IR 05000361/1997004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-361/97-04 & 50-362/97-04

ML20149E661
Person / Time
Site:	San Onofre
Issue date:	07/15/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
References
50-361-97-04, 50-361-97-4, 50-362-97-04, 50-362-97-4, NUDOCS 9707180278
Download: ML20149E661 (4)

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j,a na%g UNITED STATES 4, I.

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Harold B. Ray, Executive Vice President Southern California Edison Co.

l San Onofre Nuclear Generating Station i

. P.O. Box- 128 San Clemente, California 92674-0128 SUBJECT: NRC INSPECTION REPORT 50-361/97-04; 50-362/97-04- 1

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Dear Mr. Ray:

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Thank'you for your letter of May 23,1997, in response to our letter and Notice of  :

Violation dated May 8,1997. We have reviewed your reply and find it responsive to the l concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been )

achieved and will be maintained. '

If you have further questions regarding our positions, please contact Mr. Blaine Murray (817/860-8126) of my staff. ,

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Sincerely,

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,f T l x ,, a a , ,w 4 Arthur T. Howell Ill, Director

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Division of Reactor Safety l

Docket Nos.: 50 361;50 362 l License Nos.: NPF 10; NPF-15 l

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Chairman, Board of Supervisors

. County of San Diego L :1600 Pacific Highway, Room 335 San Diego, California 92101 Aisn R. Watts, Esq.

W oodruff, Spradlin & Smart

701 S. Parker St.' Suite 7000

Orange, California 92868-4720 l

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Southern California Edison Co. -2-Sherwin Harris, Resource Project Manager

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Public Utilities Department City of Riverside 3900 Main Street Riverside, California 92522 R. W. Krieger, Vice Fiesident Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128 Dr. Harvey Collins, Chief

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Division of Drinking Water and

! Environmental Management California Department of Health Services P.O. Box 942732 Sacramento, California 94234-7320 I

l Terry Winter, Manager l Power Operations l San Diego Gas & Electric Company

! P.O. Box 1831 1 San Diego, California 92112 Mr. Steve Hsu l Radiological Health Branch State Department of Health Services P.O. Box 942732 Sacramento, California 94234 Mayor City of San Clemente 100 Avenida Presidio San Clemente, California 92672 Mr. Truman Burns \Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, California 94102

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Southern California Edison Co. -3-E-Mail report to T. Boyce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

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I DOCUMENT NAME: R:\_SO23\SO704ak.ABE To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PSS:PSB aff C:PSB 3 E D:DRP pp:DRS y fff3 ABEarnest/imt(f/6 BMurray 0 TPGwyng'jQAVATHoweijg M 07(q/97 074y97 07//497'$" 07//,5797 ""

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OFFIC AL RECORD COPY

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F EDISON ?24-An EDISO4 INTER %A TIONAL Company _ _ , , ;

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May 23,1997

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l U. S. Nuclear Regulatory Commission Document Control Desk j--- - ..

Washington, D.C. 20555 Subject: Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 l

References: (1) Letter, Mr. A. T. Howell lll (USNRC)

to Mr. Harold (Edison), dated May 8,1997 (2) Letter, Mr. D. E. Nunn (Edison) to USNRC Region IV (Attn: Mr. R. Wise), dated October 21,1996 Reference 1 transmitted the results of NRC Inspection Report No. 50-361/97-04 and

. 50-362/97-04, conducted February 24-28,1997, at the San Onofre Nuclear Generating Station, Units 2 and 3. The enclosure to Reference 1 also transmitted a Notice of Violation containing two violations (9704-02 and 04). These violations involved: (1)

the failure to change out the security lock and key system after the termination for cause of an individual with access to the keys of that system; and (2) a failure to follow physical security plan and procedural requirements prior to allowing a vehicle to access the area behind the vehicle barrier system.

In accordance with Reference 1, the enclosure to this letter provides Edison's reply to the Notice of Violation. However, as described in the enclosure, Edison took prompt corrective action while the inspector was on site or had completed the corrective actions prior to the inspection. Edison believes this information should have been reflected in the inspection report to accurately reflect the inspection.

If you have any further questions, please contact me.

Sincerely, b .

