ML16258A031

PVNGS Units 1-3 - Notif of NRC Insp of the Implementation of Mitigation Strategies and Spent Fuel Pool Instr. Orders and Emer. Prep. Comm./Staffing/Multi-Unit Dose Assessment Plns(05000528/ 2016009;05000529/2016009;and 05000530/2016009) and

ML16258A031
Person / Time
Site:	Palo Verde
Issue date:	09/14/2016
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Edington R Arizona Public Service Co
Alexander R
References
EA-12-049, EA-12-051 IR 2016009
Download: ML16258A031 (9)

See also: IR 05000529/2016009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

September 14, 2016

Randall K. Edington

Executive Vice President, Nuclear/CNO

Palo Verde Nuclear Generating Station

P.O. Box 52034, MS 7602

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

NOTIFICATION OF NRC INSPECTION OF THE IMPLEMENTATION OF

MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION

ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/

STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS (05000528/2016009;

05000529/2016009; AND 05000530/2016009) AND REQUEST FOR

INFORMATION

Dear Mr. Edington:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

staff will conduct a mitigation strategies for beyond-design-basis external events, spent fuel pool

instrumentation, and emergency preparedness enhancements inspection at the Palo Verde

Nuclear Generating Station from November 14 - 18, 2016. The inspection will consist of two

reactor inspectors from the NRCs Region IV office, one inspector from the NRC Region III

office, plus one of the assigned Resident Inspectors at Palo Verde for one week. The

inspection will be conducted in accordance with the NRCs Temporary Instruction 2515/191,

Inspection of the Implementation of Mitigating Strategies and Spent Fuel Pool Instrumentation

Orders, and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment

Plans.

Experience has shown that this inspection is resource intensive both for the NRC inspectors

and licensee staff. In order to minimize the impact to your onsite resources and to ensure a

productive inspection, we have enclosed a request for documents needed for this inspection

activity. Please note that the documents are requested to be provided by November 1, 2016.

During the onsite inspection, inspectors will verify that plans for complying with NRC Orders

EA-12-049 and EA-12-051 are in place and are being implemented. Inspectors will also verify

the establishment of staffing and communications plans provided in response to the March 12,

2012, request for information letter, and multi-unit dose assessment information provided per

COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for

Japan Lessons Learned, dated March 27, 2013. These plans and information were provided in

the site specific submittals, which were subsequently reviewed by the NRC staff for

understanding and documented in the NRCs plant safety evaluations (SEs) and safety

assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX

strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should

be available to support the inspectors at the site during the inspection.

R. Edington -2-

We have discussed the schedule for this inspection activity with your staff and understand that

our regulatory contact for this inspection will be Sean Dornseif of your licensing organization. If

there are any questions about this inspection or the material requested, please contact the lead

inspector, Ryan D. Alexander, by telephone at (817) 200-1195 or by e-mail at

ryan.alexander@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, control

number 3150 0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Geoffrey Miller, Chief

Project Branch D

Division of Reactor Projects

Docket Nos: 50-528, 50-529, 50-530

License Nos: NPF-41, NPF-51, NPF-74

Enclosure:

FLEX Strategies, Spent Fuel Pool

Instrumentation, & EP Enhancements

Inspection Request for Information

Request for Information

FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection

Palo Verde Nuclear Generating Station

Inspection Report: 05000528/2016-009

05000529/2016-009

05000530/2016-009

Inspection Dates: November 14 - 18, 2016

Inspection Procedure: Temporary Instruction 2515/191, Inspection of the

Implementation of Mitigating Strategies and Spent Fuel Pool

Instrumentation Orders, and Emergency Preparedness

Communication/Staffing/Multi-Unit Dose Assessment Plans

Inspectors: Ryan D. Alexander, Team Lead, Sr. Project Engineer, Region IV

Dustin Reinert, Ph.D., PVNGS Resident Inspector

Eddie Uribe, Reactor Inspector, Region IV

Bruce Bartlett, Project Engineer, Region III

Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or electronic

format (use of the Certrec IMS information portal is preferred), to the attention of Ryan

Alexander, by November 1, 2015. [If electronic/CD format is preferred by PVNGS, additional

copies may need to be sent to the home office of supporting inspectors.] The inspectors will

select specific items from the information requested below and then request from your staff

additional documents needed during the onsite inspection week. Also, we request that you

categorize the documents in your response with the numbered list below. Please provide

requested documentation electronically if possible. If requested documents are large and only

hard copy formats are available, please inform the lead inspector, and provide subject

documentation during the first day of the onsite inspection. If you have any questions regarding

this information request, please call the lead inspector as soon as possible.

TI 2515/191 - Appendix A

1. Provide current revision of the FLEX Final Integrated Plan, including any revisions since

December 2015 submission to the NRC

2. Provide the FLEX Strategy Basis Document

3. Provide each operating, off-normal, abnormal, and/or emergency procedures where entry

into the FLEX Support Guideline(s) are initiated

4. Provide a list of key pieces of equipment that directly perform a FLEX mitigation strategy for

core cooling (RCS and Steam Generators), containment, and/or spent fuel pool cooling.

