation used to validate that for NRC review in the STARS the display location can be accessed without Alliance website e-portal.unreasonable delay following a BDB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. Additionally, 7 APS Third 6-Month Status Report on the Overall Integrated Plan for Spent Fuel Pool Level Instrumentation Interim Staff Evaluation Requests for Additional Information (RAIs)'Status please include a description of the radiological and enviromnental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BDB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

RAI #15 Complete Please provide a list of the procedures addressing APS response has been provided operation (both normal and abnormal response), for NRC review in the STARS calibration, test, maintenance, and inspection Alliance website e-portal.procedures that will be developed for use of the spent SFP instrumentation.

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

RAI #16 Complete Please provide the following:

APS response has been provided for NRC review in the STARS a) Further information describing the maintenance Alliance website e-portal.and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

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

b) A description of the in-situ calibration process at the SFP location that will result in the channel calibration 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 Impacts There 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 for Spent Fuel Pool Level Instrumentation 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 (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 Fuel Pool 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, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 4. NRC Letter, Interim Staff Evaluation and Request for Additional Information Regarding Order EA-12-051 Reliable Spent Fuel Pool Instrumentation, dated October 29, 2013 (ML13296A006) 9