ML17312A866
| ML17312A866 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/18/1996 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9607250112 | |
| Download: ML17312A866 (21) | |
Text
CATEGORY j.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9607250112 DOC.DATE: 96/07/18 NOTARIZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclea Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION STEWART,W.L.
Arizona Public Service Co. (formerly Arizona Nuclear power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to NRC 960621 ltr re violations noted in insp repts 50-528/96-08,50-529/96-08
& 50-530/96-08 on 960513-17.C/A:suspended individual unescorted access.
DISTRIBUTION CODE:
ZEOID COPIES RECEIVED:LTR I
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/0 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response E
NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
05000528 05000529 05000530 INTERNAL:
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NRR/DRPM/PERB OE DIR RGN4 FILE 01 COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME CLIFFORD,J AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL 1
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EXTERNAL: LITCO BRYCESJ H
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN, SD-5(EXT. 415-2083)
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TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 20
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Arizona Public Service PALO VERDE NUCLEAR GENERATING STATION P.O. BOX 52034 PHOENIX. ARIZONA 85072.2034 WILLIAML. STEWART EXECUTIVEVICEPRESIDENT NUCLEAR U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001 102-03737-WLS/AKK/DRL July 18, 1996
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 60-628/529/630 Reply to Notice of Violation 50-528/629/530/96-08-01 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/96-08 and the Notice of Violation (NOV) dated June 21, 1996.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
Enclosure 1
to this letter is a restatement of the NOV. APS'esponse is provided in Enclosure 2.
APS continues to express that this violation meets the criteria to not be cited.
Furthermore, the NRC Inspection Report discusses possible willful omissions of information by the access applicant; APS restates that given the information that PVNGS had compiled from available sources, including law enforcement agencies, and in accordance with regulations and site procedures, there is no evidence to prove a willfulomission of information.
Therefore, this individual would not have been denied unescorted access.
The second issue involved the granting of unescorted access and issuance of a badge prior to obtaining the final authorizing signature on the access authorization form.
Although it is true that a
violation was identified in NRC Inspection Report 528/529/530/95-11(sic),
APS agrees with the NRC that the circumstances were not identical.
However, the project does not agree that the corrective actions to the problem previously identified would have precluded this occurrence since the previous incident was corrected by putting in place a second person verification, and this incident involved a training deficiency for temporary access authorization personnel.
9607250ii2 9607i8 PDR ADQCK 05000528 8
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notice of Violation 50-528/529/530/96-08-01 Page 2 Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421.
Sincerely, WLS/AKK/DR L/pv Enclosures
- 1. Restatement of Notice of Violation
- 2. Reply to Notice of Violation cc:
L. J. Callan C. R. Thomas K. E. Johnston K. E. Perkins
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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-528/529/530/96-08-01 NRC INSPECTION CONDUCTED MAY13 THROUGH MAY17, 1996 INSPECTION REPORT No. 50-528/529/530/96-08
OL During an NRC inspection conducted on May 13-17, 1996, three examples of a violation of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30, 1995)(sic), the violation is listed below:
Paragraph 2.E. of the Facility Operating License NPF-41 for Palo Verde Nuclear Generating Station requires the licensee to fullyimplement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans, including all amendments to those plans made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55, and pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54 (p).
Paragraph 1.3.1 of the licensee physical security plan requires the access authorization program to meet the requirements of Regulatory Guide 5.66.
Regulatory Guide 5.66, under Clarification to the Guidelines, paragraph 2, states that, while it is permissible to grant temporary unescorted access for 180 days, a licensee cannot grant back-to-back temporary unescorted access.
Paragraph 3.11.1 of Procedure 20AC-OSK07 states "Atemporary authorization for unescorted access to the ProtectedNital areas of PVNGS may be granted for a single 180-day period pending completion or collection of information required for permanent authorization."
Paragraph 3.7.4 of Procedure 20AC-OSK07 states "In determining whether an individual is trustworthy and reliable, specific consideration must be given to any of the following which is revealed in the security screening process:
Willfulomission or falsification of material information submitted in support of employment or request for unescorted access authorization."
