Letter Sequence Response to RAI |
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EPID:L-2020-LLM-0002, Application for Order Approving Indirect Transfers of Control of Licenses (Open) |
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MONTHYEARML20337A3442020-12-0202 December 2020 Application for Order Approving Indirect Transfers of Control of Licenses Project stage: Request ML20366A1682020-12-31031 December 2020 NRR E-mail Capture - Palo Verde 1, 2, and 3, and ISFSI - Acceptance Review of an Order Associated with Indirect Transfers of Control of Licenses Project stage: Acceptance Review ML21011A2592021-01-21021 January 2021 ISFSI, FRN - Notice of Consideration of Approval of Application Regarding Proposed Indirect License Transfer and Opportunity for a Hearing Project stage: Other ML21011A2492021-01-21021 January 2021 ISFSI, Letter - Notice of Consideration of Approval of Application Regarding Proposed Indirect License Transfer and Opportunity for a Hearing Project stage: Other ML21043A1462021-02-11011 February 2021 NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAI for an Order Associated with Indirect License Transfer from Public Service Company of New Mexico to Avangrid, Inc Project stage: RAI ML21061A1562021-02-26026 February 2021 Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses Project stage: Response to RAI ML21132A2372021-05-12012 May 2021 NRR E-mail Capture - Palo Verde 1, 2, and 3, and ISFSI - Final Package for an Order Associated with Indirect Transfers of Control of Licenses from Pnm to Avangrid Project stage: Other ML21134A2442021-05-14014 May 2021 Supplemental Information in Support of License Transfer Application - Specific Conditions Project stage: Supplement ML21146A3342021-05-14014 May 2021 ISFSI - Final Package for an Order Associated with Indirect Transfers of Control of Licenses from Pnm to Avangrid Project stage: Other ML21118B0292021-05-25025 May 2021 Order Approving Indirect Transfer of Licenses for Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation (EPID L-2020-LLM-0002) (Order) Project stage: Other ML21118B0282021-05-25025 May 2021 Letter/Se Approving Indirect Transfer of Licenses for Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation Project stage: Other ML21118B0312021-05-25025 May 2021 FRN - Order Approving Indirect Transfer of Licenses for Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation Project stage: Other 2021-02-11
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Category:Letter
MONTHYEARML24262A0972024-09-23023 September 2024 Notification of Post-Approval Site Inspection for License Renewal and Request for Information Inspection (05000529/2024011) ML24241A2542024-08-28028 August 2024 Inservice Inspection Request for Information ML24241A2782024-08-28028 August 2024 License Amendment Request to Revise the Technical Specifications 3.5.1 and 3.5.2 Safety Injection Tank Pressure Bands, and to Use GOTHIC Code ML24240A2682024-08-27027 August 2024 Transmittal of Technical Specification Bases Revision 79 IR 05000528/20240052024-08-22022 August 2024 Updated Inspection Plan for Palo Verde Nuclear Generating Station - Units 1, 2, and 3 (Report 05000528/2024005, 05000529/2024005, 05000530/2024005) 05000530/LER-2024-001, Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation2024-08-21021 August 2024 Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation ML24208A0612024-08-20020 August 2024 Issuance of Amendment Nos. 224, 224, and 224 Regarding Revision to Technical Specifications 3.5.1, 3.5.2 and 3.6.5 IR 05000528/20244042024-08-0808 August 2024 Cybersecurity Inspection Report 05000528/2024404, 05000529/2024404 and 05000530/2024404 ML24213A3292024-07-31031 July 2024 Transmittal of Relief Request (RR) No. 72: Re-Submittal of RR-39 ML24213A3232024-07-31031 July 2024 Transmittal of Relief Request (RR) No. 71: Re-Submittal of RR-30 IR 05000528/20240022024-07-29029 July 2024 Integrated Inspection Report 05000528/2024002 and 05000529/2024002 and 05000530/2024002 ML24173A3302024-07-24024 July 2024 Pressurizer Surge Line Inspection Program ML24159A4702024-07-17017 July 2024 Issuance of Amendment Nos. 223, 223, and 223 Revision to Technical Specifications 3.5.1 and 3.5.2 Using Risk Informed Process for Evaluations ML24198A0662024-07-16016 July 2024 Program Review - Simulator Testing Methodology ML24193A3442024-07-11011 July 2024 Fourth 10-Year Interval, Second Period Owner’S Activity Report Number 3R24 ML24129A0522024-07-0303 July 2024 Review of the Spring 2023 Steam Generator Tube Inspection Report IR 05000528/20240042024-06-25025 