5. Provide a list and copies of every FLEX Support Guideline (FSG) or equivalent procedure

which you developed or revised to implement your mitigating strategies. Provide copies of

the FSGs/procedures which address (as applicable):

-1- Enclosure

a. Restoration of AC power to essential loads (with or without alternate AC power

source(s))

b. DC Load shedding

c. Primary (RCS) loss and makeup, including water source(s)

d. Secondary/steam generator makeup, including water source(s)

e. Containment isolation and safe shutdown valve operations while AC power is

unavailable

f. Monitoring and makeup options to the Spent Fuel Pool

g. Portable lighting (e.g., flashlights or headlamps) necessary for ingress and egress to

plant areas required for deployment of FLEX strategies

h. Communications systems necessary for ingress and egress to plant areas required for

deployment of FLEX strategies

i. Achieving area access during a loss of AC power, including the Protected Area and

internal locked areas where remote equipment operation is necessary

j. Mitigating the effects of a loss of forced ventilation/cooling

k. Access and pathways to locations where operators will be required to perform local

manual operations

l. Equipment failure does not occur as a result of loss of heat tracing during ELAP

m. Replenishment of fuel to diesel/gas powered equipment (e.g., FLEX diesel generators,

pumps, etc.)

n. Implementation of portable systems (such as portable power supplies & portable pumps)

o. Deployment routes and locations for FLEX portable equipment

p. Containment venting (and/or analysis to demonstrate that containment venting is not

required)

q. Actions to maintain the FLEX equipment necessary to support shutdown risk

processes/procedures (i.e., FLEX strategies in Modes 5 and 6)

r. How FLEX equipment could be deployed or pre-deployed/pre-staged to support

maintaining or restoring key safety functions in the event of a loss of shutdown cooling

6. Applicable site specific hazards for PVNGS

a. Seismic

i. Provide documents which show the locations and configuration of structures which

store FLEX equipment.

ii. Provide the evaluation/evidence to support that FLEX equipment is stored in

location(s) such that each location:

1. Meets the plants design basis Safe Shutdown Earthquake, OR

2. Meets the design requirements as described in ASCE 7-10, Minimum Design

Loads for Buildings and Other Structures, OR

3. Is outside a structure and evaluated for seismic interactions to ensure equipment

is not damaged by non-seismically robust components or structures.

-2- Enclosure

iii. Provide documentation that explains how large portable FLEX equipment such as

pumps and power supplies are secured to protect them during a seismic event (i.e.,

Safe Shutdown Earthquake (SSE) level).

iv. Provide documents which show that stored equipment and structures are protected

from seismic interactions to ensure that unsecured and/or non-seismic components

do not damage the equipment.

v. Provide the travel route(s) for FLEX equipment from storage location(s) to their

location(s) of use, AND evaluation(s) which demonstrate that for the potential for soil

liquefaction is not of a concern for these travel route(s).

vi. Seismic concerns for water source(s)

1. If the FLEX water sources are seismically robust, then provide the assessment

that shows that they are.

2. If the FLEX water sources are not seismically robust, then provide:

a. an assessment of alternate water sources, and

b. the procedure(s) which describe when and how to access those sources.

vii. If power is required to move or deploy FLEX equipment, then describe and identify

the locations of the power supplies which provide that power, and provide the

procedures which describe implementing those power supplies.

viii. If equipment is needed to move the FLEX equipment, provide documents that show

how that equipment is protected from the seismic event.

ix. Provide documents which show that the FLEX equipment connection points to

permanently installed plant system are seismically qualified to the same extent as

the permanently installed equipment.

x. Provide documents which show that staged tools used to connect FLEX equipment

are acceptable/compatible with the connections used.

b. Extreme high temperatures

For each key piece of equipment described in #4 (above) that directly performs or

implements a FLEX mitigation strategy:

1. Provide the document which describes the high-temperature limit of the range within

which the equipment will function.

2. Describe how the equipment is maintained below that limit in its storage location.

7. Provide the station-specific FLEX strategies time validation study(ies)

8. Relative to the testing and maintenance program for FLEX equipment, for each key piece of

equipment described in #4 (above) that directly performs or implements a FLEX mitigation

strategy:

a. Identify the equipment and provide documents that describe either how you tested the

equipment (including electrical cables) or how you used other means to verify that the

equipment can perform its required function.

b. If the equipment is portable, then provide documents that describe how maintain and

test the equipment in accordance with INPO AP-913 or an acceptable alternative.

-3- Enclosure

9. Provide documents which describe the programmatic controls in place to ensure that if

equipment and applicable connections are unavailable (e.g., due to maintenance), then

compensatory measures are implemented in accordance with guidance outlined NEI 12-06.

