ML20056G966
| ML20056G966 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/30/1993 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02622-WFC-T, 102-2622-WFC-T, NUDOCS 9309080013 | |
| Download: ML20056G966 (7) | |
Text
.-
l l
u Arizona Public Service Company l
P O. BOX E3999 PHOENIX. ARIZONA 85072-3999 102-02622-WFC/TRB/JJN I
WILUAM F CONWAY August 30,1993 rncow g gesma U. S. Nuclear Regulatory Commission ATTN: Document Control Desk l
Mail Station P1-37 Washington, DC 20555
Reference:
Letter dated July 29,1993, from R. J. Pate, Chief, Safeguards, Emergency Preparedness, and Non-Power Reactor Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
I Units 1,2, and 3 Docket Nos. STN 50-528/529/530-Notice of Violation 50-528/93-31-04 File: 93-070-026
,s Arizona Public Service Company (APS) has reviewed ;NRC inspection Report 50-528/529/530/93-31, and the Notice of Violation, dated July 29,1993. Pursuant to the provisions of 10 CFR 2.201, APS' response is enclosed. Enclosure 1 to this letter is a restatement of the Notice of Violation. APS' response is provided in Enclosure 2.
Should you have any questions, please call Thomas R. Bradish at '(602) 393-5421.
Sincerely,-
l
/
l 0
T WFC/TRB/JJN/rv
Enclosures:
1.
_ Restatement of the Notice of Violation 2.
Reply to the Notice of Violation cc:
B. H. Faulkenberry J
hl J. A. Sloan f?O*30
[
l h
i I
i 1
1 i
l f
i r
J
{
ENCLOSURE 1 i
i RESTATEMENT OF NOTICE OF VIOLATION 1
i 50-528/93-31-04 i
+
t, i
NRC INSPECTION CONDUCTED 4
1 il -
JUNE 28 THROUGH JULY 9,1993 i
INSPECTION REPORT NOS. 50-528/529/530/93-31 l
I i
i-i
)
)
~
Restatement of Notice of Violation 50-528/93-31-04 7
i During an NRC inspection conducted on June 28 through July 9,1993, one violation of
~
NRC requirements was identified. In accordance with the " General Statement of Policy i
and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
t 10 CFR 73.21 provides that each power reactor licensee is required to ensure that l
Safeguards information (SGI) is protected against unauthorized disclosure, and that while unattended, SGI shall be stored in a locked security storage container.
Contrary to the above, on nine occasions.the licensee failed to properly protect l
l Safeguards Information, in that-i l
(1) on three occasions, January 4, January 27, and June 9,1993, unattended safeguards containers storing SGI documents were left unlocked. Two containers were located at APS Corporate Headquarters Building 411, and one container was located at Palo Verde Building F.
i (2) on February 17,1993, it was discovered that unattended SGI documents had been stored for approximately eight months outside of a locked security storage container in the audio visual room at Palo Verde Building F.
(3) on March 5,1993, unattended SGI documents were temporarily stored outside of a locked security storage container inside an employee's work cubicle at Palo Verde Building F.
(4) on April 26, 1993, an unattended package containing SGI documents was
-l temporarily stored outside of a locked security storage container in a central in-box at Palo Verde Building B.
(5) on April 30,1993, SGI from a network computer in Building B, was left unattended in that the information was printed over an unprotected line to a remote printer.
1 (6) on two separate occasions on June 30,1993, unattended SGI drawings were i
temporarily stored outside of a locked security storage container. One drawing was atop a shredder, and a second drawing was atop an employee's desk in Palo Verde Building A.
This is a Severity Level IV Violation (Supplement 111).
Page 1 of 1
q i
i 1
ENCLOSURE 2 l
i REPLY TO NOTICE OF VIOLATION l
l 50-528/93-31-04 l
l NRC INSPECTION CONDUCTED JUNE 28 THROUGH JULY 9,1993 INSPECTION REPORT NOS. 50-528/529/530/93-31 1
l 1
I m.
Repiv to Notice of Violation 50-528/93-31-04 Reason For The Violation The reasons for the violation were personnel error and potential mechanical malfunction of the safe's lock. In each instance an investigation of the event was conducted to determine the cause, anc'. spropriate corrective action was taken. For the events involving personnel error, the inca..'_.als involved were aware of the requirements.
The primary cause of each personnel error was the inattention to the requirements of securing safeguards material. In severalinstances, the possibility of a mechanical failure i
of the safe's lock has not been eliminated. The mechanical failure may be due to worn components in the locking mechanism.
J Corrective Steps That Have Been Taken And Results Achieved
)
The individuals involved were counseled regarding the requirements to properly secure safeguards material.
Due to the number of recent safeguards events, a comprehensive Human Performance Evaluation System (HPES) investigation of the most recent occurrences was commenced. This investigation is reviewing the specifics of each event to determine what methods can be effectively employed to remind personnel when safeguards material is not secured.
Page 1 of 3
. On June 24,1993, APS issued a sitewide memorandum as part of the Security l
Awareness Program.
This memorandum included a discussion of the control of safeguards material. On August 27,1993, APS issued a memorandum to personnel on the safeguards authorization list. This memorandum discussed recent events involving the loss of control of safeguards material, reminded personnel to maintain their awareness of safeguards material when using it, and suggested methods to aid personnel in remembering to secure safeguards material.
Corrective Steos That Will Be Taken to Avoid Further Violations l
l The HPES investigation is ongoing. Following the completion of this investigation, APS will implement corrective actions to aid PVNGS personnel in properly securing safeguards material. APS is evaluating the effect of reducing the number of personnel authorized access to safeguards material and additional controls such as designated areas for use of safeguards materials and signed verification for the opening of safeguard material containers.
APS is investigating the apparent intermittent failure of the locks for the safeguard containers. This failure is suspected to be caused by worn components in the locking mechanism. Appropriate corrective action will be taken based on the results of the investigation.
Page 2 of 3
j Date When Full Compliance Will Be Achieved k
i Each example cited in the violation was corrected on the day of discovery. Full l
i compliance was achieved on June 30,1993, when the last example in the violation was t
corrected.
t i
i i
l I
r 1
1 l
1 l
i h
l 3
I l
?
l
.i i
i.
Page 3 of 3 l
l t
i 3
-