ML15065A032

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Palo Verde, Units 1, 2, & 3, APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)
ML15065A032
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 02/27/2015
From: Mims D C
Arizona Public Service Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07005-DCM/TNW/PJ H, EA-12-049
Download: ML15065A032 (16)
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EA-12-049DWIGHT C. MIMSSenior Vice President, NuclearRegulatory & Oversight102-07005-DCM/TNW/PJ H Palo VerdeNuclear Generating StationFebruary 27, 2015 P.O. Box 52034Phoenix, AZ 85072U.S. Nuclear Regulatory Commission Mail Station 7605ATTN: Document Control Desk Tel 623 393 540311555 Rockville PikeRockville, MD 20852

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3Docket Nos. STN 50-528, 50-529, and 50-530APS Fourth 6-Month Status Report on the PVNGS OverallIntegrated 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 wasimmediately effective and directed APS to develop, implement, and maintainguidance and strategies to maintain or restore core cooling, containment, and spentfuel 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 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 regardingmitigation strategies. In Reference 3, APS provided the PVNGS OIP.After reviewing the PVNGS OIP for mitigation strategies, the NRC issued a requestfor additional information (RAI) to APS (Reference 4). On July 18, 2013, APSprovided a response to the NRC RAI regarding the PVNGS OIP for mitigationstrategies (Reference 5).Reference 1 also required submission of status reports at 6-month intervals followingsubmittal of the OIP. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)Implementation Guide, Revision 0, provides direction regarding the content of thestatus reports.Reference 6 provided the APS first 6-Month Status Report on the PVNGS OverallIntegrated 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.References 8 and 9 provided the APS second and third 6-Month Status Reports,respectively. Reference 10 provided the APS Notification of Full Compliance with NRCOrders EA-12-049 and EA-12-051 for PVNGS Unit 1.The NRC issued the Interim Staff Evaluation for the PVNGS OIP on November 25,2013 (Reference 7).A member of the STARS (Strategic Teaming and Resource Sharing) AllianceCallaway -Diablo Canyon -Palo Verde -Wolf Creek 102-07005-DCM/TNW/PJHATTN: Document Control DeskU.S. Nuclear Regulatory CommissionAPS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation StrategiesPage 2The enclosure to this letter provides the fourth 6-Month status report on the PVNGSOIP for mitigation strategies.No commitments are being made to the NRC by this letter.Should you need further information regarding this letter, please contact ThomasWeber, Department Leader, Regulatory Affairs, at (623) 393-5764.I declare under penalty of perjury that the foregoing is true and correct.Executed on _/_2_ 26__S_(Date)Sincerely,DCM/TNW/hsc

Enclosure:

APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Planfor Mitigation Strategies for Beyond-Design-Basis External Eventscc: W. M. DeanM. L. DapasB. K. SingalM. M. WatfordC. A. PeabodyJ. BoskaL. M. RegnerNRC Director Office of Nuclear Reactor RegulationNRC Region IV Regional AdministratorNRC NRR Project Manager for PVNGSNRC NRR Project ManagerNRC Senior Resident Inspector PVNGSNRC NRR/MSD Project ManagerNRC NRR/JLD/JPMB Project Manager

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 20122. APS Letter 102-06614, Initial Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (Order Number EA-12-049), dated October 29,2012 102-07005- DCM/TN W/PJ HATTN: Document Control DeskU.S. Nuclear Regulatory CommissionAPS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation StrategiesPage 33. APS Letter 102-06670, APS Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (Order Number EA-12-049), dated February 28,20134. NRC Letter, Palo Verde Nuclear Generating Station, Units 1, 2, and3 -Request for Additional Information Regarding Overall IntegratedPlan in Response to Commission Order EA-12-049 ModifyingLicense with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events, dated June 20, 20135. APS Letter 102-06733, Response to Request for AdditionalInformation for the PVNGS Overall Integrated Plan in Response tothe March 12, 2012 Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), datedJuly 18, 20136. APS Letter 102-06758, APS First 6-Month Status Report on thePVNGS Overall Integrated Plan for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049),dated August 28, 