ML17306A303
| ML17306A303 | |
| 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) |
| References | |
| 102-02087-WFC-T, 102-2087-WFC-T, NUDOCS 9112120198 | |
| Download: ML17306A303 (16) | |
Text
ACCELERATED.DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9112120198 DOC.DATE: 91/12/09 NOTARIZED: NO DOCKET CIL:STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 911108 ltr re violations noted in Insp Rept t50-529/91-35,->on 910908-1012.Corrective actions: visitor control requirements for site personnel reinforced through plant employee news bulletin.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED-LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response D
NOTES:Standardized plant.
RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME TRAMMELL,C COPIES LTTR ENCL 1
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INTERNAL:
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NOTES ACRS AEOD/DEIIB DEDRO NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12
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NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS 1 RGN5 FILE 01 NRC PDR 1
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NOTE TO ALL"RIDS" RECIPIENTS:
D D
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LIFKFOR DOCUMENTS YOU DON'T NEED!
OTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL 26
'l I
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
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PHOENIX, ARIZONA85072-3999 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:
SUBJECT'ALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION50-529/91-3&05 File: 9170-026 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 Appendix A - Notice of Violation 2.
Attachment 1 - Reply to Notice of Violation cc:
J. B. Martin D. H. Coe t 20'."-
pgg2g20<98 pDR goocK 05000529 PDR
APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION 50-529/915%5 NRC INSPECTION CONDUCTED SEPTEMBER 8, 1991-OCTOBER 12, 1991 INSPECTION REPORT NO. 50-529/91-35
C
RESTATEMENT OF NOTICE OF VIOLATION 50-529 91-355 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 License 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) Allescortees 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 IVViolation (Supplement III) applicable to Unit 2.
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ATTACHMENT1 REPLY TO NOTICE OF VIOLATION 50-529/915%5 NRC INSPECTION CONDUCTED SEPTEMBER 8, 1991-OCTOBER 12, 1991 INSPECTION REPORT NO. 50-529/915
0
VIOLATION60-629 94-3&0 Reason for he 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 ofthe wall caused the escort to momentarily lose sight ofthe 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 activities could not have gone undetected.
Thus, in accordance with the security plan, control was maintained.
Each badge provided to escorts Includes the followingwritten 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 ofthe fact that visitors out of line of sight, even momentarily, constitutes a violation of the Security Plan.
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Corrective Ste That Have Been Taken n
Re u 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.
rre lv e
Tha Wilt 8 Taken t Avol F rther Violation 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 ofthis 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.
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Date When Full om llance Will Be Achieve Full compliance was achieved on October 7, 1995, when the definition of "all escortees remain in view of the escort" was explained to the escort and complied with.
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