ML17313A969
| ML17313A969 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/08/1999 |
| From: | Stewart S NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Beckman V AFFILIATION NOT ASSIGNED |
| References | |
| CON-FIN-J-2548, CON-NRC-03-98-021, CON-NRC-3-98-21 NUDOCS 9906140167 | |
| Download: ML17313A969 (18) | |
Text
Beckman and Associates, Inc.
ATTN: Vicki Beckman 1071 State Route 136 Belle Vernon, PA 15012 4N D3 NQ c
o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 cy t5 I>,8 S&g'sc
SUBJECT:
TASK ORDER NO. 042, "PALO VERDE SAFETY SYSTEM ENGINEERING INSPECTION (SSEI)" UNDER CONTRACT NO. NRC-03-98-021
Dear Ms. Beckman:
In accordance with Section G.5, Task Order Procedures, of the subject contract, this letter definitizes the subject task order. The effort shall be performed in accordance with the enclosed Statement of Work.
Task Order No. 042 shall be in effect from June 3, 1999 through July 15, 1999, with a total cost ceiling of$79,153.32. The amount of$76,661.81 represents the estimated reimbursable costs and the amount of $2,491.51 represents the fixed fee.
Accounting data for Task Order No. 042 is as follows:
B8R No.:
Job Code:
BOC:
APPN No.:
FFS¹:
Oblig. Amt.:
920-15-103-105 J-2548 252A 31X0200.920 NRR98021042
$79,153.32 The fottowtng individuals are considered to be essential to the successful performance of work
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hereijnder:
Mr. Robert Quirk and Mr. Michael Shlyamberg.
The Contractor agrees that such personnel shall not be removed from the effort under the task order without compliance with C <<CI
~.
The issuance of this task order does not amend any terms or conditions of the subject contract.
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Your contacts during the course of this task'order are:
Technical Matters:
~ Edmund Kleeh Project Officer (301) 415-2964 Contractual Matters:
Mona Selden Contract Specialist (301) 415-7907 Acceptance of Task Order No. 042 should be made by having an official, authorized to bind your organization, execute three copies of this document in the space provided and return two copies to the Contract Specialist.
You should retain the third copy for your records.
Sincerely, tgharon D. Stewart, Contracting Officer Contract Management Branch 2 Division of Contracts and Property Management Office of Administration
Enclosure:
Statement of Work ACCEPTE 'ask Order
. 042 NAME TITLE DATE
~CONTRACT NRC-03-98-021 STATEMENT OF WORK Task Order 042 Revision 0 A
V TITLE: Palo Verde Safety System Engineering Inspection (SSEI)
DOCKET NOMBER: 50-528/529/530 B8 R NUMBER: 920-15-103-105 JOB CODE: J-2548 INSPECTION REPORT NUMBER:
NRC PROJECT OFFICER:
E. A. Kleeh, NRR (301) 415-2964 TECHNICALMONITOR:
Rebecca Nease, Region IV (817) 860-8154 PERFORMANCE PERIOD:
June 3, 1999-July 15, 1999 BACKGROUND A Safety System Engineering Inspection (SSEI) will be conducted for the Palo Verde nuclear plant near Phoenix, Arizona.
The SSEI will assess the operational performance capability of selected safety system(s) to verify that the system is capable of performing its intended safety function.
The inspection will assess the licensee's engineering effectiveness through an in-depth review of calculations, analysis, and other engineering documents used to support system performance during normal and accident or abnormal conditions.
The inspection will also verify completed actions for regulatory commitments that the licensee made in conjunction with the safety systems.
Review of safety systems is to be performed in accordance with NRC Ihspection Procedure 93809 for a Safety System Engineering Inspection (SSEI).
OBJECTIVE The objective of this task order is to obtain expert technical assistance in the areas of electrical/18C and mechanical design. The specialists are needed to assist the NRC inspection team in the performance ofthe SSEI. The electrical/l8C and mechanical specialists should primarily have a design background, such as from an architect-engineer firm with experience in electrical power systems design bases and thermal/fluids system operational requirements, respectively.