Paragraph 3.1 of Licensee Procedure 20DP-OSK18 requires that the request for unescorted access be signed by only certain responsible individuals prior to issuing a badge/keycard.
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Paragraph 3.2.1.8 of the Licensee Procedure 20AC-OSK07 states "The individuals reputation for emotional stability, reliability, and trustworthiness shall be examined through contacts with at least two references supplied by the individual requesting access and at least two additional references developed during the background investigation."
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Contrary to the above: (1) On October 18, 1995, the licensee incorrectly granted back-to-back temporary unescorted access to an individual who may have willfullyomitted or falsified information. This individual was previously granted temporary unescorted access between July 14 and August 9, 1994. (2) During a review of access authorization records, the licensee discovered and reported an incident where an employee was granted unescorted access and his background screening records did not indicate a developed reference. A developed reference was, subsequently, contacted and the employee was again allowed unescorted access.
(3) A safeguards event report dated March 14, 1996, indicated that an employee had been granted unescorted access and issued a badge prior to getting an authorized signature on the access authorization documents. A similar violation was identified in NRC Inspection Report 50-528/95-11; 50-529/95-11; 50-530/95-11.
This is a Severity Level IVviolation (Supplement III).
ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION50-528/529/530/96-08-01 NRC INSPECTION CONDUCTED MAY13 THROUGH MAY17, 1996 INSPECTION REPORT Nos. 50-528/529/530/96-08
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E L C 0 OL 0-2 96-The violation occurred due to a screening analyst failing to verify that the previous full background investigation had been completed.
The verification should have been accomplished by reviewing the individual's screening file to ensure the required elements were completed prior to granting unescorted access.
On March 18, 1996, a screening analyst conducting a secondary review of the individual's file could not locate a developed reference form for the temporary unescorted access granted on September 26, 1995. The analyst suspended the individual's unescorted access and logged the incident in accordance with 10 CFR 73.71. During the subsequent investigation of the incident,.it was discovered that a developed reference had been contacted and documented prior to granting unescorted access on September 26, 1995. The developed reference was re-contacted and stated that he remembered answering the reference questions. The developed reference form was re-created on March 22, 1996. At this time, the incident was not classified as a violation, and the 10 CFR 73.71 event was'de-classified.
The investigation revealed that the original developed reference form had been lost, and that the developed reference, in fact, had been contacted prior to granting unescorted access.
On 03/13/96, the Authority for Unescorted Access to Protected/Vital Areas (AVA) form was completed except for the authorization signature.
This form was passed from one access authorization section employee to another in a stack of paperwork that was completed except for the final review. The employee receiving the paperwork was a temporary access authorization employee who misunderstood and thought that the only thing that needed to be accomplished was a check of the review that had been accomplished by the previous access authorization employee.
This temporary access authorization employee was not fullyaware of the 1995 corrective action to perform a final review of the AVA,and the contract employee's access was granted.
Co eve The individual's unescorted access was suspended, the event was logged in accordance with 10 CFR 73.71, and an investigation was initiated in accordance with the PVNGS incident investigation program. The temporary access authorization screener was counseled on the correct way to complete the final review and instructed that any outstanding or unresolved issues would be brought to the access control section leader or designee for final disposition. No other incidents have occurred.
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,0 Ifit is identified that a developed reference form is missing or lost, the same process as described in the reason for the violation willbe followed. The individual's access willbe removed, the event willbe logged in accordance with 10 CFR 73.71, and a developed reference willbe contacted. Additionally, the access authorization personnel were re-instructed on the importance of maintaining documentation required for granting unescorted access.
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c The access control section leader re-emphasized the importance of attention to detail, and the temporary access authorization employee was instructed on the proper verification process prior to activation of unescorted access.
V'ased on the corrective steps that have been taken, no further action is required.
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D Based on the corrective steps that have been taken, no further action is required.
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i Based on the corrective steps that have been taken, no further action is required.
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B Full compliance was achieved on October 25,
- 1995, when the individual's unescorted access was removed.
Full compliance was achieved on March 22, 1996, when the developed reference form was re-created.
i n Full compliance was achieved on March 14, 1996, when the final authorization signature was obtained on the AVAform.
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