June 2024 Notification of Inspection (NRC Inspection Report 05000528/2024004, 05000529/2024004, 05000530/2024004) ML24177A3222024-06-25025 June 2024 Invalid Specified System Actuation of Train B Emergency Diesel Generator ML24177A3212024-06-25025 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canisters Identification Numbers AMZDFX180, AMZDFX181, AMZDFX182 Vertical Concrete Cask Identification Nu ML24170A9962024-06-18018 June 2024 Response to Second Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown a IR 05000528/20243012024-06-17017 June 2024 NRC Examination Report 05000528/2024301; 05000529/2024301; 05000530/2024301 ML24129A2062024-06-14014 June 2024 Issuance of Amendment Nos. 222, 222, and 222 Revision to Technical Specifications to Adopt TSTF-266-A ML24157A3392024-06-0505 June 2024 Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation ML24159A0262024-06-0303 June 2024 Annual Report of Guarantee of Payment of Deferred Premium ML24144A2772024-05-23023 May 2024 Valid Specified System Actuations of Unit 2 Train B Emergency Diesel Generator and Train B Auxiliary Feedwater ML24135A2482024-05-14014 May 2024 Response to Second Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24164A2582024-05-0909 May 2024 10-PV-2024-04 Post-Exam Comments ML24129A1482024-05-0707 May 2024 and Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Casks with Applied Changes ML24128A2702024-05-0707 May 2024 Docket Nos. Stn 50-528/529/530 - Response to NRC Regulatory Issue Summary (RIS) 2024-01, Preparation and Scheduling of Operator Licensing Examinations IR 05000528/20240012024-05-0202 May 2024 Independent Spent Fuel Storage Installation, Integrated Inspection Report 05000528/2024001, 05000529/2024001, 05000530/2024001, 07200044/2024001, and Exercise of Enforcement Discretion ML24119A0022024-04-26026 April 2024 2023 Annual Environmental Operating Report ML24116A2082024-04-24024 April 2024 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2023 IR 05000528/20244012024-04-22022 April 2024 Security Baseline Inspection Report 05000528/2024401 and 05000529/2024401 and 05000530/2024401 (Cover Letter) ML24109A0712024-04-22022 April 2024 NRC Initial Operator Licensing Examination Approval 05000528/2024301, 05000529/2024301, and 05000530/2024301 ML24112A0012024-04-19019 April 2024 Core Operating Limits Report, Revision 32 ML24108A1982024-04-16016 April 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Casks with Applied Changes Authorized by an Amended Certificate of Compliance ML24103A2482024-04-12012 April 2024 Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2023 ML24131A0972024-04-10010 April 2024 Annual Radiological Environmental Operating Report 2023 ML24096A2202024-04-0505 April 2024 Transmittal of Technical Specification Bases Revision 78 ML24032A1542024-04-0303 April 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) ML24089A1892024-03-28028 March 2024 Present Levels of Financial Protection ML24068A2522024-03-0808 March 2024 License Amendment Request to Revise Technical Specifications 3.5.1 and 3.5.2 Using Risk-Informed Process for Evaluations ML24066A0472024-03-0606 March 2024 Response to Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown and TS IR 05000528/20240122024-03-0404 March 2024 Age-Related Degradation Inspection Report 05000528/2024012, 05000529/2024012 and 05000530/2024012 IR 05000528/20230062024-02-28028 February 2024 Annual Assessment Letter for Palo Verde Nuclear Generating Station, Units 1, 2 and 3 Report 05000528/2023006 and 05000529/2023006 and 05000530/2023006 ML24053A3972024-02-22022 February 2024 License Renewal - Alloy 600 Management Program Plan ML24047A3632024-02-16016 February 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canisters Identification Numbers AMZDFX177, AMZDFX178, AMZDFX179 Vertical Concrete Cask Identification No. AMZDNE179, AMZDNE178 IR 05000528/20230042024-02-12012 February 2024 Integrated Inspection Report Report 05000528/2023004 and 05000529/2023004 and 05000530/2023004 ML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owner’S Activity Report Number 1R24 2024-09-23
