IR 05000528/1991035

Forwards Restatement of 911108 Notice of Violation Re Insp Repts 50-528/91-35,50-529/91-35 & 50-530/91-35

ML17306A416
Person / Time
Site:	Palo Verde
Issue date:	12/09/1991
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17306A415	List: IR 05000528/1991035 ML17306A416
References
102-02087-WFC-T, 102-2087-WFC-T, NUDOCS 9202030060
Download: ML17306A416 (14)

Text

WILLIAM F.CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Pie" C,"I~I>~D r:RC R GJO'J V Arizona Public Service Company JPPJ Q-"p J 3 gf fg p8 P.O, EIOX 53999~PHOENIX.ARIZONA 850?2.3999 102-02087-WFC/TRB/JRB December 9, 1991 U.S.Nuclear Regulatory Commission Attention:

Document Control Desk Mail Station: P1-37 Washington, DC 20555 Reference:

Letter from S.A.Richards, Chief, Reactor Projects Branch, NRC to W.F.Conway, Executive Vice President, Nuclear, APS, dated November 8, 1991.Gentlemen:

SUB JECT: PALO VERDE NUCLEAR GENERATING STATION (PVNGS)UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION 50-529/91-35-05 File: 91-070-026 Arizona Public Service Company (APS)has reviewed NRC Inspection Report 50-528, 529, 530/91-35 and the Notice of Violation dated November 8, 1991.Pursuant to the provisions of 10 CFR 2.201, APS'esponse is attached.Appendix A to this letter is a restatement of the Notice of Violation.

APS'esponse is provided in Attachment 1.Should you have any questions regarding this response, please contact me.Very truly yours, WFC/TRB/RJR/dmn Attachments 1.Appendix A-Notice of Violation 2.Attachment 1-Reply to Notice of Violation cc: J.B.Martin D.H.Coe'7r~Oc~03OOIL Q I?'~?Q g,?~PDh ADDGK 05opp:>~@Q PDi",

APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION 50-529/9145-05 NRC INSPECTION CONDUCTED SEPTEMBER 8,'1991-OCTOBER'I2, l991 INSPECTION REPORT NO, 50-529/91-35 l l ll i l l RESTATElVIENT OF NOTICE OF VIOLATION 50-529 91-35-05 During an NRC inspection conducted on September 8, 1991, through October 12, 1991, one violation of NRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C-(1991), the violation is listed below: A.Paragraph 2E of Facility Operating Ucense No.NPF-51 for the Arizona Public Service (APS)Palo Verde Nuclear Generating Station, Unit 2, states, in part: "APS shall fully implement and maintain in effect all provisions of the Commission-approved physical security...

plan, including amendments made pursuant to...the authority of 10 CFR 50.90 and 10 CFR 50.54(p)." The licensee's approved"Palo Verde Nuclear Generating Station Security Plan," dated October 1979, as amended, at Section 1.6.1.2 (entitled'Vital Areas/Island")states, in part, that temporary access may be authorized to specific vital areas provided that: "...3)The visitor is escorted and monitored by an individual possessing unescorted access status...".

Section 1.6.1.3 (entitled"Escorts")further requires that: "1)All escortees remain in view of the Escorts, and 2)The Escort can provide positive control over the escortees." Contrary to the above, at about 2:00 p.m.on October 7, 1991, the escort of a visitor left the visitor unescorted in the"D" Vital DC Equipment Room of.the Unit 2 Control Building.This is a repeat Severity Level IV Violation (Supplement III)applicable to Unit 2.Page 1 I!I l ATl ACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-529/915%5 NRC INSPECTION CONDUCTED SEPTEMBER 8, 1991-OCTOBER 12, 1991 INSPECTION REPORT NO.50-529/915 f j 1 l Reason for the Violation At the time of this event, the escort was providing instructions at an open door to personnel on opposite sides of a wall.The act of providing instructions to workers on one side of the wall caused the escort to momentarily lose sight of the visitor on the other side of the wall.Although momentary loss of sight did occur, the escort was aware of the visitor's assigned activities and was positioned in the doorway such that unauthorized 7 activities could not have gone undetected.

Thus, in accordance with the security plan, control was maintained.

Each badge provided to escorts includes the following written responsibility;"I am accepting responsibility for escorting the visitor into authorized areas only and will keep him/her in sight and control at all times." Thus, the instructions to keep the person in sight at all times is clearly delineated to the escort.In this case, the escort did converse with personnel on the other side of a wall from where the visitor was located which constitutes a"loss of sight." Therefore, the reason for the violation was that the escort was not cognizant of the fact that visitors out'of line of sight,.even momentarily, constitutes a violation of the Security Plan.Page 2 f 1 il ii Corrective Ste s That Have Been Taken and Results Achieved The requirement of the Security Plan for"...escortees remain in view of the escorts" was discussed with the affected department personnel.

The individual assigned escort duties at the time of the event was counselled in accordance with the APS positive discipline program.As a result of this event, APS has taken the opportunity to reinforce the visitor control requirements to site personnel through the Palo Verde Employee News Bulletin.Corrective Ste s That Will Be Taken to Avoid Further Violations APS believes that the visitor control program is well defined and increased programmatic controls would not provide greater assurance that visitor control would improve, This particular instance, and the two instances referenced In Inspection Report 50-528/91-04, represent implementation problems of the visitor control program.Although APS'nvestigation of this incident identified that control was never lost, APS has taken this opportunity to reinforce the visitor control requirements as stated in the previous section.No further actions are planned at this time.Page 3 P~0 I I I 0 Date WlIen Full Cpm liance Will Be Achieved 3 Full compliance was achieved on October 7, 1991, when the definition of"all escortees remain in view of the escort" was explained to the escort and complied with.Page 4 1 b fl