ML20217F404

Ro:On 970731,discovered That Intrusion Detection Sys segment,guardwire-645,did Not Have self-contained Backup Battery.Caused by Inadequate Field Change Notice.Will Install Battery for GW-645 by 971031

ML20217F404
Person / Time
Site:	San Onofre
Issue date:	10/03/1997
From:	Krieger R SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9710080184
Download: ML20217F404 (3)

Text

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. Ib MdlHIRN cat HORNm P . W. Krieger M EDISON M,0.

wiwv ovu dnow Ln.n, October 3,1997 U. S. Nuclear Regulatory Commission  !

Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50 361 and 50-362 Revised 14 Day Follow-up Report San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Letter, R. W. Krieger (SCE) to USNRC Document Control Derk, Dated August 15,1997 By the referenced letter, Southern California Edison (SCE) provided the 14 day follow-up report required by Condition 2.G of License Nos. NPF-10 and NPF-15 for San Onofre Units 2 and 3, respectively, because an intrusion detection system (IDS) segment, guardwire-645 (GW-645), did not have a self-contained backup battery as required by the Physical Security Plan (PSP), Section 6.3.4. That report stated SCE was investigating the cause of the condition and would submit a follow-up report. The purpose of this letter is to submit the fellow-up report.

Cause of the EveD1 The root cause of the installation of GW-645 without self contained battery backup as required by the PSP was an inadequate Field Change Notice (FCN) due to incorrect packaging and insufficient detall. Information necessary for field implementatiori, i.e.,

reference to the backup battery, was prepared and included in the FCN peckage as Construction Notes instead of being paginated within the actual FCNs as required by I procedure SO123 XXIV-10.21. The FON originator intended for the battery Ir.stallation d and testing infr:mation to be used by the field personnel. However, due to the incorrect packaging of the FCNs, that information was not distributad to them in ,

addition, specific details concerning the backup battery placement and wiring were not shown on the FCNs, The originator assumed that the backup battery was contained TQQ within the power supply and, therefore, would not necessarily be required to be shown k on the drawing. This was an incorrect assumption, By not validating this assumption with the vendor as required by our program, the required information for installation in the plant was not obtained and transmitted to the implementing organization.

9710000104 9710o3 PDR ADOCK 0500o361.

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Docurhent Control Desk October 3,1997 Also, contrary to procedure SO123 XXIV-1,1, which requires independent design verification, the Independent Review Engineer (IRE) function for the FCN package was performed by the engineer who was primarily involved in the design preparation. As a result, there was inadequate independent review of the FCN to identify the lack of battery configuration. The engineer originally involved with the design left the company and the reviewer assumed responsibility for the rhnnge. According to procedure SO123 XXIV-10.9, it was the first line supervisors rosponsibility to assign a qualified IRE. The supervisor exercised poor judgment in not assigning another IRE to review the change. This was a contributing cause.

SCE will install the battery for GW-645 by October 31,1997. The FCN originator and IRE will receive appropriate disciplinary action. The first line supervisor is no longer SCE. Engineering personnel will be tralned on the lessons learned from this event.

SCE believes this to be an isolated occurrence.

Guardwire-845 Periodle Testino IDS segments are tested periodically using repetitive maintenance orders (RMOs).

The RMO used to test GW-645 was developed from the FCN package described above and, therefore, did not prescribe battery testing. Consequently, periodic testing of GW 645 from April 1996 through August 1997 could not detect the missing battery.

IDS Power Sucolles The referenced letter also reported that the PSP did not correctly indicate that some IDS segments are powered from a station uninterruptible power supply rather than normal station power. Some Security personnel did not recognize that this condition required a PSP change. Management will reinforce our expectation of verbatim compilance with the PSP and the Safeguards Contingency Plan (SCP).

As discussed in our separate letter to the NRC dated September 2,1997, SCE initiated a validation program for comparing the installed equipment against the PSP and SCP requirements, in that letter, SCE committed to submit a single integrated License Condition 2.G written report, which is the subject of separate correspondence.

Additional Information - Security Proaram Imorovements Our investigation of these events, to be documented in our Event Report 970800080, identified some weaknesses and areas for improvement in our Security Program.

Corrective actions are being initiated and tracted under our Event Report system.

Docurhent Control Desk October 3,1997 Additional Information - 1992 Event During preparation of this report, an unrelated item was identified regarding a condition potentially reportable under Condition 2.G of our plant operating licenses. Specifically, in February 1992, during a 45-minute scheduled power outage to several IDS E Fleld segments, the backup batteries did not power the E-Field segments as expected.

When investigated at that time, SCE discovered the batteries were dead and their terminals corroded. SCE concluded that E-Field battery testing methodology was deficient and did not properly test battery performance. SCE replaced the dead batteries, improved the periodic testing of the E Field batteries using RMOs, scheduled all E-Field backup batteries for replacement every 18 months, and made a security event log entry in accordance with 10CFR73.71(c). This event should also have been reported under License Condition 2.G, but was not. SCE is including this discussion as the follow-up report required by condition 2.G.

This report was delayed to allow submission of a complete report. If you have any questions, please let me know.

l Sincerely,

/

y t q-W.

cc: E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV M. B. Fields, NRR Project Manager, San Onofre Units 2 & 3 J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 & 3 Institute of Nuclear Power Operations (INPO)

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