ML071160437

Request for Additional Information Regarding Withdrawal and Resubmittal of Emergency Plan and Implementing Procedure Requests (TAC Nos. MD3883, MD3884, and MD3885)

ML071160437
Person / Time
Site:	Palo Verde
Issue date:	04/27/2007
From:	Fields M B NRC/NRR/ADRO/DORL/LPLIV
To:	Edington R K Arizona Public Service Co
Markley, M T, NRR/DORL/LP4, 301-415-5723
References
TAC MD3883, TAC MD3884, TAC MD3885
Download: ML071160437 (5)

Text

April 27, 2007Mr. Randall K. EdingtonSenior Vice President, Nuclear Mail Station 7602 Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -REQUEST FOR ADDITIONAL INFORMATION REGARDING WITHDRAWAL AND RESUBMITTAL OF EMERGENCY PLAN AND IMPLEMENTING PROCEDURE REQUESTS (TAC NOS. MD3883, MD3884, AND MD3885)

Dear Mr. Edington:

By letter dated December 22, 2006, Arizona Public Service Company (APS) submitted arequest for withdrawal and resubmittal of changes to the Emergency Plan (EPlan) and Emergency Plan Implementing Procedures (EPIPs) for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. You requested withdrawal of proposed EPlan Revisions 32 and 33 and EPIP 99 changes provided in APS letters dated April 22 and May 31, 2005, respectively.

Your request provides changes to the EPlan and EPIP 99 that reflect the substance of the previous submittals, and intervening changes performed under 10 CFR 50.54(q).The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided anddetermined that additional information is required in order to complete the evaluation. The enclosed request for additional information was discussed with Glenn Michael of your staff on April 18, 2007. As agreed upon, the NRC staff is expecting a response within 60 days of the date of this letter.If you have any questions, please contact Michael Markley at 301-415-5723.Sincerely,/RA C. Lyon for Mel B. Fields/Mel B. Fields, Senior Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosure:

Request for Additional Information cc: See next page

ML071160437*previously concurredOFFICENRR/LPL4/PMNRR/LPL4/PMNRR/LPL4/LANRR/LPL4/BCNAMEMMarkley*MFields:CFL for MBF*JBurkhardtTHiltz:MTM for TGH*

DATE4/27/074/27/074/27/074/27/07 January 2007Palo Verde Nuclear Generating Station cc:Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007Mr. Douglas Kent PorterSenior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770Senior Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 40 Buckeye, AZ 85326Regional Administrator, Region IVU.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064ChairmanMaricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003Mr. Aubrey V. Godwin, DirectorArizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040Mr. Scott Bauer, Acting General ManagerRegulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034Mr. Matthew BenacAssistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004Mr. John TaylorPublic Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224Mr. Geoffrey M. CookSouthern California Edison Company 5000 Pacific Coast Hwy Bldg N50 San Clemente, CA 92672Mr. Robert HenrySalt River Project 6504 East Thomas Road Scottsdale, AZ 85251Mr. Jeffrey T. WeikertAssistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901Mr. John SchumannLos Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100Mr. Brian AlmonPublic Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326Ms. Karen O'ReganEnvironmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix AZ 85003 REQUEST FOR ADDITIONAL INFORMATIONPALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530By letter dated December 22, 2006, Arizona Public Service Company (APS), submitted arequest for withdrawal and resubmittal of changes to the Emergency Plan (EPlan) and Emergency Plan Implementing Procedures (EPIPs) for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. This APS requested withdrawal of proposed EPlan Revisions 32 and 33 and EPIP 99 changes requested in letters dated April 22 and May 31, 2005, respectively. The staff has reviewed the information provided and determined that the following additionalinformation is required in order to complete the evaluation.RAI #Palo Verde EAL #Information Requested1How do these changes fit into the overall Emergency ActionLevel (EAL) scheme? Provide the entire EAL Matrix for assessing these changes in relation to the complete scheme.23-3, 3-13Please provide additional information to support theserevisions.3VariousAre there other gaseous effluent monitors besides the PlantVent and the Fuel Building Vent?4Why is the transition from RU-143 to RU-144 made at theSite Area Emergency (SAE) level for the Plant Vent but the transition is made from RU-145 to RU-146 for the Fuel Building at the Alert level? Ref., Table 3, page 7 of 493.5VariousWhy do the Initiating Conditions (ICs) refer to both gaseousand liquid radioactivity releases when no liquid monitors are used in the EALs? 6EAL 3-13This EAL is for level <132.5 ft and uses sumps as anindication. How do sumps equate to this level?7VariousThe basis document describes a reduction in credited filterefficiency for the Plant Vent from 95% to 70%, yet the Fuel Building filters still use a 95% value. Why does the Fuel Building remain unchanged? If this is correct, provide justification why the Fuel Building filters remain at 95%

efficiency.8VariousWhy do several proposed ICs refer to 'whole body' and'child thyroid' when these terms were supplanted with

'TEDE' and 'thyroid CDE' by EPA-400-92-001? RAI #Palo Verde EAL #Information Requested93-14, 3-15, 3-17, 3-18These EALs have either deletions or content that wasmoved. Please provide justification (i.e., 'OR Valid doseassessment indicates > 100 mrem-..

' was deleted).101-4, 3-2, 3-15, 3-18These EALs were changed to a higher threshold activityvalue. What is the justification for using a less conservative value in each of these?11Pages 356 of basisWhat is the reason for the deleted paragraph on this page?