ML18094A522

Responds to NRC 890331 Ltr Re Violations Noted in Insp Repts 50-272/89-03 & 50-311/89-03.Corrective Actions:Future Organizational Changes Affecting Content of Section 6 to Tech Specs Will Be Discussed W/Nrr Prior to Implementation

ML18094A522
Person / Time
Site:	Salem
Issue date:	06/09/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89118, NUDOCS 8906210242
Download: ML18094A522 (5)

Text

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• Public Service Electric and Gas Company en E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer JUN 0 9 1989 NLR-N89118 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC COMBINED INSPECTION REPORT 50-272/89-03 AND 50-311/89-03 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company {PSE&G) has received the subject inspection report dated March 31, 1989, which included a Notice of Violation"concerning failure to obtain a license amendment prior to implementing an organizational change.

Pursuant to the requirements of 10 CFR 2.201, our response to this Notice of Violation is provided in the attachment to this letter. _

Should you have any questions in regards to this transmittal, do not hesitate to call.

sincerely,

/~z~t!lr:br Attachment 8906210242 890609 PDR ADOCK 05000272 G PNU

. i Document Control Desk 2 NLR-N89118 JUN O 9 1989 c Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

REF: PSE&G letter NLR-N89118 STATE OF NEW JERSEY SS.

COUNTY OF SALEM Steven E. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated JUN o*9 1009 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.

Subsc::ribed and Sworn (} before me this 9fA day of ~AUl , 1989

~J~14'1~aJ Notary Public of New Jersey DELORIS D. HADDEN ANotary Public of New Jersey My Commission expires on MJCommission£xpiresMarchl4,1990

VIOLATION This violation was characterized as follows in Inspection Report 272/311-89-03.

"Technical Specification 6.5.2.2 requires, in part, that the composition of the Nuclear Safety Review Department include the Manager - Onsite Safety Review Group, who is supported by at least four dedicated, full-time engineers.

Contrary to the above, as of April 30, 1989, the composition of the Onsite Safety Review Group consists of an Onsite Safety Review Engineer who is supported by three other full-time engineers."

To clarify this violation, excerpts of the Inspection Report follows:

" The inspector reviewed TS requirements, LCR 88-07 dated July 15, 1988, and related licensee response to NRC Request for Additional Information dated April 25, 1989, and held discussions with the licensee. The inspector concludes that the manning of the onsite safety review group (SRG) does not meet NSR composition requirements of a Manager - SRG and four dedicated, full-time engineers. The SRG consists of an onsite safety review engineer who is assisted by three full-time engineers. In addition, the inspector determined that the licensee has not submitted an LCR or provided justification for reduction in the manning for the SRG. Failure to meet the manning requirements of TS for the SRG is an apparent violation applicable to both units (272/89-03-03) 11 *

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION PSE&"G believes this violation to be self-identified since a License Change Request (LCR 84-01 Rev. 1) was submitted on October 6, 1986 requesting a change to the Onsite Safety Review Group (SRG) organization to reflect the current configuration.

That LCR remained essentially inactive at NRR until early 1988, when the NRC Licensing Project Manager requested that PSE&G restructure and resubmit the LCR for ease of review. Due to efforts by NRR to reduce the backlog of LCRs for Salem, resubmittal of this and other administrative LCRs was delayed, per NRR request, until this time.

Additionally, the discrepancy between the actual SRG organization and the Technical Specifications was the subject of Quality "

Action Report (QAR) MA-88-Q028-0, dated May 6, 1988. The QAR was closed by reference to this LCR.

Therefore, this violation is considered by PSE&G to be self-identified.

ROOT CAUSE The root cause of this violation was the failure to submit a LCR in a timely manner (i.e. prior to implementation of the organization change). This was caused in part by a belief at that time that it was an accepted industry practice that changes in organization could precede the formal LCR. This idea was reinforced by the response to Question 2.9 in NUREG 1022, "Licensee Event Reporting system," Supplement 1, dated February 1984., which states "However, if the requirement is only administrative and does not affect plant operation, then an LER is not required; for example, a change in the plants organizational structure that has not yet been approved as a Technical Specification change". Additionally, this change is identical to one previously reviewed and approved on the Hope Creek docket giving evidence that the change was not considered a risk to plant operation.

CORRECTIVE ACTIONS IMPLEMENTED PSE&G submitted an LCR to change the Technical Specifications to reflect the current configuration in October 1986. At the request of the NRC Licensing Project Manager, this LCR is being revised to clarify the numerous changes incorporated in the LCR.

This LCR will be submitted by June 30, 1989.

CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Any future organizational changes affecting the content of Section 6 to the Technical Specifications will be discussed with NRR and..approv~d prior* to implementation. A License Change Request will be submitted to reflect the proper configuration.

Implementation will precede the issuance of a formal license amendment only with the specific approval of NRR. A letter has been issued from the Vice President - Nuclear Engineering to all Managers and above to emphasize that changes to Section 6 of the Technical Specifications must be preceded by a License Amendment prior to implementation of the change.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved upon approval of the pending LCR by the NRC NRR. Approval is estimated to be in December 1989 based on a June 30, 1989 submittal of the revised LCR.