ML20217D364
| ML20217D364 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/1998 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-97-24, 50-362-97-24, NUDOCS 9803270400 | |
| Download: ML20217D364 (6) | |
Text
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~ An M/S&WqjnGM,Canpany March 20,1998 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
1.
Letter, E. W. Merschoff (USNRC) to Harold B. Ray (SCE), " Notice of Violation (NRC Inspection Report No. 50-361/97-24; 50-362/97-24),"
February 18,1998 2.
Letter, Arthur T. Howell, Ill (USNRC) to Harold B. Ray (SCE),
"Predicisional Enforcement Conference Summary," January 23,1998 3.
Letter, R. W. Krieger (SCE) to Document Control Desk (USNRC),
" Revised 30-Day Report, Licensee Event Report 97-002-01."
December 19,1997 4.
Letter, R. W. Krieger (SCE) to Document Control Desk (USNRC),
"14 Day Follow-up Report," August 15,1997 Reference 1 transmitted the results of NRC Inspection Report No. 50-361/97-24 and 50-362/97-24, conducted November 17 through December 5,1997, at Southem California Edison's (SCE) San Onofre Nuclear Generating Station, Units 2 and 3. The enclosure to that letter contained a Notice of Violation for 1) the loss of a copy of the Safeguards Contingency Plan (SCP); 2) two instances of an unlocked security weapons container,3) the failure to report the two instances of the unlocked security weapons container, and; 4) the failure to provide a backup power supply for a portion of the intrusion detection system.
The enclosure to this letter provides SCE's reply to these violations.
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PDR ADOCK 05000361 G
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San Clemente. CA 92674 0128 714-368-1480 Fax 714-368-1490
In addition to the information contained 'in the enclosure to this letter:
Reference 2 provides additional detail and information regarding all four Violations, Reference 3 provides additional detail and information regarding Violation A, the loss e
of a copy of the SCP, and, Reference 4 provides additional detail and information regarding Violation B.3, the e
failure to provide a backup power supply for a portion of the intrusion detection system.
If you have any further questions, please contact me.
I Sincerely,
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Enclosure:
As stated cc:
E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 and 3 L!-
4 ENCLOSURE
(
RESPONSE TO NOTICE OF VIOLATION
- Violation A-I "10 CFR 73.21(b)(1)(viii) requires that the composite safeguards contingency plan for the facility j
or site will be protected as safeguards information.10 CFR 73.21(d)(1) and (2) require that
. safeguards information shall be under the control of an authorized individual or if in storage, shall
- be locked in an a locked security storage container.
" Contrary to the above, on October 27,1997, the licensee discovered and reported that a copy of the composite safeguards contingency plan was lost, i.e., not under the control of an authorized individual or locked in a locked security storage container. The plan was missing from the safeguards storage container in the security operations office, located outside the protected area.
A search of the site did not result in the discovery of the safeguards document. (01013) j "This is a Severity Level lli violation (Supplement 111)."
Response to Violation A.
1.
Reason for the Violation SCE has concluded that the reason for the violation was that a copy of the Safeguards Contingency Plan (SCP) was removed or borrowed from its cabinet by an unknown, authorized employee and not retumed. The facts and circumstances surrounding this violation have been previously discussed in references (2) and (3).
2.
Corrective Steps Taken and Results Achieved
)
' Prompt security compensatory measures included notifying the Security Force of the loss and initiating an increased Security posture in and around the plants' protected areas.
Corrective steps taken to enhance the Safeguards Information (SI) material handling program included Sl cabinet inventories, use of check out logs, single point control of Si access, distribution control of SCP and Physical Security Plan transferred to Controlled Document Management (CDM), use of color binders, and a reduction in the number of storage locations, cabinets and personnel with Si access.
3.
Corrective Steps That Will Be Taken SCE plans to r* view the enhanced program after 6 months to assess the effectiveness of these changes 4.
Date When Full Compliance Will Be Achieved Full compliance was achieved on December 19,1997, when the Safeguards Contingency Plan was revised (Revision 18).
r Violation B.
- " Licensee Condition 2 E of the San Onofre Nuclear Generating Station Operating Licensee dated i
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Violation B."-
- " Licensee Condition 2.E of the San Onofre Nuclear Generating Station Operating Licensee dated August 25,1988, requires, in part, that the license fully implement and maintain in effect
. all provisions of the Commissien-approved physical security plan. This includes amendments and changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p)."
Violation B.1.
