ML052280256

Response to NRC Order EA-05-007

ML052280256
Person / Time
Site:	Palo Verde
Issue date:	08/05/2005
From:	Overbeck G Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC/SECY, NRC/SECY/RAS
References
102-05317-GRO/CKS/DGM/DFH, EA-05-007
Download: ML052280256 (5)

Text

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EA-05-007 LAMAP A subsidiaty of Pinnacle Wmest Capital Corporation Palo Verde Nuclear Generating Station Gregg R. Overbeck Senior Vice President Nuclear Tel (623) 393-5148 Fax (623) 393-8077 Mail Station 7602 PO Box 52034 Phoenix, Arizona 85072-2034 102-05317-GRO/CKS/DGM/DFH August 5, 2005 Document Control Desk ATTN: Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Secretary, Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff Washington, DC 20555

Subject:

1. NRC Order EA-05-007, dated July 19, 2005, "Issuance of Order for Additional Security Measures on the Transportation of Radioactive Material Quantities of Concern" Palo Verde Nuclear Generating Station (PVNGS)

Docket Nos. STN 50-528, 50-529 and 50-530 Response to NRC Order EA-05-007

Dear Sirs:

Pursuant to 10 CFR 2.202, Palo Verde Nuclear Generating Station (PVNGS) files this reply to the referenced Order regarding Additional Security Measures (ASMs) for Radioactive Material Quantities of Concern (RAMQC). PVNGS consents to the Order.

Currently, PVNGS has no plans to ship radioactive materials in the quantities of concern described in the Order. In accordance with Section III.A of the Order, when a need arises to ship radioactive materials in quantities of concern, PVNGS will complete implementation of the ASMs before such shipment. In the meantime, PVNGS commits to referencing this Order and incorporating the table of isotopes/limits in our shipment procedure to ensure the issue is considered before any future shipment.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

Document Control Desk ATTN: Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Response to NRC Order EA-05-007 Page 2 If you have questions concerning this matter, please contact Daniel G. Marks at 623-393-6492.

Sincerely, GRO/CKS/DGM/DFH/ca

Enclosures:

1.) Oath 2.) Twenty-day Response to Order EA-05-007 cc:

B. S. Mallet, Region IV Administrator M. B. Fields, PVNGS Project Manager G. G. Warnick, Resident Inspector J. E. Dyer, Director, Office of Reactor Regulations Office of Enforcement Assistant General Counsel for Materials Litigation and Enforcement Secretary of the Commission (hearinadocket(Enrc.cov)

Office of General Counsel (OGCMailCenteranrc.qov)

Enclosure STATE OF ARIZONA

)

) ss.

COUNTY OF MARICOPA

)

I, Gregg R. Overbeck, represent that I am Senior Vice President, Nuclear, and the foregoing response letter to NRC Order 05-007 "Issuance of Order for Additional Security Measures on the Transportation of Radioactive Material Quantities of Concern," dated July 19, 2005, has been signed by me, with full authority to do so on behalf of the Arizona Public Service Company, and to the best of my knowledge and belief, the statements made therein are true and correct.

Al

/

Gregg R. Overbeck Sworn Before Me This

-Day Of W+

, 2005.

No ublic SUSIE LYNN ERGISH Z1~Notory Public - Arizona Madcopc County My Comm. Expires JA 14.2007 Notary Commission Stamp

20-Day Response to NRC Order Dated July 19, 2005 The NRC order of July 19, 2005 includes the following reporting requirements:

Ill.

B.

1.

All Licensees shall, within twenty (20) days of the date of this Order, notify the Commission (1) if they are unable to comply with any of the requirements described in Attachment 2, (2) if compliance with any of the requirements is unnecessary in their specific circumstances, or (3) if implementation of any of the requirements would cause the Licensee to be in violation of the provisions of any Commission regulation or the facility license. The notification shall also provide justification for seeking relief from or variation of any specific requirement.

2.

Any Licensee that considers that implementation of any of the requirements described in Attachment 2 to this Order would adversely impact safe operation of the facility must notify the Commission, within twenty (20) days of the date of this Order, of the adverse safety impact, the basis for its determination that the requirement has an adverse safety impact, and either a proposal for achieving the same objectives specified in the Attachment 2 requirement in question, or a schedule for modifying the facility to address the adverse safety condition. If neither approach is appropriate, the Licensee must supplement its response to Condition B.1 of this Order to identify the condition as a requirement with which it cannot comply, with attendant justifications as required in Condition B.1.

C.

All Licensees shall report to the Commission when they have achieved full compliance with the requirements described in Attachment B.

PALO VERDE NUCLEAR GENERATING STATION (PVNGS) RESPONSE:

B. 1. PVNGS will, to the extent permitted under existing Federal and state statutes and laws, and when shipping radioactive material quantities of concern (RAMQC), implement the additional security measures described in attachment B of the NRC order dated July 19, 2005. PVNGS will implement these measures prior to any shipment of RAMQC. If any

shipments are planned prior to full implementation PVNGS will notify the NRC 90 days prior to this shipment.

2. Implementation of the requirements described in Attachment B to the Order would not adversely impact safe operation of PVNGS.

C.

If PVNGS should ship radioactive material quantities of concern, it will be reported to the Commission when full compliance with the requirements in Attachment B to the Order has been achieved.