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 NRC/NRR/ADRO/DORL/LPLIV
To:	Edington R 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, 2007 Mr. Randall K. Edington Senior 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 a request 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 and determined 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 Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosure:

Request for Additional Information cc: See next page

ML071160437 *previously concurred OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME MMarkley* MFields:CFL for MBF* JBurkhardt THiltz:MTM for TGH*

DATE 4/27/07 4/27/07 4/27/07 4/27/07 Palo Verde Nuclear Generating Station cc:

Mr. Steve Olea Mr. John Taylor Arizona Corporation Commission Public Service Company of New Mexico 1200 W. Washington Street 2401 Aztec NE, MS Z110 Phoenix, AZ 85007 Albuquerque, NM 87107-4224 Mr. Douglas Kent Porter Mr. Geoffrey M. Cook Senior Counsel Southern California Edison Company Southern California Edison Company 5000 Pacific Coast Hwy Bldg N50 Law Department, Generation Resources San Clemente, CA 92672 P.O. Box 800 Rosemead, CA 91770 Mr. Robert Henry Salt River Project Senior Resident Inspector 6504 East Thomas Road U.S. Nuclear Regulatory Commission Scottsdale, AZ 85251 P.O. Box 40 Buckeye, AZ 85326 Mr. Jeffrey T. Weikert Assistant General Counsel Regional Administrator, Region IV El Paso Electric Company U.S. Nuclear Regulatory Commission Mail Location 167 Harris Tower & Pavillion 123 W. Mills 611 Ryan Plaza Drive, Suite 400 El Paso, TX 79901 Arlington, TX 76011-8064 Mr. John Schumann Chairman Los Angeles Department of Water & Power Maricopa County Board of Supervisors Southern California Public Power Authority 301 W. Jefferson, 10th Floor P.O. Box 51111, Room 1255-C Phoenix, AZ 85003 Los Angeles, CA 90051-0100 Mr. Aubrey V. Godwin, Director Mr. Brian Almon Arizona Radiation Regulatory Agency Public Utility Commission 4814 South 40 Street William B. Travis Building Phoenix, AZ 85040 P.O. Box 13326 1701 North Congress Avenue Mr. Scott Bauer, Acting General Manager Austin, TX 78701-3326 Regulatory Affairs and Performance Improvement Ms. Karen O'Regan Palo Verde Nuclear Generating Station Environmental Program Manager Mail Station 7636 City of Phoenix P.O. Box 52034 Office of Environmental Programs Phoenix, AZ 85072-2034 200 West Washington Street Phoenix AZ 85003 Mr. Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 January 2007

REQUEST FOR ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 By letter dated December 22, 2006, Arizona Public Service Company (APS), submitted a request 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 additional information is required in order to complete the evaluation.

RAI # Palo Verde EAL # Information Requested 1 How do these changes fit into the overall Emergency Action Level (EAL) scheme? Provide the entire EAL Matrix for assessing these changes in relation to the complete scheme.

2 3-3, 3-13 Please provide additional information to support these revisions.

3 Various Are there other gaseous effluent monitors besides the Plant Vent and the Fuel Building Vent?

4 Why is the transition from RU-143 to RU-144 made at the Site 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.

5 Various Why do the Initiating Conditions (ICs) refer to both gaseous and liquid radioactivity releases when no liquid monitors are used in the EALs?

6 EAL 3-13 This EAL is for level <132.5 ft and uses sumps as an indication. How do sumps equate to this level?

7 Various The basis document describes a reduction in credited filter efficiency 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.

8 Various Why 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 Requested 9 3-14, 3-15, 3-17, 3-18 These EALs have either deletions or content that was moved. Please provide justification (i.e., OR Valid dose assessment indicates > 100 mrem.. was deleted).

10 1-4, 3-2, 3-15, 3-18 These EALs were changed to a higher threshold activity value. What is the justification for using a less conservative value in each of these?

11 Pages 356 of basis What is the reason for the deleted paragraph on this page?