The specialists should also be familiar with installation and suiveillance testing of equipment along with cognizance of how site engineering and operations organizations function. The specialists should be thoroughly familiar with NRC regulations and inspection methodology. Also, the specialists should be familiarwith the regulatory process, and should be able to develop a list of regulatory commitments from docketed licensee correspondence for the plant system(s) selected for review. The specialists willthen be required to verify implementation of the licensee's commitments.
It shall be the responsibility of the contractor to assign technical staff, employees, and subcontractors, who have the required educational background, experience, or combination thereof, to meet both the technical and regulatory objectives of the work specified in this Statement Of Work (SOW). The NRC will rely on representation made by the contractor concerning the qualifications of the personnel proposed for assignment to this task order including assurance that all information contained in the technical and cost proposals, including resumes and conflict of interest disclosures, is accurate and truthful.
N WORK REQUIREMENTS AND SCHEDULE The contractor shall provide the qualified specialists, and the necessary facilities, materials, and services to assist the NRC staff in preparing for, conducting, and documenting the inspection activities and findings.- The contractor shall provide the latest rad-worker training amd MMPItest dates ofthe specialists that willassist in the SSEI at Palo Verde. The Technical Monitor/Team Leader forthis task is Rebecca Nease. The Technical Monitor may issue technical instructions from time to time during the duration of this task order.
Technical instructions must be within the general statement of work stated in this task order and shall not constitute new assignments of work or changes of such nature as to justify an adjustment in cost or period of performance.
The contractor shall refer to the basic contract for further information and guidance on any technical directions issued under this task order.
Any modifications to the scope ofwork, cost or period of performance ofthis task order must be issued by the Contracting Officer and will be coordinated with the NRR Project Officer. Specific tasks under this task order are:
Task Schedule Com letion Develop a listofregulatory commitments for the selected plant system(s) based upon a review of docketed information.
Prepare an inspection plan and obtain a thorough understanding of the selected system(s).
Inspection preparation willtake place at the Region IV office in Arlington, Texas on or about June 7-11, 1999.
2.
Perform the inspection.
On-site inspection is to take place on or about June 14-18; and on or about June 28-July 2, 1999.
Review of documentation, licensee inquiries, and other inspection-related activites will be conducted in contractor's home offices during on or about June 21-25, 1999..
3.
Prepare the inspection report.
Documentation of inspection willtake place on or about July 5 thru July 9 in contractor's homeoffice.
Final inspection report input is due on or about July 12, 1999.
NOTE: Prior to the start of on-site preparation, the contractor's staff is required to be available to coordinate inspection aspects, such as travel logistics, with the Team Leader.
REPORT RE UIREMENTS At the completion of Task 1, the contractor's specialist shall provide an inspection plan to the NRC Team Leader.
The format and scope of this input shall be as directed by the NRC Team Leader.
During Task 2, the contractor's specialist shall provide daily reports to the NRC Team Leader. The format and scope of this report shall be as directed by the NRC Team Leader.
Atthe completion ofTask 2 (priorto the inspection team's exit meeting with the licensee), the contractor's specialists shall provide a draft inspection report input to the NRC Team Leader. The format and scope shall be as directed by the NRC Team Leader.
Typically, this input willconsist of a handwritten summary of the specialist's inspection findings.
Atthe completion ofTask 3, the contractor shall deliver the final inspection report input (feeder report) to the NRC Project Officer (original and one copy) with one hard copy and one computer diskette version (WordPerfect 5.1/6.1 or other IBM PC patible software acceptable to the NRC Team Leader) to the NRC Team Leader.
The format and scope of the corn db final report inputs shall be in accordance with the guidance in NRC Inspection Manual Chapter 0610 or as directe y
2
the NRC Team Leader.
A specialist's feeder report willserve as documentation of-the specialist's inspection activities, effort, and findings, and
'ill be usedby the NRC Team Leader forthe preparation ofthe NRC's inspection report. The form and scope ofthe final report input shall be in accordance with the guidance in NRC Inspection Manual Chapter 0610 or as directed by the NRC Team Leader.