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24170A9962024-06-18018 June 2024 Response to Second Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown a ML24135A2482024-05-14014 May 2024 Response to Second Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24066A0472024-03-0606 March 2024 Response to Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown and TS ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle ML23048A3202023-02-17017 February 2023 Response to NRC Requests for Additional Information Regarding 2022 Unit 1 Steam Generator Tube Inspections ML22090A0802022-03-31031 March 2022 Response to NRC Requests for Additional Information Regarding 2021 Unit 3 Steam Generator Tube Inspections ML22053A2122022-02-22022 February 2022 Response to Requests for Confirmation of Information for Exemption from Certain Requirements of 10 CFR 50.62(c)(1) Using Risk-Informed Process for Evaluations ML21173A3602021-06-22022 June 2021 Response to Request for Additional Information for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML21061A1562021-02-26026 February 2021 Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses ML21005A2712020-12-29029 December 2020 102-08208 PVNGS Communication Required by Confirmatory Order EA-20-054 ML20090L9442020-03-30030 March 2020 APS Response to Request for Additional Information- Relief Request 65 Unit 2, COVID-19, Request for Relief from Bottom Mounted Instrumentation Nozzles and a Pressurizer Nozzle to Surge ML20073R7532020-03-13013 March 2020 Independent Spent Fuel Storage Installation (ISFSI) - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements ML20054A2692020-02-19019 February 2020 Response to Request for Additional Information - Relief Request 64 - Unit 1 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19340B2142019-12-0606 December 2019 Response to NRC Request for Additional Information Regarding 2019 Steam Generator Tube Inspections ML19331A3612019-11-26026 November 2019 Supplemental Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19277J4572019-10-0404 October 2019 Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19165A1402019-06-14014 June 2019 Response to Request for Additional Information - Relief Request 63 - Unit 3 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19137A1182019-05-17017 May 2019 Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome High Thermal ML19074A1382019-03-14014 March 2019 Response to Request for Additional Information - Relief Request 62 - Third and Fourth 10-Year Inservice Inspection Intervals, Proposed Alternative - Pressurizer Heater Sleeve Repairs ML19031C9052019-01-31031 January 2019 Supplemental License Amendment Request to Revise Technical Specifications Regarding Response Time Testing of Pressure Transmitters and Request for Additional Information Response ML18296A4662018-10-18018 October 2018 Supplemental Information Regarding License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel ML18278A2952018-10-0505 October 2018 Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 ML18264A3182018-09-21021 September 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18194A9142018-07-13013 July 2018 Supplemental Response to Request for Additional Information 3.a for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML18152B8742018-06-0101 June 2018 Response to Electrical Engineering Operating Reactor Branch (Eeob) Request for Additional Information for Risk-Informed Completion Times ML18138A4802018-05-18018 May 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18129A4482018-05-0909 May 2018 APS Response to Request for Additional Information for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML17272B0332017-09-29029 September 2017 Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests ML17153A3732017-06-0202 June 2017 Response to NRC Staff Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Next Generation Fuel ML17144A3762017-05-24024 May 2017 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML17002A0012017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML17066A1842017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML16358A7152016-12-23023 December 2016 Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Diesel Generator Completion Time ML16340A9882016-12-0101 December 2016 Addendum to Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors ML17167A2152016-11-23023 November 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised ... ML16321A0022016-11-0909 November 2016 Response to RAI, Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 ML16300A1562016-10-26026 October 2016 Response to NRC Electrical Engineering Branch Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay ... ML16286A2422016-10-0606 October 2016 Westinghouse Electric Company, WCAP-18030-NP Review, Suggested Response to Request for Additional Information ML16286A2402016-10-0606 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML16257A5442016-09-0909 September 2016 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16203A3812016-07-21021 