ML17312A727
| ML17312A727 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/22/1996 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9604300405 | |
| Download: ML17312A727 (14) | |
See also: IR 05000528/1995024
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UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZADRIVE, SUITE 400
ARLINGTON,TEXAS 76011 6064
APR 22 S96
Arizona Public Service
Company
ATTN:
William L. Stewart
Executive Vice President,
Nuclear
P.O.
Box 53999
Phoenix,
85072-3999
SUBJECT:
NRC
INSPECTION REPORT 50-528;529;530/95-24
Thank you for your letter of February
28,
1996, in response
to our letter and
Notice of Violation, dated January
22,
1996.
In your response,
you stated
that Violations A and
B should
be considered
as advisory issues
since there
were no regulatory criteria which could be used to prevent these types of
failures.
We have conducted
a careful
review of the violations and your response.
This
review included
an assessment
of the violations by the Office of Nuclear
Reactor Regulation.
A detailed discussion of our resolution of your concerns
is enclosed.
Our review determined that the violations did occur;
however.
we agree that
the breech of Zones
14A and
21 (via
a "three-man
jump") are beyond the current
regulatory criteria.
Therefore,
these
examples
are hereby deleted
from the
Additionally, in a telephone
conversation
between
Ms. A. Krainik, of your
staff,
and Mr. K.
E.
Brockman,
Deputy Director, Division of Reactor Safety.
you requested
a meeting to discuss
the NRC's Regional Assist and Operational
Safeguards
Response
Evaluation inspections.
We have tentatively scheduled
'his meeting for 1 p.m.
~
on June
6,
1996, at the Region
IV office in
Arlington. Texas.
In closing'ou are required to respond to Violations A and
B, as outlined in
our letter and Notice of Violation, dated January
22,
1996,
and
as revised
by
this letter.
We will review the implementation of your corrective actions for
Violation C during
a future inspection to determine that full compliance
has
been achieved
and will be maintained.
Sincerely,
Enclosure:
As stated
T omas
P.
,
rector
ivision of Reactor
Safety
9604300405
960422
ADOCK 05000528
8
0
Arizona Public Service
Company
Dockets:,
50-528
50-529
50-530
Licenses:
NPF-51
cc w/enclosure:
Arizona Corporation
Commission
ATTN:
Mr. Steve
Olea
1200
W. Washington Street
Phoenix,
85007
Southern California Edison
Company
ATTN:
T.
E. Oubre.
Esq.
P.O..
Box 800
Rosemead,
91770
Arizona Radiation Regulatory Agency
ATTN:
Aubrey V. Godwin, Director
t
4814 South
40 Street
Phoenix,
85040
Maricopa County Board of Supervisors
ATTN:
Chairman
111 South Third Avenue
Phoenix,
85003
Arizona Public Service
Company
ATTN:
Angela
K. Krainik, Manager
Nuclear Licensing
P.O.
Box 52034
Phoenix,
85072-2034
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Arizona Public Service
Company
-3-
E-Mail report to D. Nelson
(DJN)
E-Hail report to NRR Event Tracking System
(IPAS)
bcc to DHB (IE01)
bcc distrib.
by RIV:
L. J. Callan
DRP Director
Branch Chief (DRP/F,
WCFO)
Senior
Project Inspector
(DRP/F,
WCFO)
Branch Chief (DRP/TSS)
Leah Tremper
(OC/LFDCB,
HS:
TWFN 9E10)
DRS AI 96-G-0012
Resident
Inspector
DRS-PSB
HIS System
RIV File
H.
Hammond
(PAO.
WCFO)
30 O 0 Q 3
DOCUMENT NAME:
G:KDRSLTRSNPV524AK.ABE
To receive copy of document, indicate In box: "C" = Copy without endosures
"E" = Copy with enctosures "N" = No copy
I: PSB
BEarnest:cg
04/I f/96
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Arizona Public Service
Company
-3-
E-Mail report to D. Nelson
(DJN)
E-Hail report to
NRR Event Tracking System
( IPAS)
bcc to
DMB (IE01)
bcc distrib,
by RIV:
L. J. Callan
DRP Director
Branch Chief (DRP/F.
WCFO)
Senior Project Inspector
(DRP/F,
WCFO)
Branch Chief (DRP/TSS)
Leah Tremper
(OC/LFDCB.
HS:
TWFN 9E10)
DRS AI 96-G-0012
Resident
Inspector
DRS-PSB
HIS System
RIV File
H.
Hammond
(PAO,
WCFO)
DOCUMENT NAME:
To receive copy of document, Indicate In box: "C" = Copy without enciosures
"E" = Copy with enclosures "N" = No copy
I: PSB
E
C:PSB
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D:DRS
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BEarnest:cg
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ENCLOSURE
VIOLATION A:
INADE UATE PROTECTED
AREA DETECTION SYSTEM
LICENSEE'S POSITION:
Zone
1 - The response to the violation states'
Issue:
Since
does not'identify a target velocity for E-field,
PVNGS. after discussion
with the manufacturer,
is applying the same target velocity used for
microwave to its E-field testing criteria.
Therefore.
using this
criteria. the test conducted
on Zone
1 was performed below the minimum
detection velocity."
RESPONSE:
One person crawled under the E-field wi res.
The licensee's
Station
Guidance is silent
on crawl speed
under the E-field, as is Regulatory
Guide 5.44.
However the manufacturer's
E-field Systems
Operations
Manual specifies crawling less than
3 centimeters
per second.
