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| | 'CCESSION NBR:9804220015 DOC.DATE: 98/04/03 NOTARIZED: NO DOCKET ¹ FACZL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 S=N-5C'-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION KANBERGS,K. Environmental Protection Agency RECIP.NAME RECIPIENT AFFILIATION DONOHEW,J.N. |
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| | ==SUBJECT:== |
| | Provides comments re review of EA &. FONSI for proposed conversion to improved standard TS for PVNGS,per NEPA,CEA NEPA Implementation Regulations at 40CFR1500-1508 E Section 309 of Clean Air Act.NEPA process related issues discussed. |
| | DXSTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: |
| | TITLE: OR Submittal: General Distribution 6 |
| | NOTES: STANDARDIZED PLANT 05000528 Standardized plant. 05000529 p Standardized plant. 05000530 R |
| | REC1PZENT COPIES RECZPZENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 LA PD4-2 PD FIELDS,M INTERNAL: ACRS FILE CENTE NRR/DE/ECGB/A NR DE EMCB NRR/DRCH/HICB NRR/DSSA/SPLB D NRR/DSSA/SRXB NUDOCS-ABSTRACT OGC/HDS2 0 EXTERNAL: NOAC NRC PDR E |
| | NOTE TO ALL "RIDS" RECIPIENTS: |
| | PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL |
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| | UNITED STATES ENVIRONMENTALPROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105 ~o-SX~/S>~~/8+> |
| | April 3, 1998 United States Nuclear Regulatory Commission Mr. Jack N. Donohew, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects -III/IV Office of Nuclear Reactor Regulation Washington, D.C. 20555-0001 |
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| | ==Dear Mr. Donohew:== |
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| | The U.S. Environmental Protection Agency (EPA) has reviewed an Environmental Assessment (EA) and finding of no significant impact (FONSI) for the Proposed Conversion to the Improved Standard Technical Specifications for Palo Verde Nuclear Generating Station Units No. 1, 2 and 3, Maricopa County, Arizona. Our comments are provided pursuant to the National Environmental Policy Act (NEPA), the Council on Environmental Quality's (CEQ) NEPA Implementation Regulations at 40 CFR 1500-1508, and Section 309 of the Clean AirAct. Based on our review, we have several NEPA process related issues to discuss. |
| | The proposed action is a series of amendments to the Current Technical Specifications (CTS). According to the EA, the need for the proposed action is the recognition that safety in nuclear power plants would benefit from an improvement and standardization of the Technical Specification (TS). We presume that the need for the proposed action is to improve and standardize technical specifications to improve safety at nuclear power plants. Ifthat is NRC's intended need, then the EA should state this in "plain language" [40 CFR 1500.4(d)]. |
| | The purposes of an EA are outlined at 40 CFR 1508.9. One of the main purposes is determination ifa proposed action could result in significant effects on the human environment. |
| | It should also include a brief discussion of alternatives f40 CFR 1508.9(b)]. The Palo Verde EA does not provide any alternatives to the proposed action and states: |
| | "Since the Commission has concluded there is no measurable environmental impact associated with the proposed amendments, any alternatives with equal or greater environment impact need not be evaluated... The environmental impacts of the proposed action and the alternative action are similar." |
| | Yet, the premise of the EA is that the proposed amendments would result in greater nuclear 98042200i5 980403 PDR ADOCK 05000528 I P PDR I |
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| | safety; therefore, the presented information could be interpreted as contradictory. EPA suggests that it would be more appropriate to contrast the proposed action against a no action alternative. |
| | In this way; NEPA requirements are met and the audience is provided a mechanism to gage the relative impacts of the two alternatives. It would appear that the proposed action provides potentially positive environmental impacts, but this is not effectively emphasized in the EA, or contrasted against a no action alternative. |
| | An EA should briefly explain why a proposed action would not have significant impacts. |
| | While we do not question the basis of your judgements, item two on page five of the EA serves as an example. The need for an "emergency action shutdown requirement" during a routine shutdown is proposed for elimination. NRC's statement could be interpreted by the public that, during routine shutdowns, the ability to respond to emergency situations would be lessened. This serves as a concrete example to illustrate the need for inclusion of concise statements stating why no significant impacts could result. |
| | EPA also notes that the FONSI does not conform to CEQ regulations-at 40 CFR 1508.13. A FONSI must include an explanation of why an action will not have a significant effect on the human environment. |
| | In conclusion, some procedural-related changes, as suggested in this letter, could result in a better NEPA process. EPA has also noticed that the NRC has written a number of EA's regarding minor changes in operation or procedures at regulated nuclear facilities, within EPA's Region IX area. I would appreciate discussing with you how your agency determines when to prepare an EA and your NEPA related policies regarding operations at Nuclear Power Plants. |
| | The CEQ regulations at 40 CFR 1500.4 provide a range of options to agencies, allowing potential streamlining of the NEPA process. |
| | We appreciate the opportunity to review the documents. For questions and further discussion, please contact me at (415) 744-1483, or at the letterhead address (code: CMD-2). |
| | Sincerely, arl Kanbergs, Environmental Scientist Federal Activities Office MI: 002836/98-072 |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17313B0991999-10-14014 October 1999
Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing
ML17313B0881999-10-12012 October 1999
Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2
ML17300B3501999-09-29029 September 1999
Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7
ML17300B3551999-09-28028 September 1999
Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl
ML17313B0851999-09-24024 September 1999
Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles
ML17313B0781999-09-20020 September 1999
Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included
ML17300B3331999-09-14014 September 1999
Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3
ML17300B3351999-09-0808 September 1999
Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met
ML17313B0761999-09-0303 September 1999
Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H
ML17313B0731999-08-31031 August 1999
Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55
ML20211A9501999-08-12012 August 1999
Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl
ML17313B0581999-08-0606 August 1999
Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included
ML17313B0311999-08-0303 August 1999
Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001
ML20210L1461999-08-0303 August 1999
Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams
ML17313B0431999-07-30030 July 1999
Advises of Listed Senior Mgt Changes That Have Taken Place at Plant
ML17313B0441999-07-30030 July 1999
Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps.
ML17313B0151999-07-20020 July 1999
Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys
ML17313B0091999-07-20020 July 1999
Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1
ML17313B0171999-07-16016 July 1999
Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations
ML17300B3111999-07-15015 July 1999
Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr
ML17300B3141999-07-15015 July 1999
Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790
ML20209G6771999-07-0808 July 1999
Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl
ML17300B2931999-07-0202 July 1999
Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval
ML17313A9951999-06-26026 June 1999
Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants.
ML17300B2831999-06-26026 June 1999
Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl
ML17313A9901999-06-15015 June 1999
Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr
ML17313A9521999-05-24024 May 1999
Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55
ML20206Q3111999-05-18018 May 1999
Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety
ML17313A9311999-05-13013 May 1999
Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload
ML17313A9481999-05-12012 May 1999
Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address
ML17313A9261999-05-0707 May 1999
Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing
ML20206H1931999-05-0303 May 1999
Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl
ML17313A9091999-04-30030 April 1999
Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld
ML17313A9181999-04-30030 April 1999
Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790
ML17313A9191999-04-30030 April 1999
Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422
ML17300B3751999-04-23023 April 1999
Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool
ML17313A9081999-04-23023 April 1999
Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531
ML20205T7421999-04-21021 April 1999
Forwards Partially Withheld Insp Repts 50-528/99-05, 50-529/99-05 & 50-530/99-05 on 990322-26.Determined That Security Program Properly Implemented.Insp Repts Details Withheld (Ref 10CFR73.21)
ML17313B0271999-04-21021 April 1999
Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl
ML17313A9031999-04-21021 April 1999
Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection
ML17313A8971999-04-20020 April 1999
Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections
05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999
Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing
ML17313A8931999-04-14014 April 1999
Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met
ML20205Q0821999-04-13013 April 1999
Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item
ML17313A8901999-04-13013 April 1999
Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing
ML17313A8831999-04-0808 April 1999
Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3
ML20205F3491999-03-30030 March 1999
Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1)
ML17313A8671999-03-24024 March 1999
Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3)
ML17313A8601999-03-16016 March 1999
Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon
ML17313A8551999-03-0505 March 1999
Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe
1999-09-08
[Table view]
Category:INCOMING CORRESPONDENCE
MONTHYEARML17313B0991999-10-14014 October 1999
Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing
ML17313B0881999-10-12012 October 1999
Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2
ML17300B3501999-09-29029 September 1999
Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7
ML17300B3551999-09-28028 September 1999
Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl
ML17313B0851999-09-24024 September 1999
Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles
ML17313B0781999-09-20020 September 1999
Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included
ML17300B3331999-09-14014 September 1999
Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3
ML17300B3351999-09-0808 September 1999
Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met
ML17313B0761999-09-0303 September 1999
Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H
ML17313B0731999-08-31031 August 1999
Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55
ML17313B0581999-08-0606 August 1999
Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included
ML17313B0311999-08-0303 August 1999
Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001
ML17313B0441999-07-30030 July 1999
Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps.