July 2016 Response to NRC Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16182A5192016-06-30030 June 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Critical Safety Analysis ML16147A0922016-05-20020 May 2016 Response to Request for Additional Information Regarding Relief Request 54, Alternative to Flaw Removal ML16133A6212016-05-12012 May 2016 ISFSI - Response to Request for Additional Information Regarding Proposed Changes to Emergency Action Levels ML16102A4632016-04-11011 April 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505 ML16029A5062016-01-29029 January 2016 Response to Request for Additional Information Regarding the Request to Change the Quality Assurance Program Description ML15273A4702015-09-30030 September 2015 IR 05000528/2015004, 05000529/2015004, and 05000530/2015004; 11/16/2015 - 11/20/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Notification of NRC Triennial Heat Sink Performance Inspection ML15258A8482015-09-15015 September 2015 Response to Request for Additional Information Regarding Exigent License Amendment Request to Amend Technical Specification Surveillance Requirement 3.1.5.3 ML15223A2062015-08-0606 August 2015 Response to Request for Additional Information Associated with Seismic Hazard and Screening Report 2024-06-18
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Attachment 1 to the Enclosure Contains Personal Privacy Information Withhold Attachment 1 from Public Disclosure Pursuant to 10 CFR 2.390.
10 CFR 50.80 10 CFR 72.50 aps Palo Verde Nuclear Generating Station 5871 S. Wintersburg Road Tonopah, AZ 85354 102-08238-TNW/MDD February 26, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Dear Sirs:
SUBJECT:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 and Independent Spent Fuel Storage Installation Docket No. 72-44 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses
REFERENCES:
- 1. Letter dated December 2, 2020, from T. N. Weber to Document Control Desk (ADAMS Accession No. ML20337A344)
- 2. Email dated February 11, 2021 from S. Lingam to M. S. Cox By letter dated December 2, 2020 (Reference 1), Arizona Public Service Company (APS), on behalf of Public Service Company of New Mexico (PNM), Avangrid, Inc. (Avangrid) and their corporate affiliates (together, Applicants), respectfully requested that the U.S. Nuclear Regulatory Commission (NRC) consent to the indirect transfers of PNM's co-owner licenses for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (PVNGS), and for the PVNGS Independent Spent Fuel Storage Installation. In Reference 2, the NRC staff requested additional information regarding the Applicants.
A response to the request for additional information is provided as an enclosure that has an . The response and attachment are provided by PNM and Avangrid.
A member of the STARS Alliance LLC Callaway* Diablo Canyon* Palo Verde* Wolf Creek
102-08238-TNW/MDD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses Page 2 contains "personal privacy" information that should be withheld from public disclosure pursuant to 10 CFR 2.390 and maintained as confidential information.
This correspondence contains no new regulatory commitments of APS or PNM.
Sincerely, Digitally signed by Weber, Thomas 0
weber Th Om as ~~
I c~~!eber, Thomas N(Z00499)
Reason: I am approving this N(Z00499) document Date: 2021.02.26 15:59:21 -07'00' Thomas N. Weber Director, Nuclear Regulatory Affairs
Enclosure:
Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses - General Corporate Information Regarding Public Service Company of New Mexico, PNM Resources, Inc, Avangrid Networks, Inc, Avangrid, Inc. and Iberdrola, S.A.
cc:
S. A. Morris NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS C. A. Peabody NRC Senior Resident Inspector for PVNGS B. D. Goretzki Arizona Department of Health Services - Bureau of Radiation Control
ENCLOSURE Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses
Enclosure Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses Page 1 of 2 Response to Request for Additional Information The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the application for the subject Order and concluded that additional information is required for complete evaluation. The NRC staff transmitted the draft request for additional information (RAI) on February 10, 2021, and Arizona Public Service Company (APS, the licensee) responded on February 11, 2021, that no clarification call was required. The NRC staff requested that the response to the following official RAI be provided within 30 days from February 11, 2021.
