ML18094A538

Responds to NRC 890522 Ltr Re Violations Noted in Insp Repts 50-272/89-10 & 50-311/89-09.Corrective Actions:Procedure GM8-DE-AP.ZZ-0016(Q) Revised to Provide Clarification for Procurement Classification of Items & Svcs,Per 10CFR71

ML18094A538
Person / Time
Site:	Salem
Issue date:	06/22/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89127, NUDOCS 8906290304
Download: ML18094A538 (5)

Text

\ I 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 2 2 1IB NLR-N89127 U. s. Nuclear Regulatory Commission Document Control Desk

.Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/89-10 AND 50-311/89-09 SALEM GENERATING STATION - UNIT NOS. 1 & 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) is in receipt of the subject inspection report, dated May 22, 1989, which issued a Notice of Violation concerning a failure to conduct an annual QA evaluation of an NRC approved Type A package supplier in accordance with 10 CFR 71.101 and the PSE&G Quality Assurance Program. - Pursuant to the provisions 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 with regard to this transmittal, please do not hesitate to contact us.

Sincerely, Attachment

~ri~

Q 6290304 Anocx 890622 osooo272 PNU I \

Document Control Desk 2 JUN I Z Bl NLR-N89127 c Mr. J. c. stone USNRC Licensing Project Manager Mrs. K. Halvey Gibson USNRC Senior Resident Inspector Mr. w. T. Russell, Administrator USNRC Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, New Jersey 08625

ATTACHMENT NLR-N89127 RESPONSE TO NOTICE OF VIOLATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION - UNIT NOS. 1 & 2 DOCKET NOS. 50-272 & 50-311 LICENSE NOS. DPR-70 & DPR-75 VIOLATION 11 10 CFR 71.101 states in part that "each licensee shall establish, maintain, and execute a quality assurance program *** satisfying any specific provisions which are applicable to the licensee's activities including the procurement of packaging". The licensee's Quality Assurance program procedure QAP 6-1, paragraph 5.1.2.2 states in part that "Major contractors who provide services in the station shall be evaluated annually". QAP 6-1, Attachment 4, Item 6.h. lists "Packaging and Transport of Radioactive Material per 10 CFR 71", as one of the activities to be audited and evaluated in accordance with the procedure.

Contrary to the above, the licensee rents an NRC approved Type A-package from NUPAC, but has not evaluated NUPAC since the initial pre-awards review in March 1987.

This violation has been categorized as a Severity Level IV problem (Supplement VII)."

RESPONSE

PSE&G DOES NOT CONTEST THE VIOLATION.

PSE&G is aware of the importance of conducting annual evaluations of shipping container vendors. In addition, we are fully cognizant of our responsibilities with regard to compliance with 10 CFR 71 and the PSE&G Operational Quality Assurance Program. This was an isolated occurrence and we do not contest the violation *

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ROOT CAUSE INADEQUATE PROCEDURES The implementing procedures associated with procurement classification and supplier controls specific to the procurement of items and services within the scope of 10 CFR 71 were determined to require further clarification and additional detail. The procedural deficiency resulted in the inappropriate classification of the purchase order associated with NUPAC.

PSE&G performed a review of shipment records for the past five years to determine if any additional suppliers of 10 CFR 71 items and/or services had not received an annual evaluation. None were identified; therefore, PSE&G believes this to be an isolated occurrence.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The actions taken to correct the concern identified in the subject Notice of Violation are presented below:

l.* PSE&G immediately obtained supportive data and performed an annual evaluation of NUPAC. The results of this evaluation were favorable.

2. Concurrently, PSE&G performed a review of shipment records for the past five years to determine if any other suppliers of 10 CFR 71 items/services had not received an annual evaluation., None were identified.

3. The Manager - Radiation Protection/Chemistry Services issued a letter on May 5, 1989, which clarified the requirements for the classification of radioactive material-related services and/or products.

ACTIONS TO PREVENT RECURRENCE The Nuclear Engineering Department has revised procedure GM8-DE-AP.ZZ-0016(Q) (Procurement Classification Guidelines) to provide clarification for the procurement classification of items and services within the scope of 10 CFR 71.

The following actions will be taken by July 30, 1989 to prevent recurrence:

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i'.I'

1. The Nuclear Quality Assurance Department will revise Quality Assurance Procedures M9-QAP 3-5 (Supplier Audits) and M9-QAP 6-1 (Quality Assurance Audits) to provide clarification with regard to supplier controls applicable to the procurement of items and services within the scope of 10 CFR 71.

2. For the next year, the Nuclear Quality Assurance Department will monitor the issuance of Purchase orders for the procurement of 10 CFR 71 items and services, on a sampling basis, to verify corrective action.

DATE FOR FULL COMPLIANCE Full compliance was achieved on May 5, 1989 when the annual evaluation of NUPAC was completed. Additional actions to prevent recurrence will be performed in accordance with the dates specified above.

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