ML17313B0431999-07-30030 July 1999
Advises of Listed Senior Mgt Changes That Have Taken Place at Plant
ML17313B0151999-07-20020 July 1999
Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys
ML17313B0091999-07-20020 July 1999
Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1
ML17313B0171999-07-16016 July 1999
Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations
ML17300B3111999-07-15015 July 1999
Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr
ML17300B3141999-07-15015 July 1999
Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790
ML20209G6771999-07-0808 July 1999
Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl
ML17300B2931999-07-0202 July 1999
Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval
ML17313A9951999-06-26026 June 1999
Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants.
ML17300B2831999-06-26026 June 1999
Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl
ML17313A9901999-06-15015 June 1999
Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr
ML17313A9521999-05-24024 May 1999
Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55
ML17313A9311999-05-13013 May 1999
Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload
ML17313A9481999-05-12012 May 1999
Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address
ML17313A9261999-05-0707 May 1999
Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing
ML20206H1931999-05-0303 May 1999
Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl
ML17313A9191999-04-30030 April 1999
Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422
ML17313A9181999-04-30030 April 1999
Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790
ML17313A9091999-04-30030 April 1999
Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld
ML17313A9081999-04-23023 April 1999
Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531
ML17300B3751999-04-23023 April 1999
Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool
ML17313B0271999-04-21021 April 1999
Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl
ML17313A9031999-04-21021 April 1999
Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection
ML17313A8971999-04-20020 April 1999
Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections
05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999
Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing
ML17313A8931999-04-14014 April 1999
Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met
ML20205Q0821999-04-13013 April 1999
Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item
ML17313A8901999-04-13013 April 1999
Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing
ML17313A8831999-04-0808 April 1999
Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3
ML20205F3491999-03-30030 March 1999
Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1)
ML17313A8671999-03-24024 March 1999
Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3)
ML17313A8601999-03-16016 March 1999
Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon
ML17313A8551999-03-0505 March 1999
Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe
ML17313A8241999-02-23023 February 1999
Advises That Kp Jarvis,License OP-50287-1,no Longer Needs to Maintain License as Permanently Assigned to Position Requiring No License
ML17313A8111999-02-18018 February 1999
Forwards PVNGS Unit 3 7th Refueling Outage, Which Provides Complete Results of SG Tube Inservice Insp Performed,Per TS 5.6.8
ML17313A8721999-02-16016 February 1999
Discusses Resolution of Generic Safety Issue 171, ESF Failures from Loss-of-Offsite Power Subsequent to Loca. Util Has Low Vulnerability to Loca/Grid Collapse/Loop Scenario
ML17313A7611999-01-22022 January 1999
Forwards PVNGS Unit 3 Inservice Insp Rept Seventh Refueling Outage, Per 10CFR50.55a.Ltr Contains No New Commitments
1999-09-08
[Table view] |
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CATEGORY 1 REGULA'x Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)
'CCESSION NBR:9804220015 DOC.DATE: 98/04/03 NOTARIZED: NO DOCKET ¹ FACZL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 S=N-5C'-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION KANBERGS,K. Environmental Protection Agency RECIP.NAME RECIPIENT AFFILIATION DONOHEW,J.N.