Prior to
receiving
a violation, the licensee staft
made
no mention of velocity
for the E-field in their testing guidance,
but upon receiving
a
violation, they substituted
a lesser
testing standard
than that which
the manufacturer
prescribed
based
on an oral concurrence of a
manufacturer's
representative.
The licensee
then indicated that they
measured
the crawling velocity to four decimal places,
although the
inspectors
and contractor staff did not notice any time or distance
measurements
being taken in the zone during the tests.
Further, the
licensee's
test procedure calls for crawling "thru the
2 bottom
wi res
.
.
. ."
The physical security plan states that the E-field
system "is designed to detect
an individual
.
.
. crawling and rolling
under the lower sensing wire, stepping
.
.
. between the field and
sensing
wires,
or jumping over the top sensing wire. "
The test
procedure
appeared
inconsistent
(and insufficient) with the physical
security plan requirements.
LICENSEE 'S POSITION:
Zones
14A and
21 - The response
to the violation states,
"Issue:
The
test conducted
on Zone
14A (and Zone 21) was performed in a method that
circumvented the ability of the zone to detect intrusion.
The test
consisted of one individual climbing on to the shoulders of the other
two individuals. thus elevating
him to a height from which he could jump
over the zone of detection
and land on unstable
ground.
The issue is
the height to which a zone must be able to detect.
NRC regulations
and
other guidance
are silent on the issue of height."
RESPONSE:
As the licensee
notes,
height of detection in not specified in guidance.
Neither is it specified in the physical security plan which requires
that the system
be "designed to detect
a
.
.
. jumping intruder
The test conducted
was within the design basis threat
capabilities.
The tests
conducted utilizing this methodology resulted
in numerous
zones
adequately
detecting the jumper.
It was only in two
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of the zones
where the height of the microwave heads,
the direction the
heads
were pointed.
or
some other vulnerability, resulted in a failure
to detect.
The jumps were
made from an approximately
4 1/2 to 5 foot
height.
It is not unreasonable
to expect
a zone to detect the jumping
tester
as indicated
when many of the zones did detect the jumper.
However, since this particular test is beyond the regulatory criteria
and the height of microwave zones
are not specified in regulatory
guidance,
these
zones will be removed from the violation.
LICENSEE 'S POSITION:
Zone
15 - The response to the violation states,
"Issue:
The test
conducted in Zone
15 was performed below the minimum detection velocity
as specified
by Regulatory Guide 5.44 and
PVNGS testing procedures."
RESPONSE:
The test conducted
consisted of one individual climbing a structure,
and
maneuvering
through barriers to avoid the zone of'etection.
A review
of video tapes
taken by the test personnel
appeared to corroborate the
licensee's
statement that the climber avoided the zone of detection.
Thus, the velocity issue is irrelevant in the case of Zone
15 as the
testers
(according to the licensee's
reply) avoided the zone of
detection.
It was apparent to all the testers that installation of
Zone
15 had left a hole in detection
and it would not matter what speed
the tester
went through the detection
zone because
there
was
no
detection
zone where the perimeter
area
was defeated.
This climbing
test
was repeated,
at the licensee's
request. 'after more barrier
material
(razor
ribbon and barbed wire) was added.
The second climbing
test
was also undetected.
GENERAL DISCUSSION:
Physical Security Plan,
paragraph
12.1 states,
"Security equipment tests
and inspection shall
be performed in accordance
with Regulatory
Guide 5.44 for perimeter intrusion equipment
and manufacturer's
recommendations
for the balance of security equipment."
Paragraph
12.6,
which is specific to the perimeter detection
system, specifically only
commits to the Regulatory Guide 5.44 criteria of Appendix A, Background
paragraphs
1,2,
and 3.
In addition paragraph
12. 1 states
that
manufacturer's
recommendations will be used for the balance of security
equipments
specifically excluding the perimeter detection
systems.
According to the above,
the staff concludes
the commitments in the
physical security plan are confusing
and contradictory.
The testing
procedure
requirements
in your reply would indicate
a compliance
based
program.
,
1
I
)
'
segments.
Your criteria requires only 90K detection
and does not
require all of the detection
system to be operability tested
every
7 days
as
does the requirement in Regulatory Guide 5.44.
VIOLATION B:
INADE UATE COMPENSATORY MEASURES
LICENSEE 'S
POSITION:
The response to the violation states,
"Issue:
The test conducted
on
Zone
15 was performed below the minimum detection velocity as specified
by Regulatory Guide 5.44 and
PVNGS testing procedure.
The removal of
established
compensatory
measures
in Zone 15, after the initial test,
was based
on successful
completion of intrusion detection
system testing
in accordance
with PVNGS operating
procedures
which are developed
using
regulatory guidance
and manufacturers
specifications."
RESPONSE:
Upon the discovery that there
was
a hole in alarm zone coverage in
Zone 15, procedural
requirements,
(Station Security Procedure
20SP-
OSK08, paragraph
3.7. 1) clearly states that
a posted
member of the
tyf
fll
d
t f
flit
~tif
~re aired.
Given that the denial of the portion of the detection aids
violation pertaining to Zone
15 has not been accepted,
and the licensee
removed the compensatory
measure
before the hole in coverage
was
adequately
repaired.
the licensee
was in noncompliance.
At the request
of the licensee.
an additional test revealed that the repair/corrective
action was inadequate to close the hole in coverage.
The licensee tests
did not replicate the intrusion path or method which had originally
ci rcumvented the zone of detection.
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