ML20204A315

Ack Receipt of Response to Item 2 to 851004 Notice of Violation Re Tech Spec 6.2.2.2 on Personnel Working Overtime W/O Required Approval or Administrative Procedures to Closely Control Overtime Work.Addl Info Required

ML20204A315
Person / Time
Site:	Palo Verde
Issue date:	05/05/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 8605120064
Download: ML20204A315 (1)

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Arizona Nuclear Power Project

-P. O. Box 52034 Phoenix, Arizona 85072-2034 g

J Attention: Mr. E. E. Van Brunt, Jr.

Executive Vice President Gentlemen:

The NRC has completed its review of your response to Item 2 of the Notice of Violation, dated October 4, 1985. This Item concerned violation of Technical Specification 6.2.2.2 by a member of the engineering staff who worked twenty hours during the twenty-four hour period beginning at 6:00 pm on August 19, 1985, without the required approval or administrative procedures to closely control overtima work.

The NRC has concluded that, in this case, a violation of the Technical Specification 6.2.2.2 did indeed occur. The NRC believes that the intent of this specification is to limit the working hours of unit staff who perform safety-related functions, which include the type of work this engineer performed, namely taking measurements and calculating percent of valve travel during safety-related surveillance testing. The specification is not limited to the examples listed: senior reactor operators, reactor operators, radiation protection technicians, auxiliary operators, and key maintenance personnel. Therefore, the engineer who was involved in the surveillance testing fell under the controls of Technical Specification 6.2.2.2.

Please review your response dated November 5, 1985 to the Notice of Violation, dated October 4, 1985, and revise it as necessary to supply the information required pursuant to the provis'.ons of 10 CFR 2.201: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which were (or will be) taken to avoid further items of noncompliance; and (3) the date when full compliance was (or will be) achieved.

Your cooperation with us is appreciated.

Sincerely, D. F. Kirsch, Director Division of Reactor Saf.ty and Projects bec: A. Johnson, RV L. Miller, RV R. Zimmerman, SR1-PV J. Axelrad, IE J. Lieberman, ELD F. Miraglia, NRR:PWR-B g E. Licitra, NRR[PWR-B RV V h g LMiller:jb AChiff f ee DK sch anson 04/)3/86 04/ p 86 C /}/86 0 / V/86 8605120064 DR 860505 i0 ADOCK 05000528 PDR

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