ML20198T020
| ML20198T020 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/04/1986 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| ANPP-36765-EEVB, NUDOCS 8606110230 | |
| Download: ML20198T020 (5) | |
Text
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ENCLOSURE CONTAINS sAlw 0ARDS INFORMATION.
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9 PONIGEPARATION THIS j,$
PAGE IS DECONTROLLED f!
Arizona Nuclear Power Project P.o. box 52034 e PHOENIX, ARIZONA 85072-2034 June 4, 1986 ANPP-36765-EEVB/ACG Mr. James Taylor Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1 and 2 Docket Nos. STN 50-528 (License NPF-41)
STN 50-529 (License NPF-51)
Response to the Notice of Violation, dated May 5, 1986, and Request for Mitigation of Proposed Imposition of Civil Penalties File: 86-020-404; 86-A-056-026; 86-B-056-026
Dear Sir:
The five copies of Arizona Public Service Company's Response to the Notice of Violation, dated May 5, 1986, and Request for Mitigation of Proposed Imposition of Civil Penalties are enclosed. This document consists of seven parts, including a summary (Part A), five parts (Parts B - F) responding to the several violations cited in the Notice, and one part (Part G) requesting mitigation of the preposed civil penalty.
The response admits that the violations cited in the Notice did occur.
The request for mitigation asserts that:
The proposed increase in the base civil penalty is not supported a.
by the record and is unfair.
b.
The corrective actions taken by the licensee have been prompt and are unusually comprehensive.
The letter transmitting the Notice of Violation makes it clear that the proposed increase in the base civil penalty is based upon a perception of "a continuing lack of management attention to identified security problems." This perception is erroneous.
The record of actions taken by management over the past three years demonstrates that management attention has been continuously devoted to security matters.
Rather than showing a' lack of attention, the record shows the continuous efforts of management to achieve its goal of excellence in the operation of Palo Verde, including the maintenance of an effective and efficient security program.
JE,, / y'
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8606110230 860604 ENCLOSURE CONTAINS PDR ADOCK 05000528 SAFEGUARDS INFORMATION.
G PDR UPON SEPARATION THIS PAGE IS DECONTROLLED.,
ENCLOSURE CONTAINS SAFEGUARDS INFORMATION.
UPON SEPABATION THIS PAGE IS DECOSTROLLED.
Mr. James Taylor, Director Response to the Notice of Violation, dated May 5, 1986, and Request for Mitigation of Proposed Imposition of Civil Penalties ANPP-36765 Page 2 Any other characterization of this record is unfair. An increase in the base civil penalty under these circumstances would be a contradiction of the stated objective of the NRC's enforcement policy of "encoraging improvment of licensee performance."
l In keeping with the past record showing management's efforts toward achieving its goal of excellence, management has adopted an unusually comprehensive Security l'
Corrective Action Plan.
In addition to addressing the root causes of the violations cited in the Notice to prevent recurrence, the Security Corrective Action Plan incorporates:
Enhancements of the security maintenance pro 8 ram.
Enhanced independent monitoring and auditing of the security plan and its impicmentation.
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Enhanced efforts to involve all site personnel in making the security program more effective and efficient.
The Security Corrective Action Plan is not limited in its focus to hardware and software elements. It also reflects consideration of human factors that impact on a successful security program.
On balance, in applying the five factors used in making adjustments of base civil penalties, mitigation of the base civil penalty is warranted because of the unusually comprehensive scope of licensee's Security Corrective Action Plan.
Accordingly, licensee requests that the civil penalty be mitigated in accordance with the NRC's enforcement policy (10 CFR Part 2, Appendix C.).
The enclosed document contains Safeguards Information which must be protected against unauthorized disclosure in accordance with the provisions of 10 CFR 73.21 and is therefore to be withheld from public disclosure in accordance with 10 CFR 2.790(d). Please ensure appropriate steps are taken to safeguard its contents.
Respectfully submitted, Arizona Public Service Company
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By:
E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/ACC/rw Attachment ENCLOSURE CONTAINS SAFEGUAUD3 I"F03nTION.
UPON SEPARATION THIS PAGE IS DECONTROLLED.
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STATE OF ARIZONA )
) ss.
COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Executive Vice President, Arizona Nuclear Power Project, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true.
(.2t.
N 0LM Edwin E. Van Brunt, Jr.
Sworn to before me this k day of bmv
, 1986.
0 Y w J $ 4 2 1 L st- $L
' Notary Public My Commission Expires:
th Ccan!rion Egiras April 6,1987
Mr. James Taylor, Director Response to the Notice of Violation, dated May 5, 1986, and Request for Mitigation of Proposed Impositicn of Civil Penalties ANPP-36765 Page 3 cc:
Mr. Jack Martin Regional Administrator Region V R. P. Zimmerman
e.
Mr. James Taylor, Director Response to the Notice of Violation, dated May 5, 1986, and Request for Mitigation of Proposed Imposition of Civil Penalties ANPP-36765 Page 4 bcc: J. G. llaynes (all w/o )
J. R. Bynum O. J. Zeringue D. M. Nelson W. F. Quinn D. R. Canady W. E. Ide T. D. Shriver R. R. Baron T. R. Bradish A. C. Gehr D. Phillips C. Kelley
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