ML17313A528
| ML17313A528 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/04/1998 |
| From: | Ryan S ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IA-98-015, IA-98-15, NUDOCS 9808130082 | |
| Download: ML17313A528 (7) | |
Text
e CATEGORY 1~
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9808130082 DOC.DATE: 98/08/04 NOTARIZED: YES 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 Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION RYAN,S.W.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Responds to NRC 980710 ltr re violations noted in insp repts 4-97-022S
&, 4-98-014.Corrective actions:steps taken to address NOV were stated in presentation at 980331 predecisional enforcement conference.
DISTRIBUTION CODE: IE54D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Region Response to Licensee re Allegations (Publicly Avail)
T E~
NOTES: STANDARDIZED PLANT Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PD4-2 LA FIELDS M COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD4-2 PD COPIES LTTR ENCL 05000528 05000529 p 05000530 R
INTERNAL.
ER NRR/DRPM/PECB RGN4 FILE 01 NRR/DRPM RES/DET/EIB D
EXTERNAL: NOAC NRC PDR Q
i C
V E
N.
NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTETH TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 Q
TOTAL NUMBER OF COPIES. REQUIRED LTTR 10 ENCL
L
Arizona Public Service Co.
P.O. Box 52034; M.S. 7050 Phoenix, Arizona 85072-2034 August 4, 1998 ID¹ 471-00526-SSB/SWR U. S. Nuclear Regulatory Commission ATTN.: Document Control Desk Washington, D.C. 20555
Subject:
Reply to a Notice ofViolation (NRC Investigation Report Nos. 4-97-022S and 4-1998-014)
To whom it may concern:
I am submitting this response in compliance withNRC letter IA98-015 dated July 10, 1998 and the associated Notice ofViolation Re: the investigation reports noted above. I have been requested to respond to four specific aspects ofthe, violation: (1) the reason for the violation, or, ifcontested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that willbe taken to avoid further violations, and (4) the date when full compliance willbe achieved.
This letter refers to and relies on material previously presented to the NRC in my interview with OI and my presentation at the March 31, 1998 predecisional enforcement conference held in
'rlington, Texas.
1.
Reason for The Vi lation I do not contest the violation. Further, I deeply regret my involvement in the incident leading to the NOV. I believe my previous testimony and correspondence, as set forth in the materials referred to above, have provided a complete and accurate accounting as to my recollections for the reasons behind this violation. To avoid being redundant I rely on the information already provided to the NRC to address the reasons for the violation.
r 2.
rrective S e n
Re ul The corrective steps taken to address the NOVwere stated in my presentation at the March 31, 1998 predecisional enforcement conference.
The detail conditions ofthe corrective action steps have not changed and therefore to discuss them again would only be redundant. I have completed preparation and delivery offormal presentations and discussions regarding this incident with site personnel in the followingdepartments:
Site Maintenance, Site Chemistry, Site Engineering, Procurement and Supply, Water Reclamation, and Operations Support. With regard to the results 9808i30082 980804 PDR ADOCK 05000528 6
4
achieved through the corrective measures, this incident and its repercussions continue to act as a constant reminder ofmy error injudgment as well acting to continually reinforce my obligation to fullydischarge my duties in accordance with regulatory requirements when acting as an employee in the nuclear industry and more specifically as a licensed operator. I have received numerous notes offeedback regarding the presentations made to plant personnel, indicating the presentations have had a profound impact on plant personnel in a way no other presentation regarding personal integrity and documentation requirements ever has. I believe hearing directly from and talking to the individuals involved has had a much greater positive influence than a simple third party presentation could possibly achieve.
3.
te s t Avoid Further iol i ns The steps for my remediation outlined in my presentation at the March 31, 1998 predecisional enforcement conference have had a profound effect on me and willcontinue to have that effect for the rest ofmy working life. These steps collectively serve to ensure that Iwillnever knowingly be involved in any violation, deliberate or otherwise, ever again. Additionally, as noted in Mr.
MerschofPs letter ofJuly 10, 1998, should I ever reapply for Part 55 licensed-operator status, my application must address and willface review under 10 CFR)55.31(b).
- 4. ~C Allmeasures specified in my plan for remediation as presented at the March 31, 1998 predecisional enforcement conference, other than those specific to the APS disciplinary policies and actions that are in effect for a year or more, are complete.
The remainder ofthe disciplinary actions willbe completed by February 10, 2000. Mr. MerschofF s letter ofJuly 10 indicates that the Commission regards these measures to be sufficient. Thus, I believe that from the Commission s standpoint, and to the extent that this concept can be applied to an individual enforcement action, full compliance has been achieved.
Iwillbe pleased to respond to any further questions you may have.
Sincerely yours, Stephen W. Ryan Maintenance Senior Advisor Arizona Public Service Co.
U.S. Nuclear Regulatory Commission July 28, 1998 Page 3 AFFIRMATIONOF STEPHEN W. RYAN County of State ofArizona
)
I hereby swear, under penalty ofperjury, that the statements I have made in this letter are true and correct.
S phenW.Ry Subscribed and sworn to before me this 4
- ofAugust, Notary Pub My commission expires o%ctat. a Eat.
EY LOVELESS otaty Public-State ot arizona MARICOPACONgy MyComm.
i une p, 2OOp CC:
Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 611 Ryan Plaza Dr. Suite 400 Arlington, Texas 76011-8064