10. Identify the procedure(s) provided in response to #4 above which address:

i. early notification to mobilize the offsite response,

ii. establishment of a point of delivery for the off-site equipment,

iii. arrangements for delivery and deployment at the site, and

iv. sufficient supplies of commodities to support the equipment and site personnel

a. Provide documents which describe your evaluation of what equipment and commodities

are needed to sustain and backup the sites coping strategies.

b. Provide documents which show that you have established means to ensure that fuel for

FLEX equipment can be delivered to the site if onsite fuel is unusable or depleted.

c. Provide documents which describe the process by which you will revise the required

supplied equipment due to changes in the FLEX strategies or plant equipment or

equipment obsolescence.

11. Provide documents which show that your installed standard mechanical and electrical

connections are compatible with Phase 3 equipment.

a. Provide the station-specific National SAFER Center Playbook

12. Relative to personnel training on FLEX strategies, provide:

a. FLEX training bases document(s)

b. Lesson plans for site emergency response leaders responsible for the implementation of

FLEX strategies. (Records for staff completing this training may be requested to be

provided to the inspectors during the onsite inspection week.)

c. Lesson plans for site personnel responsible for the execution of mitigating strategies for

BDBEEs (i.e., operators, craft personnel, security, radiation protection, etc.) to ensure

familiarity and considering available job aids, instructions, and mitigating strategy time

constraints.

13. Provide the procedure(s) which describe your configuration control program; AND provide

lists that identify by number, name, and revision number the documents, drawings,

sketches, calculations, analyses, procedures/guidance and evaluations related to your

mitigation strategies.

14. Listing of corrective action program document summaries generated related to FLEX

equipment, strategies, procedures, and/or training.

TI 2515/191 - Appendix B

15. Provide the procedures you approved for maintenance, testing, calibration, and use of the

primary and backup Spent Fuel Pool (SFP) instrumentation channels.

16. Provide documents which describe the training program that addresses the use,

maintenance, calibration, surveillance, and the use of alternate power to the primary and

backup SFP instrument channels. Specifically provide training materials used in that

program.

-4- Enclosure

TI 2515/191 - Appendix C

17. Communications:

a. Provide documents which show that the communications system(s), technologies,

equipment and power supplies would be available from the beginning of the event and

operate during an ELAP.

b. Provide documents which show that you have completed appropriate maintenance and

testing program activities to verify off-site response organizations communication

systems operate as designed.

c. Provide the procedures and/or guidance used to implement the communication

capabilities.

d. Provide documents which show that you have added any new communications

equipment, portable power supplies and/or systems have been added to ongoing testing

and preventative maintenance programs.

18. Staffing:

a. Provide documents which show that onsite and augmented staff will be available to

implement the strategies in response to a large scale natural event that results an ELAP

and impedes access to the site, and that functions/tasks have been appropriately

staffed.

b. Provide documents which show that the site access methods (e.g., roadways, navigable

bodies of water and dockage, airlift, etc.) expected to be available following the event

and available to the Emergency Response Organization (ERO) [as described in your

Phase 1 and 2 staffing assessments and NRC safety assessment].

c. Provide documents which show the testing, training, and drills/exercises performed by

you to demonstrate the EROs ability to utilize the communications systems and/or

equipment.

19. Provide documents which show that your multi-unit dose assessment is capable of

analyzing concurrent radiological releases from all on-site significant sources (including

releases from spent fuel pools) during an ELAP.

Lead Inspector Contact Information:

Ryan D. Alexander, Sr. Project Engineer Mailing Address:

817-200-1195 U.S. NRC, Region IV

Ryan.Alexander@nrc.gov 1600 East Lamar Blvd.

Arlington, TX 76011-4511

Attn: Ryan Alexander, DRP

-5- Enclosure

ML16258A031

SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword

By: RDA Yes No Non-Sensitive Publicly Available NRC-002

OFFICE DRP/RPBA C:DRP/RPBD

NAME RAlexander GMiller

SIGNATURE /RA-E/ /RA/

DATE 09/13/16 09/14/16

Letter to Randall K. Edington from Geoffrey Miller, dated September 14, 2016

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

NOTIFICATION OF NRC INSPECTION OF THE IMPLEMENTATION OF

MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION

ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/

STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS (05000528/2016009;

05000529/2016009; AND 05000530/2016009) AND REQUEST FOR

INFORMATION

DISTRIBUTION:

Regional Administrator (Kriss.Kennedy@nrc.gov)

Deputy Regional Administrator (Scott.Morris@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Charles.Peabody@nrc.gov)

Resident Inspector (David.You@nrc.gov)

Resident Inspector (Dustin.Reinert@nrc.gov)

Administrative Assistant (Yvonne.Dubay@nrc.gov)

Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP (Vacant)

Project Engineer, DRP/D (Jim.Melfi@nrc.gov)

Project Engineer, DRP/D (Brian.Parks@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Project Manager (Siva.Lingam@nrc.gov)

Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Inspection Team Lead, Sr. Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Team Member, Reactor Inspector, DRS/IPAT (Eduardo.Uribe@nrc.gov)

Team Member, Project Engineer, Region III/DRP (Bruce.Bartlett@nrc.gov)