As a minimum, each specialist's report input shall include the following:
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Identity of the individuals (name, company, and title) that provided information to the specialist during the inspection.
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For each area inspected, a description of the activities and general findings and conclusions reached regarding the adequacy of the area.
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For each area with a concern or findings, a discussion of the concerns or findings with technical bases.
NOTE:
The contractor is not required to undertake any further efforts toward report finalization.
For example, management review of the feeder report beyond its submittal to the NRC Team Leader and Project Manager is not needed.
Business Letter Re ort The contractor shall provide monthly progress reports in accordance with the requirements of the basic contract.
MEETINGS AND TRAVEL For estimating purposes only, the following meetings and travel are anticipated One, two-person, 5-day trip to the Region IVoffice to prepare for the inspection (June 7 - 11, 1999).
Off-normal travel permitted up to half-day for each contractor to ensure early arrival at business office on Monday morning.
Two, two-person, 5-day trips to the Palo Verde site to conduct the initial inspection.
(June 14-18, 1999; and June 28-July 2, 1999.
Off-normal travel permitted up to half-day for each contractor to ensure early arrival at plant site office on Monday morning.
The contractor's staff shall coordinate all travel arrangements in advance with the NRC'Team Leader.
NRC FURNISHED MATERIAL Documents required to prepare for the inspection willbe provided by the NRC Team Leader.
OTHER APPLICABLE INFORMATION The work specified in this SOW is 100% licensee fee recoverable.
The contractor shall provide fee recovery information in the monthly progress reports in accordance with the requirements of the basic contract.
The contractor's specialists assigned to this task order willhave to be badged forunescorted access privilege at the plant site. Questions concerning badging and plant site access shall be addressed to the NRC Technical Monitor.
Distri96.txt Distribution Sheet i/sr/~>>
Priority: Normal From:
Andy Hoy Action Recipients:
M Fields Internal Recipients:
RGN4 FILE 01 OE NRR/DIPM/EPHB External Recipients:
NOAC Copies:
1 1
1 1
1 Paper Copy Paper Copy Paper Copy Paper Copy Paper Copy Paper Copy Total Copies:
Item:
ADAMS Document Library:
ML ADAMS"HQNTAD01 ID: 003683177
Subject:
Letter of 24 January 2000 to Gregg Overbeck, Senior Vice President, Ar izona Public Service
- Company, regarding.FEMA's Exercise Evlauation Rep ort of the 9 March 1999 PVNGS Emergency Preparedness Exercise Body:
ADAMS DISTRIBUTION NOTIFICATION.
Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS.
The Document may also be viewed by searching f or Accession Number ML003683177.
IE35 Emergency Preparedness-Appraisal/Confirmatory Action Ltr/Exerci se Rept/Etc.
Docket:
05000528 Docket:
05000529 Page 1
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Docket:
05000530 Distri96.txt Page 2
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RADIATIONREGULATORY AGENCY Jane Dee Huii Governor Aubrey V. Godwin Director 4814 South 40th Street Phoenix, Arizona 85040-2940 (602) 255%845 Fax (602) 437-0705 28 January 2000 Gail M. Good, Chief Plant Support Sranch, Division of Reactor Safety Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Ste. 400 Arlington, TX 76011-8064 Re: Your letter of 24 January 2000 to Gregg Overbeck, Senior Vice President, Arizona Public Service Company, regarding FEMA's Exercise Evaluatio'n Report of the 9 March 1999 PVNGS Emergency Preparedness Exercise
Dear Ms. Good:
Attached please find my letter to James L. Witt, Director, Federal Emergency Management Agency.
You should be aware that the FEMA report has not gone without challenge.
Specifically, I am concerned that the report contains ari entry that is incorrect, a fact that was brought to the attention of the evaluators before issuance of the final report, yet remains in that report.
Further, other statements are included that evaluators said would not appear in the report. This refers to check sources for high range survey meters.
I am further concerned over the apparent disregard of our comments on draft reports and the iack of any diaiog that couid aid in resolving any problems and/or misperceptions.