20137. NRC Letter, Palo Verde Nuclear Generating Station, Units 1,2, and3- Interim Staff Evaluation Relating to Overall Integrated Plan inResponse to Order EA-12-049- Mitigation Strategies, datedNovember 25, 20138. APS Letter 102-06840, APS Second 6-Month Status Report on thePVNGS Overall Integrated Plan for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049),dated February 28, 20149. APS Letter 102-06932, APS Third 6-Month Status Report on thePVNGS Overall Integrated Plan for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049),dated August 28, 201410. APS Letter 102-06985, Notification of Full Compliance with NRCOrders EA-12-049 and EA-12-051 for PVNGS Unit 1, dated January9, 2015 ENCLOSUREAPS Fourth 6-Month Status Report on the PVNGS OverallIntegrated Plan for Mitigation Strategies forBeyond-Design-Basis External Events APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Events1 IntroductionArizona Public Service (APS) developed an Overall Integrated Plan (OIP) (Reference 2in Section 8), documenting the diverse and flexible strategies (FLEX), in response toReference 1. This attachment provides an update of milestone accomplishments sincesubmittal of the OIP, including any changes to the compliance method, schedule, or needfor relief or relaxation and the basis for such changes, if any.2 Milestone AccomplishmentsThe following milestone(s) have been completed since the development of the OIP, andare current as of February 10, 2015:Develop Storage Plan: A location for the onsite FLEX Emergency EquipmentStorage Facility (EESF) has been selected (See Open Item 1 [OI1] in Section 6 ofthis enclosure). The EESF will consist of five separate, stand-alone structures thatare seismically designed to American Society of Civil Engineers (ASCE) 7-10,Minimum Design Loads for Buildings and Other Structures. The EESF design iscomplete and construction has started on the seismic concrete storage pads andtie-downs. The initial pad to be used on an interim bases has seismic tie-downsand has been completed. Construction of the EESF to shelter FLEX equipmentfrom the environment will be completed in Fall 2015." Completed implementation and provided notification of Full Compliance withNRC Orders EA-12-049 and EA-12-051 for PVNGS Unit 1 on January 9, 2015(Reference 7).3 Milestone Schedule StatusThe following table provides an update to Attachment 2 of the OIP. This section providesthe status of each activity and changes to target completion dates. The provided dates arefor planning purposes and are subject to change as design and implementation details aredeveloped. Additional changes in target completion dates will be noted in future 6-monthstatus reports.A number of activities have occurred to validate the feasibility of the mitigationstrategies. FLEX strategies were validated using applicable configuration managementprocedure requirements during development of modification packages. Proceduralrequirements and instructions were aligned with modifications and staffing analysis.During and after planned training activities, desktop simulation and plant walk-throughswere performed for FLEX equipment connections and tie-ins to validate the mitigationstrategies. FLEX strategies were validated using the NEI FLEX Validation Process(Section 8, Reference 5).The revised milestone target completion dates do not impact the order implementationdate. The Milestone Schedule Status Table below lists the design status of theI APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Eventsmodifications by project identification number and design modification work order(DMWO) package numbers.RevisedTarget Activity TargetMilestone Completion Status CompletionDate DateSubmit 60 Day Status Report Oct 2012 CompleteSubmit Overall Integrated Plan Feb 2013 CompleteSubmit 6 Month Updates:Update 1 Aug 2013 CompleteUpdate 2 Feb 2014 CompleteUpdate 3 Aug 2014 CompleteUpdate 4 Feb 2015 Complete'Update 5 Aug 2015 Not StartedImplementation Preearation:Develop Strategies Sept 2013 CompleteWalk-throughs or Sept 2014 CompleteDemonstrations2CompletePerform Staffing Analysis May 2014 (Section 8,Reference 6)Modifications:Modifications Evaluation Feb 2013 CompleteUnits 1, 2, and 3 Engineering Sept 2014 CompleteDesign Work (Mod DesignStatus)AF-1626 Steam Generator Mar 2014 CompleteInjection via AuxiliaryFeedwater (AF) System(DMWO 4345882)AF- 1633 Equipment Hatch Feb 2014 CompleteOpening to "A" AF Room forAccess and Ventilation(DMWO 4345887)CH-1624 Reactor Water Tank Dec 2013 CompleteTie-In (DMWO 4345884)CT-1625 Condensate Storage Dec 2013 CompleteTank Tie-In(DMWO 