IR 05000354/1988003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/88-03

ML20196C699
Person / Time
Site:	Hope Creek
Issue date:	06/22/1988
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Miltenberger S Public Service Enterprise Group
References
NUDOCS 8807010195
Download: ML20196C699 (2)

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JUN 2 21988 Docket No. 50-354 Public Service Electric & Gas Company ATTN: Mr. Steven E. Miltenberger V1ce President and Chief Nuclear Officer Post Office Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:

Subject:

Inspection No. 50-354/88-03 This refers to your letter dated May 26, 1988, in response to our letter dated April 27, 1988.

Thank you for informing us of the corrective and preventive actions documented I

in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

. Original Signea by; Jacque P. Durr

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Chief, Engineering Branch Division of Reactor Safety l

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S. LaBruna, General Manager, Hope Creek Operations Scott B. Ungerer, Manager, Joint Generation Projects Department, Atlantic Electric Company L. A. Reiter, General Manager - Licensing and Reliability Rebecca A. Green, Bureau of Radiation Protection Public Document Room (PDR)

i Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey b

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S. LaBruna, General Manager, Hope Creek Operations Scott B. Ungerer, Manager, Joint Generation Projects Department, Atlantic Electric Company L. A. Reiter, General Manager - Licensing and Reliability Rebecca A. Green, Bureau of Radiation Protection Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey

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Region I Docket Room (with concurrences).

Management Assistant, DRMA (w/o encl)

DRP Section Chief Robert J. Bores, DRSS t

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i Pubhc Service Electric and Gas Company Steven E. Miltenberger Pubhc Service Electric and Gas Company P.O. Box 236, Hancocks Rndge, NJ 08038 609 339-4199 v<e mescene am cne Neea on<er NLR-N88084 May 2 6, 1988 U. S.

Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 Gentlement REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-354/88-03 DOCKET NO. 50-3 54 HOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSE&G) is in receipt of your letter, dated April 27, 1988, which transmitted a Notice Violation involving a failure to comply with the requirements of 10 CFR 50, Appendix B, Criteria V.

Pursuant to the provisions of 10 CFR 2.201, our response to the Notice of Violation is provided in Attachment 1.

Sincerely, AJ A

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d Attachment C

Mr.

W. T. Russell, Administrator USNRC Region I Mr. G. W. Rivenbark USNRC Licensing Project Manager

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Mr. G. W. Meyer USNRC Senior Resident Inspector

Mr.

D. M. Scott, Chief Bureau of Nuclear Engineering

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Department of Environmental Protection

380 Scotch Road Trenton, NJ 08 628 r>

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O ATTACHMENT 1 10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NUMBER 50-354/88-03 As described in Appendix A of your April 27, 1988 letter, 10 CPR 50, Appendix V states, in part, that: "Activities affecting quality shall be accomplished in accordance with instructions, procedures...".

Procedure number VPN-MSP-07, Section 8.2.1 states, in part, that : "The use of whiteout and/or obliteration is not permitted on Quality Assurance records.

Changes shall be made by a single line drawn through the item with new information written in, initialed and dated."

Contrary to the procedural requirements, on January 29, 1988, EQ files were found with whiteout changes and/or deletions of original text and the changes had not been initialed or dated.

This was identified as a Severity Level V violation.

1.

PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.

I 2.

THE ROOT CAUSE OF THE VIOLATION WAS PERSONNEL ERROR IN NOT COMPLYING WITH THE PROCEDURE, VPN-MSP-07.

3.

IMMEDIATE CORRECTIVE ACTIONS:

A memorandum was distributed on February 4, 1988, instructing'

those personnel responsible for the equipment qualification program to adhere specifically to the procedural requirements of VPN-MSP-07, Section 8.2.

This instruction was reenforced on February 9, 1988, during a staff meeting with the i

responsible group.

A sample of the EQ files was reviewed to determine the extent of the use of whiteout and/or correction tape, and any other lack of compliance with the requirements of VPN-MSP-07, Section 8.2.

The results of the review indicated that only

"Review Checklists", which are used by the EQ engineers in their review of Vendor Test Plans and Qualification Reports, contained non-conforrances with the subject VPN procedural requirement,

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ATTACHMENT 1 (CONT'D)

A four hour training class was held on April 11, 1988 to clarify to all engineers working on our Salem and Hope Creek Generating Stations' EO files, proper preparation, review and updating techniques for EQ file binders.

4.

ACTIONS TAKEN TO PREVENT RECURRENCE:

Programmatic Standard, DE-PS.ZZ-0002(0)-A6, "Audit Binder Control", will be revised to specifically address the methods of updating documents and to reenforce the prohibition of the use of whiteout and/or correction tape on OA records.

PSE&G will restructure the Hope Creek Generating Station Equipment Qualification files.

An implementation plan and schedule for this effort will be submitted to the NRC by June 30, 1988.

During the implementation of this program, PSE&G will examine, particularly, methods to reenforce proper correction techniques for all EQ files.

5.

WE ARE IN FULL COMPLIANCE.

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