Dwight E. ,4unn Enclosure P. O. Box 128 San Clemente. CA 92640128

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j DOCUMENT CONTROL DESK -2-l

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cc: E. W. Merschoff, Regional' Administrator, NRC Region IV A. T. Howell, Director, Division of Reactor Safety, NRC Region IV K. E. Perkins, Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 and 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3

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ENCLOSURE l

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VIOLATION A '

The enclosure to Mr. A. T. Howell's letter dated May 8,1997, states in part:

"10 CFR 73.55(d)(9) states, in part, 'Whenever an individual's unescorted access is !

revoked due to his or her lack of trustworthiness, reliability, or inadequate work l

performance, keys, locks, combinations, and related access control devices to l

which that person had access must be changed or rotated.' I i

" Paragraph 4.4 of the licensee's physical security plan states, in part, 'In addition, i whenever an individual's unescorted access is revoked due to his or her lack of l trustworthiness, reliability, or inadeq'uate work performance, keys, locks, combinations, and related access control devices to which that person had access are changed or rotated within five days.'

" Paragraph 6.4.2 of Security Procedure SO123-IV-4.4, Revision 1, states, in part,

' Evaluate termination to determine individual's reliability and trustworthiness. Direct

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l a Security Specialist, Lock and Alarm to change applicable locks, keys, and combinations within five days from day of employee's termination for cause, if i required.'

" Contrary to the above requirements, on December 16,1995, a security officer, with access to security keys, was terminated for cause. The licensee determined the

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security officer was untrustworthy and unreliable in that she failed to report an arrest

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for driving under the influence of alcohol. However, the inspector determined that the licensee did not rotate or change the locks and keys after her termination.

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"This is a Severity Level IV violation (Supplement lil) (50-361;-362/9704-02)."

RESPONSE TO VIOLATION A 1. Reason for the Violation The reason for the violation was an inadequate procedure (SO123-IV-4.4), which incorrectly allowed Security the flexibility to make a determination if the locks and keys needed to be cbsnged when they terminated the individual in December 1995.

The locks were changed in March 1996 (annual changeout).

2. Corrective Actions Taken and Results Achieved As corrective action, Procedure SO123-IV-4.4 was changed the day of the NRC inspection exit (February 28,1997) to not allow Security to make an independent determination of an individual's reliability and trustworthiness. Instead, now upon

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-2-Central Processing Facility notification of an employment termination for cause, or if unescorted access is permanently revoked for cause, the procedure requires all appropriate locks, keys, and combinations to be changed within five days.

3 Corrective Actions That Will Be Taken No additional corrective actions are planned.

4. Date When Full Compliance Will be Achieved Full compliance was achieved on March 10,21996,'when the locks were changed.

VIOLATION B The enclosure to Mr. A. T. Howell's letter dated May 8,1997, states in part:

" Paragraph 4.6.5 of the licensee's physical security plan requires that active barriers remain in the denial position and be removed only after the authorization for entry has been confirmed. It further states that access control measures for the vehicles provide assurance that the vehicle is not transporting a design basis threat explosive device.

" Paragraph 6.7.1.4.4 of licensee Security Procedure SO123-IV-5.3.3 requires a visual search, at the vehicle barrier system, of the vehicle for design basis threat explosives, weapons, and personnel.

" Paragraph 6.7.1.6.1 of licensee Security Procedure SO123-IV-5.3.3 states that, after the search, the active vehicle barrier system can be lowered and the vehicle allowed to enter the area behind the vehicle barrier system.

" Contrary to the above, on September 9,1996, the inspector observed a security officer lower the vehicle barrier system prior to a search of a vehicle stopped at the barrier. Further, the security officer did not perform an adequate search of the vehicle prior to allowing it to proceed inside the barrier.

"This is a Severity Level IV violation (Supplement Ill) (50-361;-362/97-04)."

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RESPONSE TO VIOLATION B 1. Reason for the Violation As noted in Reference 2, the reason fE[t$dkbi$iiEirEif/$sisiih66Hil error.f6I Oinadequate~fattention to~ detail. The security officer did not maintain proper ,

68ie"rvation over the subject vehicle because he was distracted while in-processing a tractor-trailer, and wm unaware of brief periods when the vehicle was outside his direct vist'al range.

~2. Corrective Actions Taken and Results Achieved Prior to this' inspection, disciplinary action had been taken for the security officer involved, which included counseling and subsequent retraining. Also, Procedure SO123-IV-5.3.3, " Search and Inspection," had been revised on December 2,1996, to clarify the vehicle search process.

3.' Corrective Actions That Will Be Taken i

i No additional corrective actions are planned. j 4. Date When Full Compliance Was Achieved Full compliance was achieved on December @dG96rupon issuance of SO123-IV-5.3.3, Revision 3.