ML18095A559
| ML18095A559 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 10/19/1990 |
| From: | Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| Shared Package | |
| ML18095A560 | List: |
| References | |
| NUDOCS 9011050411 | |
| Download: ML18095A559 (4) | |
See also: IR 05000272/1990010
Text
- -
Docket Nos. 50-272
50-311
50-354
Public
ATTN:
P. 0.
Service Electric and Gas CompanY
Mr. Steven E. Miltenberger
Vice President and
Chief Nuclear Officer
Box 236
Hancocks Bridge, New Jersey 08038
Gentlemen:
OCT 1 0 1990
Subject: Inspection Nos.
50-272/90~10, 50-311/90-10 and 50-354/90-07
This letter refers to your June 28, 1990, letter in response to the subject
inspection of your Fitness-For-Duty (FFD) program and a Management Meeting,
held on July 19, 1990, at the Artificial Island Generating Station, to discuss
the findings of that inspection.
The attendees are listed in Details,
Paragraph 1 of the enclosed Meeting Report.
Your agenda for the meeting is *
attached to the re~ort (Attachment 1).
At the meeting, we discussed several inspection findings, which you questioned,
and several statements, which you considered to b~ inaccurate, as well as your
concern that the tone of the report is negative and would lead a reader to
surmise that the FFD program being implemented at Artificial Island is less
than fully responsive to the NRC rule (10 CFR 26).
On this last issue, I want
to make it clear that the inspectors found your FFD program to be very
responsive to the spirit and intent of the NRC rule, and its implementation, in
terms of resources, equipment and facilities, to be commendable.
Nevertheless,
as we agreed during the subject meeting, there are certain aspects bf the NRC
rule where implementation procedures need further clarification. It is our
desire to identify and resolve those quickly, and this was one of the primary
objectives of our meeting.
Based on the information exchanged during the meeting, three items in the
inspection report will be revised.
The first revision is- to the Findings, Paragraph 4, and Details, Paragraph*
7.b., of the inspection report.
The revision relates to the predictable gap
- in random testing over weekends and between 7:00 p.m. and 6:00 a.m. on
weekdays~- Since issuance of the inspection report, we have determined that
this matter should have been addressed as an Unresolved Item rather than a
9011050411 901019
ADOCK 05000272
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OFFICIAL RECORD COPY
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Public Service Electric and Gas
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2
OCT 1 9 1990
non-cited Violation because of the problem in the interpretation of 10 CFR 26
in that regard.
Our records will be modified accordi~gly.
We also note that
your response to the inspection report states that random testing is performed
on some weekends and holidays and that you have committed to conduct random
testing on at least one holiday and one weekend day per quarter.
We were not
aware of this commitment during the inspection.
The second revision is to the Findings, Paragraph 5, and Details, Paragraph
lb.
The revision pertains to the changing of a laboratory procedure which
impacts chain-of-custody.
We have determined that the written procedure was
adequate if properly adhered to, and that subsequent measures were taken to
ensure that laboratory technicians complied with the procedure.
The third revision is to the details, Paragraph S(e), and involves searches
with drug detection dogs as a means of achieving the goal of a drug-free
workplace.
That statement was intended to suggest one method of how a licensee
might achieve that goal.
It was not intended that the use of drug detection
dogs is an NRC requirement nor that the use of dogs is the only method of
aGhieving that goal.
An inaccuracy appeared in our May 18, 1990, letter that transmitted the
inspection report to you.
That inaccuracy involves Paragraph 4 of the letter.
We now understand that no change was made to your process for randomly testing
those persons who have infrequent access to the plants but rather, that such a
change is being contemplated.
The inspection report and the May 18, 1990, letter which transmitted the
inspection report to you have been revised to accurately reflect the foregoing.
The enclosed Meeting Report documents our discussions relative to the other
inspection findings that you questioned and provides the current NRC position
on those issues.
The inspection of your program was the first formal FFD
inspection conducted by the NRC.
Inspections of other licensees, nationwide,
are underway.
We fully expect that other questions concerning the implementa-
tion of 10 CFR 26 will occur, and as previously stated, we will attempt to
resolve them expeditiously.
We appreciate the information that was provided during .the meeting and believe
the meeting was mutually beneficial in further understanding your program.
If
you have any concerns with the enclosed meeting report, please do not hesitate
to contact me.
Cop~es of the revised documents, the inspection report and the letter of
transmittal, will be forwarded separately .
OFFICIAL RECORD COPY
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Public Service Electric and Gas
Company
3
OCT 1 9 7990
Your cooperation with us in this matter is appreciated.
Sincerely,
Original Signed By:
Maicolm R. Knapp
Enclosure:
Management Meeting Report
cc w/encls:
S. Labruna, Vice President-Nuclear
Malcolm R. Knapp, Director
Division of Radiation Safety and
Safeguards
J. J. Hagen, General Manager, Hope Creek-Operations
J. Urban, General Manager, Fuels Department, Delmarvi Power & Light Co.
L. K. Miller, General Manager - Salem Operations
C. P. Johnson, Manager - Quality Assurance Nuclear Operations
B. A.
Presto~, Manager, Licensing and Regulation
J. H. Walter, Chief Engineer, Public Service Commission of Maryland
General Manager - Nuclear Safety Review
M. J. Wetterhahn, Esquire
R. Fryling, Jr., Esquire
S. B. Lingerer, Manager, Joint Generation Projects Department,
Atlantic Electric Company
Licensing Project Manager, NRR
J. Lipot, State of New Jersey
D. Wersan, Assistant Consumer Advocate, Office of Consumer Advocate
R. F. Engel, Deputy Attorney General, Dept. of Law and Public Safety
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
OFFICIAL RECORD COPY
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Public Service Electric and Gas
Company
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
J. Joyner, DRSS
Section Chief, DRP
J. Caldwell, EDD
4
OCT 1 9 1990
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