For the most part, FERA evaluations are fair and reasonable; however, this report struck a nerve, thus the letter to Director Witt.
Should you have any questions, please call me.
Sincerely, Aubrey V. Godwin a.d'~~
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C HADtATIONREGULATORY AGENCY Jane Oee Hull Governor Aubtey V. Godwin Director 4814 South 40th Street Phoenix, Arizona 85040-2940 (602) 255<845 Fax (602) 437-0705 January 24, 2000 Mr. James L. Witt, Director Federal Emergency Management Agency 500 C Street SW Washington, D.C. 20472
Dear Director Witt,
We have recently received FEMA's Final Evaluation Report, dated 14 December
- 1999, for the 9 March 1999 Palo Verde Nuclear Generating Station Offsite Biennial Exercise.
There are some factually incorrect and inaccurate items in the report that need to be addressed.
Under the heading Areas Recommended for Improvement (ARFI), there is a entry referring to silver zeolite cartridges not being available in the field. This is not the case; the Agency individual directly in charge of field operations showed one of the evaluators, Bill Serrano, a case of 24 cartridges in the Agency command vehicle.
These cartridges are carried in that vehicle as a contingency every time it goes to the field for training or for exercises and drills.
In the Planning Issues section, there is an entry taking exception to the fact that there was not a radioactive check source provided in the field to check the high range survey instrument.
These instruments have a range of 0 500 R/hour using multiplier scales.
We would need a check source of sufficient strength to require a license in order to cause the meter needle to deflect upscale far enough to obtain an adequate calibration check, even on the lowest scale.
We do not propose to put licensable sources in our field kits or maintain them at our field command post, both'essentially uncontrolled locations.
These instruments are calibrated annually.and are source checked at our office under controlled conditions before use.
Additionally, Objective 6, Field Radiological Monitoring-Ambient Radiation Monitoring, in REP 14, neither has a specific reference to a high range survey instrument check source as it does for low range GM detectors, nor does it specifically require check sources for any instrument.
Objective 6
- says, in part, "When available, appropriate radioactive check
t
sources...should be used for checking the proper operational response of the survey instruments."
(Emphasis added).
This evaluation comment has been discussed with senior evaluators and our understanding from those discussions is that this item would not appear in the report.
- Moreover, as a matter of comparison, the civil defense high range survey meter, CD V-715, range 0-500 R/hr, over which FEMA had control for both wartime use and peacetime power reactor incident response for many years, never had a check source, nor was one ever required.
To my knowledge, no other state is required to have a check source for high range instruments.
In addition to the above
- comments, we are awaiting the resolution of two planning issues from the evaluated medical exercise held 18 November 1998.
These involved FEMA's recommendation to provide dosimetry and training to Rural Metro Fire Department, the first response organization in the exercise.
Rural Metro provides fire and ambulance service to much of the area around the Palo Verde Nuclear Generating Station; it is a private, for profit, organization.
Compliance with the recommendation would mean expending public monies for private enterprise; this is not permitted in Arizona.
There are several other evaluator comments/recommendations in the 9 March 1999 exercise report that are apparently quite subjective and have no consistency from evaluation to evaluation.
During one exercise, players will perform an action, or not, and there will be no comment.
During the next
- exercise, similar events will occur and there will be evaluation comments.
Our procedures for the conduct of various activities all have reasons supporting them; when a comment is made in a draft report that contradicts what we do and there appears to be no rationale for the comment other than subjectivity, we respond with our reasons for the action.
When there is no change from the draft to the final report, and no dialog acknowledging our response to the draft that would provide a FEMA perspective, I have to wonder ifanyone reads our responses.
In view of the
- above, I respectfully request that the evaluation report be withdrawn pending resolution of the cited issues.
Thank you very much for your attention in this matter.
Aubrey
. Godwin
~ Director pc:
Martha Whetstone, Director, FEMA RIX Tom Ridgeway, RAC Chair, FEMA RIX Richard Echevarria, Evaluation Team Leader, FEMA RIX
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