IR 05000354/1982005

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in IE Insp Rept 50-354/82-05. Initial Corrective Actions Did Not Resolve Underlying Cause of QC Problems

ML20062E656
Person / Time
Site:	Hope Creek
Issue date:	08/02/1982
From:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Martin T Public Service Enterprise Group
Shared Package
ML20062E659	List: IR 05000354/1982005 ML20062E662
References
NUDOCS 8208100214
Download: ML20062E656 (2)

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AUG 2 1962

Docket No. 50-354 Public Service Electric and Gas Company ATTN: Mr. T. J. Martin Vice President Engineering and Construction 80 Park Plaza - 17C Newark, New Jersey 07101

4 Gentlemen:

Subject:

Inspection 50-354/82-05 This refers to your letter dated June 14,1982, in response to our Notice of Vio-lation dated May 13, 1982, citing two violations by W-H Constructors.

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.

In your letter, you also expressed a belief that these citations appear to be con-l trary to the stated NRC Enfercement Policy because of your prior notification to the NRC Resident Inspector of problems with the W-H Constructor's QA Program.

It is clear that the NRC encourages and supports licensee initiative for self-ider.ti-

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fication and correction of problems. However, it is also necessary that the cor-

rective actions taken by the licensee be sufficiently comprehensive so as to deter a recurrence of the identified problem. 1.icensees are afforded sufficient oppor-tunity to correct self-identified problems. However, if corrective actions are

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j ineffective to deter recurrence and appear to be limited in nature and scope, appro-j priate enforcement action is taken.

In this regard, NRC inspectors who are made j

aware of problems are expected to evaluate noncompliances with the purpose of bet-ter understanding the reasons for the violation (s) and to encourage corrective ac-tion that will address the underlying cause(s). Consequently, when problem areas i

are identified, there is increased attention and followup by the NRC Resident In-spector to assure that the degree of licensee initiative is responsive to the par-I ticular situation.

In this instance, the W-H problems were brought to your atten-tion prior to NRC involvement; howey?r, tha steps taken by your organization to resolve the issue (s) were insufficient. The recent violation identified by NRC on June 18, 1982 regarding W-H's use of unqualified QC personnel to inspect in-progress work activities and the subsequent stop work order is another. indication that the under7ying problems being experienced with W-H have not been properly i

self-identifieo or corrected.

Based on uty understanding of the issues, I conclude that the initial corrective actions were narrow in scope, focused primarily on the specific incidents pre-viously identified, and were not oriented to resolving all the underlying causes(s)

oftheproblem(s).

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8208100214 820802

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OFFICIAL RECORD COPY

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l AUG 2 1N2 Public Service Electric and Gas

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Company In sumary, we encourage and support licensee initiative for self-identification and correction of problems. As stated in the NRC Enforcement Policy, we will not generally issue a notice of violation for these situations that meet all five (5)

tests stated in the Federal Register Notice (9991 FRN dated March 9,1982). In this instance, we find that test (4) was not met.

Your cooperation is appreciated.

Sincerely

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02 iginal Signed By:

Richard W. Starostecki, Director Division of Project and Resident Programs cc:

R. L. Mitt 1, General Manager, Corporate QA PublicDocumentRoom(PDR)(w/cyofLicensee'sResponse)

Local Public Document Room (LPDR) (w/cy of Licensee's Response)

NuclearSafetyInformationCenter(NSIC)(w/cyofLicensee'sResponse)

NRC Resident Inspector (w/cy of Licensee's Response)

State of New Jetsey (w/cy of Licensee's Response)

bcc:

Region I Docket Room (with concurrences) (w/cy of Licensee's Response)

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