ML13246A008

Palo Verde, Units 1, 2 and 3 - 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

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. MPIMSRegulatory

& Oversight Palo VerdeNuclear Generating StationP.O. Box 52034Phoenix, AZ 85072Mail Station 7605102-06759-DCM/MAM/TLC Tel 623 393 5403August 28, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses withRegard to Reliable Spent Fuel Pool Level Instrumentation, datedMarch 12, 20122. APS Letter 102-06613, Initial Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051),

dated October 29, 20123. APS Letter 102-06669, APS Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regardto Reliable Spent Fuel Pool Level Instrumentation (Order NumberEA-12-051),

dated February 28, 20134. APS Letter 102-06728, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regardto Reliable Spent Fuel Pool Level Instrumentation (Order NumberEA-12-051),

dated July 11, 2013

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3Docket Nos. STN 50-528, 50-529, and 50-530APS First 6-Month Status Report on the PVNGS OverallIntegrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool 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 wasimmediately effective and directs that PVNGS must have a reliable means ofremotely 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)

AllianceCallaway-Comanche Peak.Diablo Canyon.Palo Verde-San OnofreSouth Texas.Wolf Creek(Z- /

ATTN: Document Control DeskU.S. Nuclear Regulatory Commission APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for ReliableSpent Fuel Pool Level Instrumentation Page 2design-basis external event. Specific requirements are outlined in Attachment 2 ofReference 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 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 arequest for additional information (RAI) to APS. On July 11, 2013, APS provided aresponse 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 withNRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel PoolInstrumentation,"

Revision 1, provides direction regarding the content of the statusreports.

The enclosure to this letter provides the first 6-month status report on thePVNGS OIP for SFP level instrumentation pursuant to Section IV, Condition C.2, ofReference 1.No commitments are being made to the NRC by this letter.Should you have any questions concerning the content of this letter, please contactMark 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 ReliableSpent 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 ManagerJ. P. Reynoso NRC Senior Resident Inspector for PVNGSL. M. Regner NRR/JLD/PMB, NRC ENCLOSURE APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses withRegard 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 forReliable 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), inresponse to Reference

1. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes tothe 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, andare current as of July 31, 2013.Engineering and design work for Units 1, 2, and 3 have been started.

Design workis ongoing and scheduled for completion in the fourth quarter of 2013 (see theSection 3 Milestone Schedule Status Table).3 Milestone Schedule StatusThe following provides an update to the milestone schedule in support of the OIP. Thissection 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 asdesign and implementation details are developed.

Additional changes in targetcompletion dates will be noted in future 6-month status reports.RevisedTarget Activity TargetMilestone Completion Status Completion Date 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 Not StartedUpdate 3 Aug 2014 Not StartedUpdate 4 Feb 2015 Not StartedUpdate 5 Aug 2015 Not StartedUpdate 6 Feb 2016 Not StartedUpdate 7 Aug 2016 Not StartedModifications:

Modifications Evaluation Feb 2013 CompleteUnits 1, 2, and 3 Engineering and 4Q2013 StartedDesign Work I II APS First 6-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements forReliable SFP Instrumentation Receipt of Unit 1 SFP Instruments 2Q2014 Not StartedReceipt of Unit 2 SFP Instruments 2Q2015 Not StartedReceipt of Unit 3 SFP Instruments 4Q2014 Not StartedUnit 1 Implementation Outage Fall 2014 Not StartedUnit 2 Implementation Outage Fall 2015 Not StartedUnit 3 Implementation Outage Spring 2015 Not StartedProcedures:

Create Procedures' Oct 2014 StartedTraining:

Develop Training Plan Apr 2014 Not StartedComplete Unit I SFP Instruments 3Q2014 Not StartedProcedures

& TrainingComplete Unit 2 SFP Instruments 3Q2015 Not StartedProcedures

& TrainingComplete Unit 3 SFP Instruments 1Q2015 Not StartedProcedures

& TrainingUnit 1 SFP Instruments Operational Nov 20142 Not StartedUnit 2 SFP Instruments Operational Nov 2015 2 Not StartedUnit 3 SFP Instruments Operational May 201 52 Not StartedFull Site SFP LI Implementation Dec 2015 Not StartedSubmit Completion Report Apr 2016 Not Started1Includes maintenance procedures 2Implementation 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 MethodThere 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 isrequested at this time.6 Open Items from Overall Integrated Plan and Draft SafetyEvaluation The following tables provide a summary of the open items documented in the OverallIntegrated 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 forReliable SFP Instrumentation Overall Integrated Plan Open Item StatusStarted011- Reference 1,Section VII, Arrangement, finalize Probe locations have not beenprimary and backup system probe locations for all finalized.

Detailed engineering three SFPs. and design work is ongoing withexpected completion in 4Q2013.Draft Safety Evaluation Open Item' StatusNoneA Safety Evaluation has not been received from the NRC.7 Potential Draft Safety Evaluation ImpactsThere 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 inthis enclosure.

1. NRC Order Number EA- 12-051, Order Modifying Licenses with Regard to ReliableSpent 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 FuelPool Level Instrumentation (Order Number EA-12-051),

dated February 28, 2013.3. APS Letter 102-06728, Response to Request for Additional Information for thePVNGS Overall Integrated Plan in Response to March 12, 2012 Commission OrderModifying 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, "ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 20123