SUBJECT:
Provides comments re review of EA &. FONSI for proposed conversion to improved standard TS for PVNGS,per NEPA,CEA NEPA Implementation Regulations at 40CFR1500-1508 E Section 309 of Clean Air Act.NEPA process related issues discussed.
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NOTES: STANDARDIZED PLANT 05000528 Standardized plant. 05000529 p Standardized plant. 05000530 R
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UNITED STATES ENVIRONMENTALPROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105 ~o-SX~/S>~~/8+>
April 3, 1998 United States Nuclear Regulatory Commission Mr. Jack N. Donohew, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects -III/IV Office of Nuclear Reactor Regulation Washington, D.C. 20555-0001
Dear Mr. Donohew:
The U.S. Environmental Protection Agency (EPA) has reviewed an Environmental Assessment (EA) and finding of no significant impact (FONSI) for the Proposed Conversion to the Improved Standard Technical Specifications for Palo Verde Nuclear Generating Station Units No. 1, 2 and 3, Maricopa County, Arizona. Our comments are provided pursuant to the National Environmental Policy Act (NEPA), the Council on Environmental Quality's (CEQ) NEPA Implementation Regulations at 40 CFR 1500-1508, and Section 309 of the Clean AirAct. Based on our review, we have several NEPA process related issues to discuss.
The proposed action is a series of amendments to the Current Technical Specifications (CTS). According to the EA, the need for the proposed action is the recognition that safety in nuclear power plants would benefit from an improvement and standardization of the Technical Specification (TS). We presume that the need for the proposed action is to improve and standardize technical specifications to improve safety at nuclear power plants. Ifthat is NRC's intended need, then the EA should state this in "plain language" [40 CFR 1500.4(d)].
The purposes of an EA are outlined at 40 CFR 1508.9. One of the main purposes is determination ifa proposed action could result in significant effects on the human environment.
It should also include a brief discussion of alternatives f40 CFR 1508.9(b)]. The Palo Verde EA does not provide any alternatives to the proposed action and states:
"Since the Commission has concluded there is no measurable environmental impact associated with the proposed amendments, any alternatives with equal or greater environment impact need not be evaluated... The environmental impacts of the proposed action and the alternative action are similar."
Yet, the premise of the EA is that the proposed amendments would result in greater nuclear 98042200i5 980403 PDR ADOCK 05000528 I P PDR I
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safety; therefore, the presented information could be interpreted as contradictory. EPA suggests that it would be more appropriate to contrast the proposed action against a no action alternative.
In this way; NEPA requirements are met and the audience is provided a mechanism to gage the relative impacts of the two alternatives. It would appear that the proposed action provides potentially positive environmental impacts, but this is not effectively emphasized in the EA, or contrasted against a no action alternative.
An EA should briefly explain why a proposed action would not have significant impacts.
While we do not question the basis of your judgements, item two on page five of the EA serves as an example. The need for an "emergency action shutdown requirement" during a routine shutdown is proposed for elimination. NRC's statement could be interpreted by the public that, during routine shutdowns, the ability to respond to emergency situations would be lessened. This serves as a concrete example to illustrate the need for inclusion of concise statements stating why no significant impacts could result.
EPA also notes that the FONSI does not conform to CEQ regulations-at 40 CFR 1508.13. A FONSI must include an explanation of why an action will not have a significant effect on the human environment.
In conclusion, some procedural-related changes, as suggested in this letter, could result in a better NEPA process. EPA has also noticed that the NRC has written a number of EA's regarding minor changes in operation or procedures at regulated nuclear facilities, within EPA's Region IX area. I would appreciate discussing with you how your agency determines when to prepare an EA and your NEPA related policies regarding operations at Nuclear Power Plants.
The CEQ regulations at 40 CFR 1500.4 provide a range of options to agencies, allowing potential streamlining of the NEPA process.
We appreciate the opportunity to review the documents. For questions and further discussion, please contact me at (415) 744-1483, or at the letterhead address (code: CMD-2).
Sincerely, arl Kanbergs, Environmental Scientist Federal Activities Office MI: 002836/98-072
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