4345885)DG-1634 Fuel Oil Day Tank Aug 2013 CompleteGravity Drain(DMWO 4345888)PB- 1630 Electrical Apr 2014 CompleteConnection to 4160kV and480V (DMWO 4304157)2 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsTarget RevisedTilestone Completion Activity TargetltC e Status CompletionDate DatePB-1648 Electrical Sept 2014 Started3 Dec 2015Connection to 4160kV CalvertBus (DMWO 4491931)PC-1629 Pool Cooling Jan 2014 CompleteElectrical, Spent Fuel PoolRemote Fill, Alternate Gas forGate Seals and DeploymentPads(DMWO 4345883)SI-1627 Reactor Coolant Jan 2014 CompleteSystem Makeup via HighPressure Safety Injection(DMWO 4304156)Unit 1 Implementation Outage Nov 2014 CompleteUnit 2 Implementation Outage Nov 2015 Not StartedUnit 3 Implementation Outage May 2015 Not StartedOnsite Storage:Develop Storage Plan Jul 2013 CompleteTemporary Pads with SeismicTie-downs Installed (For Unit 1 Nov 2014 Completeand N+1 Implementation)EESF Complete Fall 2015 Started Sept 2015Protected Area Pads for FLEXEquipment Deployment InstalledFLEX Equipment:Procure On-Site EquipmentUnit 1 and N+1 Oct 2014 CompleteUnit 2 Oct 2015 StartedUnit 3 April 2015 CompleteBoth of the National StrategicAlliance for FLEX Emergency Sept 2014 CompleteResponse (SAFER) ResponseCenters OperationalSelect Staging Area 'C' -OffsiteStaging Area for Phase III FLEXequipment. It is the area wherethe Phase III portable equipment Sept 2014 Completeis readied for transport to theplant site.3 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsRevisedTarget Activity TargetMilestone Completion Status CompletionDate DateProcedures:PWROG issues NSSS-specific May 2013 Completeguidelines (Modes 1 -4)Develop FSGs4 Sept 2014 CompleteCreate Administrative & Oct 2014 CompleteMaintenance ProceduresTraining:Develop Training Plan Mar 2014 CompleteImplement Training Sep 2014 Complete _Full Implementation:Unit 1 FLEX Implementation Nov 2014 CompleteUnit 2 FLEX Implementation Nov 2015 Not StartedUnit 3 FLEX Implementation May 2015 Not StartedSubmit Full Compliance ReportUnit 1 Jan 2015 CompleteUnit 2 Mar 2016 Not Started Jan 2016Unit 3 Sept 2015 Not Started July 2015Submit Final Integrated Plan Apr 2016 Not Started1 The Fourth 6-Month update is complete with this submittal. The milestone scheduledates in Attachment 2 of the Order required updating as described in Section 3.2 Desktop simulation and plant walk-throughs3 Modification is not required for Phase II or III FLEX Strategy. Equipment is forrecovery phase. Implementation is pending and schedule will be dependent onavailability of materials needed for modification.4 Includes Basis Document and Procedures for all operating Modes5The strategies have been completed for all 3 Units, any differences will be noted infuture 6-Month update.4 Changes to Compliance MethodThere are no changes to the compliance method as documented in the OIP.5 Need for Relief/Relaxation and Basis for the Relief/RelaxationAPS expects to comply with the order implementation date and no relief or relaxation isrequested at this time.4 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Events6 Open Items from Overall Integrated Plan and Interim StaffEvaluationThe following tables provide a summary of the open and confirmatory items documentedin the OIP and the Interim Staff Evaluation (ISE) and the status of each item for the PaloVerde Nuclear Generating Station (PVNGS).Overall Integrated Plan Open ItemsStatusOIl- A storage location for FLEX equipment needs tobe selected.CompleteLocation has been selected forFLEX equipment storage. TheFLEX Emergency EquipmentStorage Facility (EESF) will belocated true west of the newProtected Area (PA) warehouse(outside of the PA but inside theSecurity Owner Controlled Area)and true east of the helicopterpad (See Section 9 Figure 1).Additional details on thelocations of the temporary pad,FLEX EESF, and Helipad areincluded in Figure 2 (See Section9 Figure 2).012- PVNGS FSG is currently a draft document and Completewill need to be finalized. Existing site EOPs will needto be updated to direct use of the PVNGS Extended Activities have been completedLoss of All Site AC Guideline during an ELAP. as scheduled and noted, asAdditionally, a program and procedural control applicable, on the Milestoneprocess is under development and will be Schedule Status Table in Sectionimplemented to meet the requirement of NEI 12-06 3 of this enclosure.