By letter dated December 2, 2020 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML20337A344], APS requested approval of indirect transfers of control of licenses related to Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde), and its Independent Spent Fuel Storage Installation (ISFSI). Briefly, APS requested NRC consent to the indirect transfers of Public Service Company of New Mexico's (PNM's) co-owner licenses to Avangrid, Inc. (partially foreign owned) for Palo Verde and its ISFSI. The NRC staff RAI is stated first followed by the APS response. The regulatory basis for the RAI was provided in the February 11, 2021, NRC staff email but is not repeated in this Enclosure.
In addition, PNM notes that as of February 1, 2021, Michael P. Mertz and Elisabeth A. Eden assumed new positions for both PNM and PNM Resources, Inc. as follows:
Michael P. Mertz, Vice President and Chief Information Officer Elisabeth A. Eden, Vice President and Treasurer This updates the information provided in Attachment 1 to the license transfer application (ADAMS Accession No. ML20337A344).
FAB-RAI-1 While the licensee's application for the subject Order provides the names and addresses of the directors and principal officers of the corporate entities involved in the proposed transaction, the application does not provide the citizenship.
Please provide the citizenship of the directors and principal officers of Public Service Company of New Mexico, PNM Resources, Inc., Avangrid Networks, Inc., and Avangrid, Inc.
Response
The citizenship information for the officers and directors of PNM, PNM Resources, Inc.,
Avangrid Networks, Inc., Avangrid, Inc., and Iberdrola, S.A. is provided in Attachment 1 of this Enclosure. of this Enclosure includes personal privacy information as defined in 10 CFR 2.390(a)(6). PNM and Avangrid therefore respectfully requests in accordance with 10 CFR 2.390(a) that Attachment 1 be withheld from public disclosure and maintained as confidential.
Citizenship information is Sensitive Personally Identifiable Information ("SPII"), which should remain confidential. For example, this is reflected in the definition of SPII in the Department of Homeland Security's "Handbook for Safeguarding Sensitive PII," Privacy
Enclosure Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses Page 2 of 2 Policy Directive 047-01-007, Rev. 3, page 5 (Dec. 4, 2017) ["Other data elements such as citizenship or immigration status, medical information, ethnic, religious, sexual orientation, or lifestyle information, in conjunction with the identity of an individual ( directly or indirectly inferred), are also SPII."] (Emphasis Added.) 1 The European Union's General Data Protection Regulation ("GDPR") also requires that SPII be maintained as confidential. 2 1
Available at: https://www.dhs.gov/sites/defau1Ufiles/publications/dhs%20policy%20directive%2004 7 007%20handbook%20for%20safeguarding%20sensitive%20PI I%2012-4-2017. pdf 2
Available at: https://gdpr.eu/tag/chapter-1/
STATE OF NEW MEXICO )
) SS.
COUNTY OF BERNALILLO )
Patricia K. Collawn, being duly sworn according to law deposes and says:
I am Chairman, President and Chief Executive Officer of Public Service Company of New Mexico (PNM), and as such, I am familiar with the contents of this correspondence and the attachment thereto concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (PVNGS), and the matters set forth therein regarding PNM and its affiliated companies are true and correct to the best of my knowledge, information and belief.
Patricia K. Collawn Subscribed and Sworn to before me this 16th day of February 2021
~!J4M4J (/ ti Notary Public of the County of Bernalillo OFFICIAL SEAL Susan G. Gordon NOTARY PUBLIC*State ofNew Mexico My Com.mission Expires September 15, 2024
STATE OF CONNECTICUT COUNTY OF NEW HAVEN Robert D. Kump, being duly sworn according to law deposes and says:
I am Deputy CEO of Avangrid, Inc. (Avangrid), and as such, I am familiar with the contents of this correspondence and the attachment thereto concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (PVNGS), and the matters set forth therein regarding Avangrid and its affiliated companies are true and correct to the best of my knowledge, information and belief.
1W Robko. Kump Subscribed and Sworn to before me this 25th day of February, 2021 Notary Public of the County of New Haven