ML17313A522

Responds to NRC 980710 Ltr Re Violations Noted in Investigation Repts 4-97-022S & 4-1998-014.Corrective Actions Taken to Avoid Future Instances of Deliberate Misconduct Outlined in Util Presentations at 980331 EC

ML17313A522
Person / Time
Site:	Palo Verde
Issue date:	08/06/1998
From:	Mccarter A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IA-98-014, IA-98-14, NUDOCS 9808110157
Download: ML17313A522 (8)

Text

. CATEGORY 3 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9808110157 DOC.DATE: 98/08/06 NOTARIZED: YES DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear'tation, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION MCCARTER,A.K. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Responds to investigation NRC 980710 ltr re repts 4-97-022S violations noted in

& 4-1998-014.Corrective actions taken to avoid future instances of deliberate misconduct outlined, in util presentations at 980331 EC.

DISTRIBUTION CODE: XE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: STANDARDIZED PLANT 05000528 Standardized plant. 05000529 Standardized plant. 05000530 0 R

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR E CL PD4-2 PD FIELDS,M 1 INTERNAL: ACRS AEOD/S PD/RAB AEOD TTC DEDRO CE NRR/DRCH/HOHB PECB NRR/DRPM/PERB D NUDOCS-ABSTRACT OE DIR OGC/HDS2 RGN4 FXLE 01 EXTERNAL: LITCO BRYCE,J H NOAC NRC PDR NUDOCS FULLTEXT E

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL

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Alan K. McCarter APS-Palo Verde Nuclear Generating Station 5801 S. Wintersburg Rd. Mail Station 7894 Phoenix, Arizona 85354-7529 August 6 1998 IA 98-014 Docket No. 55-50192 License No. OP-50210-2 U. S. Nuclear Regulatory Commission ATTN.: Document Control Desk Washington, D.C. 20555

Subject:

Reply to a Notice of Violation (NRC Investigation Report Nos. 4-97-022S and 4-1998-014)

To Whom it May Concern:

I am submitting this response'in compliance with NRC letter IA 98-014 dated July 10, 1998 and the associated Notice of Violation Re: the investigation reports noted above. I have been requested to respond to four specific aspects of the violation: (1) the reason for the violation, or, ifcontested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that willbe taken to avoid further violations, and (4) the date when full compliance willbe achieved.'he material submitted in this letter supplements material which I have already presented to the NRC in my interview with OI This letter refers to and relies on material already presented to the NRC in my interview with OI and at the March 31, 1998 predecisional enforcement conference in Arlington, Texas.

9808iiOi57 980806 PDR ADQCK 05000528 9 PDR

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1 Reasons for The Violation On March 10, 1993 I was involved in the falsification of a surveillance test record by backdating the time of completion to reflect that the surveillance had been performed on time to meet the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> requirement for verification of offsite power availability. I was persuaded by the technical argument presented by my supervisor that the acceptance criteria of the surveillance had been met at all times during the shift. This led me to conclude that there was no safety significance to the intended falsification I realize now that I was not and am not the person to make that decision. This should have been reported so that the appropriate people could determine the significance. I did participate and therefore I do not contest nor dispute this violation, and I deeply regret its occurrence.

2. Corrective Ste s and Results The corrective actions taken to avoid future instances'of deliberate misconduct were outlined in APS's presentations at the March 31 Predecisional Enforcement Conference.

3. Ste s to Avoid Further Violations The steps outlined above have had a profound effect on me and will continue to have one for the rest of my working life. Together, they ensure that I will never knowingly be involved in any violation, deliberate or otherwise, ever again.

if Additionally, as noted in Mr. Merschoff's letter of July 10, 1998, I ever reapply for Part 55 licensed-operator status, my application will face review under 10 CFR)55.31(b).

4. Full Com liance Allmeasures taken in response to the violation, other than those in effect for a year or more, are complete already. The remainder will be completed by February 10, 2000. Mr. Merschoff's letter of July 10 indicates that the Commission regards these measures to be sufficient. Thus, I believe that from the Commission's standpoint, and to the extent that this concept can be applied to an individual enforcement action, full compliance has been achieved.

I willbe pleased to respond to any further questions you may have.

Sincerely yours, Alan K. McCarter AFFIRMATIONOF ALANK. MCCARTER County o State of Arizona )

I hereby swear, under penalty of perjury, that the statements I have made in this letter are true and correct.

Alan K. McCarter Subscribed and sworn to before me this 5 day of August, 1998.

Notary Public My commission expires:

CC: Regional Administrator offCAt. SEQ U. S. Nuclear Regulatory Commission, Region IV NORA E. MEADQR ttotae Pubk - State ot Arizona 611 Ryan Plaza Dr. Suite 400 Arlington, Texas 76011-8064 My Comm. Eqkee ~

MARlCOPA COUNtv s, tggg

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