(Reference 3).013- Structure, content, and details of the National CompleteSAFER Response Center Phoenix playbook, andlocation of the offsite staging area will be determined. The contract agreement and theResponse Plan template withPVNGS-specific informationhave been issued. The NationalSAFER Response CenterPhoenix has been designated tobe the Staging Area 'C' location.5 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsOverall Integrated Plan Open Items Status014- Additional strategies to maintain containment Completeconditions during Modes 5 and 6 ELAP will beevaluated. The Nuclear Energy Institute(NEI) generic guidance(Reference 4) has beenincorporated in FSGs.Interim Staff Evaluation StatusOpen Items'3.1.1.2.A -Means to move equipment. CompleteIn its Integrated Plan, APS has identified that there is APS response has been provideda 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 for NRC review in the STARSkW 480 V generators in order to recharge batteries. Alliance website e-portal.APS has not identified a means to move thegenerators along with the concomitant method forreasonable protection of that means from theidentified hazards applicable to PVNGS as would berequired 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 CompleteThe licensee was requested to provide RCP seal APS response has been providedleakage testing data applicable to ELAP conditions for NRC review in the STARSfor Palo Verde and show the following: Alliance website e-portal.(a) the calculated maximum RCP seal leakage of 17gpm/seal exceeds the RCP seal leakage rate obtainedfrom the RCP seal testing data, and(b) the assumed maximum seal gap increase of 0.01inches exceeds the seal gap increase obtained fromthe RCP seal testing data. The testing data used tosupport the calculated maximum leakage rate and theassumed maximum increase in the seal gap should beapplicable to Palo Verde seals (with respect to theseal design and material, and seal cooling system),and ELAP conditions (in terms of the maximumtemperature and pressure conditions) for an extendedtesting period consistent with the ELAP coping time.3.2.1.2.B -Operating Conditions CompleteTo determine whether the licensee adequately APS response has been providedaddressed the information discussed in Section 3.2.1.2 for NRC review in the STARS6 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsInterim Staff EvaluationOpen Items'Statusof this evaluation relating to Section 4.4.2 of WCAP-17601, the NRC staff requested the licensee toprovide the following information.(a) Confirm whether an instruction step is available ornot for the operator to maintain the subcooled marginwhich is credited for an ELAP event. If the procedurestep is not available, provide justification.(b) Justify the following statement that was used tosatisfy criterion (b) discussed in Section 3.2.1.2 ofthis evaluation: "... the temperature must reach 460 OFat the inlet of the Fourth stage seal prior to posing apop open concern."Alliance website e-portal.1An Interim Staff Evaluation has been received from the NRC (Reference 4).Interim Staff EvaluationConfirmatory Items'Status3.1.1.4.A -Utilization of offsite resources. APS Actions Complete.APS has provided information regarding its use of the APS is using the Nationaloffsite resources through the industry SAFER SAFER Response Centerprogram, and identified the local staging area, but Phoenix facility as the Stagingneeds to provide details on transportation to the site Area 'C' and the SAFER Teamfollowing a seismic event, will supply the transport vehiclesto move the equipment to thePVNGS site.3.2.2.A -SFP cooling makeup flow rates. CompleteTable A of Reference 18 identifies a performance The value of 110 gpm in Table Acriterion of 110 gpm for the identified SFP makeup of Reference 18 is incorrect. SFPpumps. This flow rate is lower than the identified makeup FLEX pump andminimum flow rate to compensate for boil off due to delivery system is designed tothe design basis heat load and postulated losses due to provide 200 gpm.leakage, which total 131 gpm. The licensee statedthey would change this to provide at least 200 gpm The OIP is Reference 18 of theper pump. Confirm this change. APS response cited in this RAIand was provided to the NRC byReference 2 of this enclosure.7 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsInterim Staff EvaluationConfirmatory ItemsIStatus3.2.3.A -Containment Functions Strategies. CompleteConsistent with the resolution of Open Item APS response has been provided3.2.1.2.A, ensure that the finalized containment for NRC review in the STARSanalysis properly utilizes the correct RCP seal Alliance website e-portal.leakage values and the mass/energy values consistentwith the approved CENTS analysis.3.2.4.2.A -Ventilation of main