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

TEA-12-049 DWIGHT C. MIMSa ps Senior Vice President, NuclearRegulatory

& Oversight Palo VerdeNuclear Generating StationP.O. Box 52034Phoenix, AZ 85072102- 06758- DCM/MAM/TLC Mail Station 7605Tel 623 393 5403August 28, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

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 29,20123. 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-Basis External Events (Order Number EA-12-049),

dated February 28,20134. APS Letter 102-06733, Response to Request for Additional Information 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, 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 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 directs APS to develop, implement, and maintain guidanceand strategies to maintain or restore core cooling, containment, and spent fuel poolA member of the STARS (Strategic Teaming and Resource Sharing)

AllianceCallaway

-Comanche Peak -Diablo Canyon -Palo Verde.San Onofre°South Texas.Wolf Creek 5/l'\,Zc ATTN: Document Control DeskU.S. Nuclear Regulatory Commission APS First 6-Month Status Report on the PVNGS Overall Integrated Plan for Mitigation Strategies Page 2cooling capabilities in the event of a beyond-design-basis external event. Specificrequirements 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 regarding mitigation 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. On July 18, 2013, APS provided a responseto 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 ofthe status reports.

The enclosure to this letter provides the first 6-month statusreport 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 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-12-049, Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External EventsDCM//MAM/TLC/hsc cc: E. J. LeedsS. A. ReynoldsJ. K. RankinJ. P. ReynosoJ. A. Kratchman E. E. BowmanNRC Director Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project ManagerNRC Senior Resident Inspector for PVNGSNRR/JLD/PMB, NRCNRR/DPR/PGCB, NRC ENCLOSURE APS First 6-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses withRegard to Requirements for Mitigation Strategies forBeyond-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 Events1 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 OverallIntegrated Plan, including any changes to the compliance method, schedule, or need forrelief 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.Develop Storage Plan: A location for the onsite FLEX equipment storage facilityhas been selected (See Open Item 1 [OI1] in Section 6 of this enclosure).

Thestorage facility will be a single, stand-alone structure and seismically designed toAmerican Society of Civil Engineers (ASCE) 7-10, Minimum Design Loads forBuildings and Other Structures.

Contracts have been issued for buildingconstruction and storage facility design engineering is ongoing.

The seismicbasemat and tie-downs for FLEX equipment (N+1) will be completed in Fall2014 at the completion of Unit I refueling cycle 18. The storage facility to shelterFLEX equipment from the environment will be completed in Fall 2015. Refer tothe Milestone Schedule Status Table in Section 3 of this enclosure for significant milestones.

" Pressurized Water Reactor Owners Group (PWROG) issued Nuclear SteamSupply System (NSSS)-specific guidelines:

The PWROG-approved Combustion Engineering (CE) NSSS generic FLEX Support Guidelines (FSGs) weretransmitted to APS for implementation on May 17, 2013.3 Milestone Schedule StatusThe following table provides an update to Attachment 2 of the OIP. This sectionprovides the activity status of each item and whether the expected completion date haschanged.

The provided dates are for planning purposes and subject to change as designand implementation details are developed.

The 6-month status report dates on the tablein Attachment 2 of the OIP were inadvertently shown as occurring one month earlier thanrequired.

These report dates have been corrected in this update. Additional changes intarget 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 withmodifications 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 Eventsdesktop simulation and plant walk-throughs will be performed for FLEXequipment connections and tie-ins to validate the mitigation strategies.

The revised milestone target completion dates do not impact the order implementation date.Target RevisedMilestone Completion Activity TargetM tC e Status Completion Date DateSubmit 60 Day Status Report Oct 2012 CompleteSubmit Overall Integrated Plan Feb 2013 CompleteSubmit 6 Month Updates:Update 1 Jul 2013 Complete Aug 2013'Update 2 Jan 2014 Not Started Feb 2014Update 3 Jul 2014 Not Started Aug 2014Update 4 Jan 2015 Not Started Feb 2015Update 5 Jul 2015 Not Started Aug 2015Update 6 Feb 2016 Not StartedUpdate 7 Aug 2016 Not StartedImplementation Preparation:

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

Modifications Evaluation Feb 2013 CompleteUnits 1, 2, and 3 Design May 2014 StartedEngineered May_201_Starte Unit 1 Implementation Outage Fall 2014 Not StartedUnit 2 Implementation Outage Fall 2015 Not StartedUnit 3 Implementation Outage Spring 2015 Not StartedOnsite Storage:Develop Storage Plan Jul 2013 CompleteSeismic Basemat and Tie-downs

-Not Started Fall 2014Installed Storage Facility Complete

-Not Started Fall 2015FLEX Equipment:

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

Procedures:

PWROG issues NSSS-specific May 2013 Completeguidelines Develop FSGs3Nov 20134 Started2 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 EventsTarget RevisedMilestone Completion Activity TargetM tC e Status Completion Date DateCreate Maintenance Procedures Sep 2014 StartedTraining:

Develop Training Plan Mar 2014 Not StartedImplement Training Sep 2014 Not StartedFull Implementation:

Unit 1 FLEX Implementation Nov 2014 Not StartedUnit 2 FLEX Implementation Nov 2015 Not StartedUnit 3 FLEX Implementation May 2015 Not StartedFull Site FLEX Implementation Dec 2015 Not StartedSubmit Completion Report Apr 2016 Not Started1The first 6-month update is complete with this submittal.

The milestone schedule datesin 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 theapproach and limitation of the FLEX capabilities in Modes 5 & 6 (See Section 6, 014 ofthis enclosure).

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.Overall Integrated Plan Open Item StatusCompleteOIl- A storage location for FLEX equipment needs to Location has been selected forbe selected.

FLEX equipment storagefacility.

The storage facility willbe located true west of the new3 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 EventsOverall Integrated Plan Open Item StatusProtected Area (PA) warehouse (outside of the PA but inside theSecurity Owner Controlled Area)and true east of the helicopter pad (See Section 9 Figure).012- PVNGS FSG is currently a draft document and Startedwill need to be finalized.

Existing site EOPs will needto be updated to direct use of the PVNGS Extended There are no updates.

AllLoss of All Site AC Guideline during an ELAP. activities are moving towardAdditionally, a program and procedural control completion as scheduled andprocess is under development and will be noted, as applicable, on theimplemented to meet the requirement of NEI 12-06 Milestone Schedule Status Table(Reference 4). in Section 3 of this enclosure.

Started013- Structure,

content, and details of the regional Contract agreement is issued andresponse center (RRC) playbook, and location of the a playbook template withoffsite staging area will be determined.

PVNGS-specific information will be used. The Phoenix RRCwill be the primary offsiteequipment staging location.

StartedThe approach and limitation ofthe FLEX capabilities in Modes014- Additional strategies to maintain containment t 6 hasabideties aconditions during Modes 5 and 6 ELAP will beevaluated.

generic concern (Reference 3).The Nuclear Energy Institute (NEI) will be coordinating withthe NRC on the schedule forresolution.

Draft Safety Evaluation Open Item' StatusNone JA 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.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 Events8 References The following references support the updates to the PVNGS Overall Integrated Plandescribed in this enclosure:

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, 2012.2. 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, 2013.3. APS Letter 102-06733, Response to Request for Additional Information for thePVNGS 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 July18, 2013.4. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 20125 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 Events9 FigureLocation Selected for the FLEX Equipment Storage Facility6