ML20203P455
| ML20203P455 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/15/1986 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20203P451 | List: |
| References | |
| ANPP-36098-EEVB, NUDOCS 8605070276 | |
| Download: ML20203P455 (2) | |
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r5CElVED Ur Arizona Nuclear Power Project 33 pg g 7 77 P o BOX 52034 e PHOENIX, AA42ONA 85072-2034 AprQg13,,,/EEVB/98.05 1986 ANPP-36098 U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:
Mr. A. E. Chaffee Reactor Projects Branch
]
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 2 Docket No. STN 50-529 (License NPF-46)
Response to Notice of Violation 50-529/86-07-01 File: 86-070-026; D.4.33.2; 86-056-026
References:
(a) Letter from E.
E. Van Brunt, Jr.,/PGN, ANPP, to NRC, ANPP 34682 dated January 17, 1986.
Subject:
LER 85-005-00.
(b) Letter from A. E. Chaffee, NRC to E. E. Van Brunt, Jr., ANPP, dated March 18, 1986.
Subject:
NRC Inspection Report Nos.
50-529/86-07; 50-530/86-06.
Dear Sir:
This letter is provided in response to the inspection conducted by Mr. R. C. Sorensen of the NRC staff on February 24 through March 5, 1986, of activities authorized by NRC License NPF-46.
Based on the results of the inspection, a violation was identified concerning the lack of addressing procedural aspects of the personnel error noted in LER 85-005-00.
See Reference (a). The violation was discussed in Appendix A of the Reference (b) letter which is provided in Attachment 1.
The response to the violation is discussed in Attachment 2.
Should you have any questions concerning these matters, please contact me.
Very truly yours, W
twt E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/JYM/dlm cc:
A. C. Gehr R. P. Zimmerman E. A. Licitra R. C. Sorensen L. F. Miller 8605070276 860502 PDR ADOCK 0000 9
G E&O/
t ATTACIDENT I APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Docket No. 50-529 P. O. Box 21666 License No. NPF-46 Phoenix, Arizona 85036 As a result of the inspection conducted on February 24 - March 5, 1986, and in accordance with NRC Enforcement Policy, 10 CFR 2, Appendix C, the following violation was identified:
10 CFR 50.73 states in part, "The Licensee Event Report shall contain....
Operator actions that affected the course of the event, including operator errors, procedural deficiencies, or both, that contributed to the event. For each personnel error, the licensee shall discuss....
Whether the error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure...."
Contrary to the above, Arizona Public Service Company submitted by cover letter dated January 17, 1986, Licensee Event Report 85-005-00 to the NRC entitled " Control Room Ventilation Recirculation Discontinued Due to Operator Error".
The report did not discuss whether the error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure.
This is a Severity Level V Violation (Supplement I)
Pursuant to the provisions of 10 CFR 2.201, Arizona Public Service Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
,i mao 1 s 1996 tb AdfV Ddted
[oy L. F. 'Mifler, Jr., C iief Reactor Projects Section No. 2 fhThb J
ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION No. 50-529/86-07-01 Clarification of Condition As stated in the Notice of Violation, the subject LER does not contain an explicit discussion of the effect of station procedures on the events which led to the reportable condition.
The LER does, however, discuss the nature of the personnel error and states that the specific error was based on an assumption by a licensed operator (paragraph 4, page 2 of 3).
10 CFR 50.73 (b)(2)(1) requires that a clear, specific narrative description be provided so that "... knowledgeable readers conversent with the design of comme rcial nuclear power plants...
can understand the complete event."
T'ie authors and reviewers of the LER believed that a statement that the subject error was the result of an assumption on the part of the licensed operator, would address the requirements of the specific paragraph cited in the Notice of Violation.
It has been determined that the root cause was a
misinterpre ta tion of the requirements of 10 CFR 50.73 (b)(2)(1) and the guidance provided in NUREG-1022 by both the authors and reviewers of the LER.
Corrective Steps Which Have Been Taken and Results Achieved The specific LER addressed in the violation will be supplemented to add an explicit discussion of the effect station procedures had on the event. To address the immediate concern, personnel within the Compliance De partment, responsible for the preparation of LERs, have been instructed to address each individual item contained in 10 CFR 50.73 (b) in addition to providing a narrative description.
Corrective Steps nich Will be Taken to Avoid Further Occurrences To reinforce the training already provided, the depa rtment guidance on the preparation of LERs will be revised to specify the inclusion of specific wording to meet the requirements of 10 CFR 50.73 (b) in addition to the required narrative.
Compliance supervision will review a sample of LERs, using Military Standard 105D1 as a basis for the sample size, for omission similar to that identified in the violation.
Should problems be identified, the necessary corrective actions will be taken.
Date When Full Compliance Will Be Achieved The supplement to the LER, the revised department guidance on the preparation of LERs, and the review of the sample of LERs and necessary corrective actions are expected to be completed by June 1,1986.
1 Military Standard Sampling Procedures and Tables for Inspection by At tributes (U.S. Government Printing Of fice,1968)
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