control room. CompleteIn its Integrated Plan, APS has presented insufficient APS response has been providedinformation for the NRC staff to conclude that the for NRC review in the STARShabitability limits of the control room will be Alliance website e-portal.maintained in all phases of an ELAP.3.2.4.8.A -Portable equipment instrumentation. CompleteIn its Integrated Plan, APS stated that instrumentation APS response has been providedwill be provided for portable equipment operation. for NRC review in the STARSThe NRC staff requested the licensee to describe the Alliance website e-portal.instrumentation that will be used to monitorportable/FLEX electrical power equipment includingtheir associated measurement tolerances/accuracy inorder to support a conclusion that the equipment willbe capable of being operated in a manner to protectinstalled equipment from adverse electricalinteractions in conformance with the guidance of NEI12-06, Section 3.2.2, guideline (13), as endorsed byJLD-ISG-2012-01. The licensee committed to providethis 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 NEIFLEX strategy station battery run-time was calculated position paper entitled EA-12-in accordance with the IEEE- 485 methodology using 049 Mitigating Strategiesmanufacturer discharge test data applicable to the Resolution of Extended Batterylicensee'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 ML13241A186.Cycles Generic Concern," ADAMS Accession No.ML13241A186. The NRC staff will evaluate alicensee's application of the guidance (calculations8 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsInterim Staff Evaluation StatusConfirmatory Items'and supporting data) in its development of the final APS Action Complete.Safety Evaluation documenting compliance withNRC Order EA- 12-049.An Interim Staff Evaluation has been received from the NRC (Reference 4).U1 Full Compliance Letter 102-06985, dated StatusJanuary 09, 2015, pending RAIs:RAI-33-B WorkingDiscuss the analysis (including methods, RAI 33-B was identified as aassumptions, and results) to show that core cooling generic concern or questionwith SG not available can be maintained through once during the NRC public meetingthrough heat removal from the RCS via coolant boil- on April 18, 2013, regarding theoff. NRC order on mitigatingstrategies (Order EA- 12-049).The nuclear industry will resolvethis concern generically throughthe applicable industry groups(e.g., PWROG, EPRI, etc.).Once this concern is resolved,APS will provide an update tothis RAI response in a periodicsix-month update.RAI-34-B WorkingProvide the following items regarding the discussion RAI 34-B was identified as aof core cooling with steam generators not available in generic concern and the nuclearPhases 2 and 3: industry will resolve this concerngenerically through theb. The source of borated coolant once the inventory of applicable industry groups (e.g.,the refueling water tank is depleted (e.g., reactor PWROG, EPRI, etc.). Once thisgrade water, raw water mixed with boric acid). concern is resolved, APS willprovide an update to this RAIresponse in a periodic six-monthupdate.7 Potential Interim Staff Evaluation ImpactsThere are no potential impacts to the Interim Staff Evaluation identified at this time.9 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Events8 ReferencesThe following references support the updates to the PVNGS OIlP described in thisenclosure:1. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard toRequirements 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 Modifying Licenses with Regard to Requirements forMitigation 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 20124. NRC Letter, Palo Verde Nuclear Generating Station, Units 1,2, and 3- Interim StaffEvaluation Relating to Overall Integrated Plan in Response to Order EA-12-049-Mitigation Strategies, dated November 25, 2013 (ML13308C153)5. NEI APC 14-17, FLEX Validation Process, dated July 18, 20146. APS Letter 102-06885, APS Submittal for Fukushima Response NEI 12-01 of Phase2 Staffing Assessment Report, dated June 11, 20147. APS Letter 102-06985, Notification of Full Compliance with NRC Orders EA-12-049 and EA-12-051 for PVNGS Unit 1, dated January 09, 2015 (ML15012A444)10 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Events9 FiguresHelicopter PadLocation of the FLEX EESFFigure 111 APS Fourth 6-Month Status Report on the PVNGS Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External EventsU1 & (N+1) Temporary Equipment Seismic Storage PadINFigure 212
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