IR 05000219/1998002
| ML20236V255 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/29/1998 |
| From: | Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| References | |
| 50-219-98-02, 50-219-98-2, NUDOCS 9808030037 | |
| Download: ML20236V255 (2) | |
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SUBJECT:
INTEGRATED INSPECTION Sl ' ;9/98-02
Dear Mr. Roche:
This letter refers to your July 2,1998 correspondence, in response to our
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June'3,1998 letter.
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- Thank you for informing us of the corrective and preventive actions documented in your letter. These' actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincco.,y.
Original signed By:
Michele G. Evans, Chief Projects Branch 7 Division of Reactor Projects
' Doc'ket No.: 50-219
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cc w/o cv of Licensee Resoonse Letter:
M. Leggart, Manager, Licensing and Vendor Audits G. Busch,'Manageri Nuclear Safety and Licensing cc w/cv of Licanase Renoonse Letter:
State of New' Jersey l.
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9909030037 900729
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PDR ADOCK 05000219
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Mr. Michael Distribution w/cv of Licensee Resoonse Letter:
Region 1 Docket Room (with concurrences)
Nuclear Safety Information Center (NSiC)
PUBLIC NRC Resident inspector H. Miller, RA/W. Axelson, ORA M. Evans, DRP N. Perry, DRP D. H-vakamp, DRP C. O'Daniell, DRP J. Yerokun, DRS B. McCabe, OEDO C. Thomas, PD1-3, NRR R. Eaton, PD1-3, NRR T. Colburn, PDI-3, NRR R. Correia, NRR F. Talcot, NRR DOCDESK Inspection Program Branch, NRR (IPAS'
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l DOCUMENT NAME: G:\\ BRAN P{ Copy without attachment / enclosure LTR\\oc9802.rpy l
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NAME DHaverkampA(d//-
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MEvans W)D DATE 07/24/98 07M/98 07/24 /98 ll OFFICIAL RECORD COPY
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GPU Nuclear, Inc.
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U.S. Route M South NUCLEAR Post Office Box 388 Forked River, NJ 08731-0388 Tel 609-971-4000 l
July 2, 1998 1940-98-20368
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U. S. Nuclear Regulatory Commission Attention: Document Control Desk
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Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 l
IR 98-002: Reply to Notice of Violation l
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In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the i
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violations identified in the subject inspection report.
If you should have any questions, or require further information, please contact Kenneth Quintana, Oyster Creek Licensing Engineer, at 609-971-4917.
Very truly yours,
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Michael J Vice President and Director
Oyster Creek l
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Attachment cc:
Administrator, Region I NRC Project Manager NRC Sr. ; Resident Inspector
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Attachment 1 l
IR 98-002 Response to Notice of Violation Violation The Code of Federal Regulations, Title 10, Part 26, Fitness-for-Duty Programs, Appendix A, Section 2.3(2) states, " Appropriate background checks and psychological evaluations shall be completed prior to assignment of any tasks associated with the administration of the program, and shall be conducted at least once every three years."
Contrary to the above, on March 25,1998, the inspector determined through review of Fitness-for-Duty records that personnel that administer the Fitness-for-Duty program did not have a background check conducted at least once every 3 years.
Thi.s is a Severity Level IV violation (Supplement VII).
Re5D005e GPUN concurs.vith the violation as stated.
Reason for Violation Approximately nine years ago a determination was made that compliance with the requirement to periodically supplement an initial background investigation with additional and/or updated appropriate background check information could be satisfied via positive determinations derived through the continual behavioral observation program. This determination of the interpretation of" appropriate background checks" was reflected in the wording of a portion of the GPUN Fitness-for-Duty Program procedure which contained the following: " Background investigation evaluations or updates as a minimum shallinclude a continual behavioral observation program (CBOP) check." While this interpretation had been reviewed by both internal and external organizations in the past, it was subsequently determined that taking credit for positive determinations derived from the CBOP does not meet the intent of10 CFR 26, Appendix A, Section 2.3(2).
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IR 98-002: Response to Notice of Violation Page 2 Corrective Actions Taken and Results Achieved Subsequent to discussions with the inspector and prior to the issuance of the Notice of Violation, GPUN fdtiated actions through the GPUN Corrective Action Program. It was ultimately decided that the three-year background check update components would mirror initial background check requirements, except that the employment history check would only be required back to the initial background check or last update completed. A memo was issued to appropriate program administration personnel informing them of the changes being made in the ccmponents that comprise the periodic updates.
Corrective Actions Taken to Avoid Further Violations A revision to GPUN Fitness-for-Duty Program Procedure 1000-ADM-2002.06 has been initiated to include specific identification of the three-year background check update components in addition to other existing requirements.
Date of Full Comoliance The expanded periodic background checks for appropriate personnel will be completed no later than July 30,1998. This will establish full compliance with the regulations. The revision to Procedure 1000-ADM-2002.06 is currently under review and implementation is expected no later than September 30,1998.
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