" Paragraph 9.2 of the physical security plan states, in part, ' Additional unloaded weapon locations, secured inside locked storage containers, are described in the security contingency plan.' Paragraph 3.4.5 of the security contingency plan states, in part, ' Weapons and -
ammunition are secured in fixed and mobile strategically located containers.' -
" Contrary to the above, on July 30 and November 7,1997, security officers discovered weapons and ammunition that were not secured. Specifically, in each instance, security.
officers found that a safeguards contingency cabinet was unlocked and unattended. The contingency cabinets contained weapons and ammunition and were unsecured for several hours. (02014)
"This is a Severity Level IV vio!stion (Supplement 111)."
Response to Violation B.1.
1.
Reason for the Violation The reason for the violation was personnel error. In each instance, a single officer (different for each instance) who should have re-locked the container after performing a routine inventory did not adequately self-check that the container was locked. Because the containers were inventoried and confirmed to be complete within 10 minutes of discovery, there was no refety significance to these events. The facts and circumstances surrounding this violation have been previously discussed in reference (2).
2.
Corrective Steps Taken and Results Achieved The two Security officers involved were disciplined.
As an additional enhancement to reduce human error, the old locks were repinned so that the key cannot be removed unless the lock is closed.
3.
Corrective Steps That Will Be Taken
- No additional corrective steps are planned.
4.
Date When Full Compliance Wdi Be Achieved Full compliance was achieved on the date of discovery, when appropriate compensatory measures were implemented upon discovery.
Violation B.2.
" Paragraph 3.2.4 of the physical security plan states, in part, 'SCE has established a management system that provides for the deveicpment, implementation, and enforcement of
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security propedures.' Paragraph B.14 of Security Procedure SO123-IV-11.2 (Attachment 2, 1-Hour Reportability Criteria), ' Loss or Unattended Weaoon in the Prot 9ded Atta,' requires that the following be reported to the NRC: 'Any weapon which becomes lost or out of the control or physical custody of security personnel for any length of time. 71.e 10 minute rule is not applicable.'
" Contrary to the above, on July 30,1997, Security Procedure SO123-IV-11.2 was not adequately implemented when no 1-hour report was made to the NRC upon discovery of a weapon which was out of the control or physical custody of security personnel for several hours. Specifically, a contingency weapon container located inside the protected area, with a weapon and ammunition inside, was unlocked and unattended. The incident was logged in ti.e safeguards event logs instead of being reported within 1-hoy to the NRC. (03014)
"This is a Severity Level IV violation (Supplement lil)"
1.
Reason for the Violation The reasons for the violation were: 1) the wording in one section of Security Procedure SO123-IV-11.2 was ambiguous, leading to the conclusion that events were to be logged instead of reported, and,2) a misunderstanding of regulatory guidance for reporting a lost weapon. The facts and circumstances surrounding this violation have been previously discussed in reference (2).
2.
Corrective Steps Taken and Results Achieved Security Procedure SO123-IV-11.2 was revised to clarify the reporting requirements.
3.
Corrective Steps That Will Be Taken l
A 30-day report will be made to the NRC by March 20,1998.
4.
Date When Full Compliance Will Be Achieved Full compliance was achieved on January 16,1998, when Revision 5 of SO123-IV-11.2 was implemented to clarify the reporting requirements.
Violation B.3.
" Paragraph 6.3.4 of the physical security plan requires that intrusion detection system units will be powered by either station power, with a 4-hour rated, self-contained battery for backup power supply, or station uninterruptible power supply.
" Contrary to the above, between July 31 and October 29,1997, Guardwire GW-645, a portion of the intrusion detection system unit, was powered by station power without a 4-hour rated, self-contained battery for backup power supply. Also, it was not powered by station uninterruptible power supply. (04014)
"This is a Severity Level IV violation (Supplement lii)."
b
Resp'onse to Violation B.3.
- 1.
Reason for the Violation The reason for the violation was an inadequate Field Change Notice (FCN) due to incorrect packaging and insufficient detail. The facts and circumstances surrounding this violation have been previously discussed in references (2) and (4).
~ 2.
Corrective Steps Taken and Results Achieved GW-645 was returned to service, with the backup battery installed, on October 29,1997.
The FCN originator and Independent Review Engineer received appropriate disciplinary action. The first line supervisor is no longer employed at SCE, so no disciplinary action was administerad in that instance. Nuclear Engineering Design Organization personnel were provided the text of the Event Report as required reading.
3.
Corrective Steps That Will Be Taken No additional corrective steps are planned.
4.
Date When Full Compliance Will Be Achieved Full compliance was achieved on October 29,1997, when GW-645 was returned to service.
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