ML021220594
| ML021220594 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/01/2002 |
| From: | Howell A Plant Support Branch Region IV |
| To: | Nunn D Southern California Edison Co |
| References | |
| EA-02-052, IR-01-019 | |
| Download: ML021220594 (6) | |
See also: IR 05000361/2001019
Text
SAFEGUARDS INFORMATION
May 1, 2002
Dwight E. Nunn, Vice President
Southern California Edison Co.
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
SUBJECT: RESPONSE TO LETTER DATED FEBRUARY 15, 2002, DENYING TWO
NONCITED VIOLATIONS IN NRC INSPECTION REPORT 50-361;-362/01-19
Dear Mr. Nunn:
This is in response to your letter dated February 15, 2002, in which you denied two violations of
NRC requirements documented as noncited violations (NCVs) in NRC Inspection Report
50-361/01-19 and 50-362/01-19, dated December 20, 2001.
The first noncited violation involved decreasing the effectiveness of your safeguards
contingency and training and qualifications plans in violation of 10 CFR 50.54(p). Specifically,
in Revision 24 to the Safeguards Contingency Plan, dated August 29, 2000, and Revision 22 to
the Training and Qualifications Plan, dated September 29, 2000, you removed the requirements
to maintain batons (and provide baton training to security officers), without substituting
equivalent equipment and training to support this functional requirement. In your February 15,
2002, response letter, following your assessment of this noncited violation, you concluded that
changes made to your Safeguards Contingency and Training and Qualifications Plans had not
reduced the effectiveness of your previously approved plans and satisfied the requirements of
10 CFR 50.54(p) and Generic Letter 95-08, 10 CFR 50.54(p) Process for Changes to Security
Plans Without Prior NRC Approval. For these reasons, you determined that the violation did
not occur. After careful review and consideration of your position, we reaffirmed that the
elimination of batons from your plans reduced the effectiveness of these plans in violation of
10 CFR 50.54(p). The basis for our conclusion is discussed in Enclosure 1 to this letter.
SAFEGUARDS INFORMATION
ENCLOSURES CONTAIN
SAFEGUARDS INFORMATION
UPON SEPARATION THIS
PAGE IS DECONTROLLED
2
The second noncited violation involved providing inaccurate information to the NRC in violation
of the requirements of 10 CFR 50.9. Specifically, your October 17, 2000, white paper stated
that the local law enforcement agency (LLEA) was better equipped/trained to handle public
disturbances at your site. Based on a subsequent NRC inspection and investigation, the NRC
determined that prior to October 17, 2000 (date of the white paper), you did not have a recent
written agreement with your LLEA to this effect. After careful review and consideration of the
information previously provided, we reaffirmed that this violation occurred as previously stated.
The basis for our conclusion is documented in Enclosure 2.
The material enclosed herewith, contains Safeguards information as defined by 10 CFR 73.21
and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy
Act of 1954, as amended. Therefore, the enclosures will not be placed in the Public Document
Room.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this letter, we will be pleased to discuss them with
you.
Sincerely,
/RA/
Arthur T. Howell III, Director
Division of Reactor Safety
Dockets: 50-361; 50-362
Enclosures:
1.
Noncited Violation No. 1 - Decrease in Effectiveness of Security Plans
2.
Noncited Violation No. 2 - Inaccurate Information Provided to the NRC
3
cc WITHOUT safeguards enclosures:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
Gary L. Nolff
Power Projects/Contracts Manager
Riverside Public Utilities
2911 Adams Street
Riverside, California 92504
Eileen M. Teichert, Esq.
Supervising Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, California 92522
R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
David Spath, Chief
Division of Drinking Water and
Environmental Management
P.O. Box 942732
Sacramento, California 94234-7320
Michael R. Olson
San Onofre Liaison
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, California 92112-4150
4
Ed Bailey, Radiation Program Director
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732 (MS 178)
Sacramento, California 94327-7320
Steve Hsu
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento, California 94327-7320
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, California 92672
Robert A. Laurie, Commissioner
California Energy Commission
1516 Ninth Street (MS 31)
Sacramento, California 95814
Douglas K. Porter
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
5
cc: WITH Safeguards Enclosures:
Vonna Ordez (NRR/DIPM)(MS O6H-02)
Alan Madison (NRR/DIPM)(MS O6H-02)
Elaine McNeil (NRR/DIPM)(MS O6H-02)
RIV Docket File - File Room Custodian
Security Inspector (Schaefer)
Electronic distribution from ADAMS by RIV without SAFEGUARDS portion of the letter
ADAMS Distribution Code (IE04)
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
Senior Resident Inspector (CCO1)
Branch Chief, DRP/C (KMK)
Senior Project Engineer, DRP/C (WCS)
Branch Chief, DRP/TSS (KMK)
STARFIRE Coordinator (NBH)
Scott Morris (SAM1)
NRR Event Tracking System (IPAS)
SONGS Site Secretary (SFN1)
G. F. Sanborn, D:ACES (GFS)
K.D. Smith, RC (KDS1)
F.J. Congel, OE (FJC)
OE:EA form (RidsOeMail Center)
DOCUMENT NAME: R:\\_SO23\\Denial of Two NCVs.wpd
RIV:DRS/PSB
PSB
C: PSB
C: ACES
C: DIPM/IOLB/NRR
Peer Review*
DWSchaefer *
GMGood *
GFSanborn
See E-Mail *
/RA/
/RA/
/RA/
via E-MAIL
03/ 03 /02
03/ 04 /02
03/ 12 /02
04/ 24 /02
03/ 25 /02
D: DRS
DRP/C
RC
OE:NRC
ATHowell III
CEJohnson *
KDSmith
JDixon-Herrity
/RA/
/RA/
/RA/
- via TELCON
03 /02
03/ 19 /02
04/ /02
04/ 24/ 02
- Previously Concurred
OFFICIAL RECORD COPY