ML18092A759

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Forwards Response to Nuclear Oversight Committee Seventh Quarterly Rept,Including Design Change Requests,Nuclear Dept Policy Manual,Safety Review Mgt & Site Protection & Emergency Preparedness
ML18092A759
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/28/1985
From: Corbin McNeil
Public Service Enterprise Group
To: Varga S
Office of Nuclear Reactor Regulation
References
NUDOCS 8509090055
Download: ML18092A759 (5)


Text

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Public Service Electric and Gas Company Corbin A. McNeill, Jr.

Vice President -

Public Service Electric and Gas Company P.O. Box236, Hancocks Bridge, NJ 08038 609 339-4800 Nuclear August 28, 1985 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, DC 20555 Attention:

Mr. Steven A. Varga, Chief Operating Reactors Branch, No. 1 Gentlemen:

NUCLEAR OVERSIGHT COMMITTEE RESPONSE TO QUARTERLY REPORT SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Enclosed for your information is a copy of our response to the August Quarterly Report o.f our Nuclear Oversight Committee.

Should you have any questions, do not hesitate to contact us.

Enclosure C

Mr. S. J. Collins, Chief Projects Branch No. 2, DPRP Region 1 Mr. Donald C. Fischer Licensing Project Manager Mr. Thomas J. Kenny Senior Resident Inspector I

.8509090055 B~ggij~72

Sincerely,

NUCLEAR DEPARTMENT RESPONSE TO THE SEVENTH QUARTERLY REPORT OF THE NUCLEAR OVERSIGHT COMMITTEE AUGUST 28, 1985


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RESPONSE TO THE SEVENTH QUARTERLY REPORT OF THE NUCLEAR OVERSIGHT COMMITTEE This response addresses the concerns expressed by the NOC in their Quarterly Report dated August 1, 1985.

1.

DESIGN CHANGE REQUESTS (DCR).AND DESIGN CHANGE PACKAGE (DCP).

Statement. of Concern The NOC would like to see an independent assessment of the 5 to 15 DCRs which might have been implemented beyond the 245 selected.

This assessment should emphasize whether the failure to implement these 5 to 15 design changes would have a serious impact on plant and personnel safety, on regulatory commitments, or on plant performance and operability.

The NOC suggests that a similar but much more cursory independent evaluation be made of all of the DCRs deferred.

Res,Eonse Although an initial assessment was made of all cancelled and deferred DCRs, Nuclear Engineering and Plant Betterment Department has conducted an additional indepth review of the next 15 DCRs beyond the 245 selected for nuclear safety and regulatory impact.

None of these 15 DCRs were found to have a significant safety impact on the plant, although several did involve regulatory commitments.

These commitments are currently under review for determination of our continued support of the need for such commitments.

Any reliability issues posed by the backlog reduction program will be addressed in an integrated manner by our ongoing reliability program.

Additionally, the Offsite Review Group of the Nuclear Safety Review Department is conducting an independent but more cursory review of all of the involved DCRs for nuclear safety impact.

At the point in this review where 350 of the involved DCRs had been reviewed, no significant safety impacts were found to result from the program.

2.

ACTION PLANS Statement of Concern The NOC expressed a concern with regard to changes that have been made to certain Actions Plans:

2.1.3 -

Nuclear De12artmentPolicy.ManuaL and su1212orting_

Procedures The change shifts the follow-up assessment originally scheduled for November 1985 to be performed by the procedure development team and replaces it with a QA audit to be performed in mid-1986.

The NOC sees no problem associated with the proposed change to a QA assessment, but asks whether the assessment should be delayed that long.

2.2.l -

Safet~ Review Management According to the material supplied, the implementation of the new safety review process will take place in mid-July and no further action plan activities are required.

The NOC comments that this decision depends on how action plan implementation is carried out in this area.

The NOC feels the need for a fuller discussion of this whole area at the next NOC meeting.

2. 2. 2 -

Cammi tment.Identification,. Tracking__ and Closeout The scope of the commitment tracking system has been reduced.

The NOC wishes to better understand the features that have been eliminated and proposes to review them at its next meeting.

2.4.4 - Site Protection and Emergency Pre12aredness Completion criteria for close-out of this Action Plan were changed to allow implementation as follow-up activities.

A QA audit of program effectiveness has been scheduled for mid-1986.

The NOC would like to discuss the schedule for implementation and the long time interval before the QA audit, in the light of recently reported difficulties in Emergency Preparedness.

2.6.2 - Maintenance Planning, Monitoring and Control Interim systems were developed, upgraded, and implemented instead of an integrated computerized maintenance information system.

The NOC agrees with the interim action taken but it would like to review its effectiveness in meeting the original objective.

2.6.4 -

Measuring and Test Equipment According to the material provided, remaining activities have been completed.

This does, however, leave some questions about implementation.

In particular, there remains a large I&C Inspection and Work Order backlog; the NOC would like to hear how Salem Station will address this.

2.7.3 -

Information Systems Integration of the information systems is being deleted from the Action Plan.

The NOC agrees with the proposed action but it wishes to review the new plan in more detail.

ResEonse 2.1.3 Establishment of the schedule for the QA assessment of this function took into account a sufficient implementation period after various action plans were completed such that a meaningful evaluation could be performed.

Also considered were changes resulting from the Nuclear Department functional reorganization which occurred in July 1985.

Routine on-going QA Audits normally address various aspects of the implementation of procedural programs of the individual auditee organization and do provide a measure of assessment relative to this Action Plan.

However, overall assessment was deemed to be more effective if conducted in the mid 1986 time frame.

As a result of the NOC's concern, the schedule for the QA Assessment will be accelerated such that it will be initiated in March, 1986.

2.2.1, 2.2.2, 2.4.4, 2.6.2, 2.6.4, 2.7.3 The NOC's concerns with regard to these Action Plans will be discussed at the September Quarterly Meeting.