ML18100B171
| ML18100B171 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/27/1994 |
| From: | Tosch K NEW JERSEY, STATE OF |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9407050142 | |
| Download: ML18100B171 (2) | |
Text
)_/
l Robert C. Shinn, Jr.
Commissioner State of New Jersey Department of Environmental Protection and Energy Division of Environmental Safety, Health, and Analytical Programs Radiation Protection Programs Bureau of Nuclear Engineering CN 415 Trenton, New Jersey 08625-0415 Tel (609) 987-2032 Fax (609) 987-6354 June 27, 1994 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
Hope Creek and Salem Generating Stations Docket Nos. 50-272, 50-311, and 50-354 Amendment to the Facility Operating License License Change Requests 94-05 and 94-10 The subject request was submitted to the NRC by Public Service Electric and Gas *on April 13,* 1994.
The request proposes to remove currently specified audit frequencies from the Technical Specifications.
Audit frequencies will be added to the Quality Assurance (QA) program descriptions contained in the Hope Creek and Salem Updated Final Safety Analysis Reports (UFSAR).
Existing audit frequencies vary from 6 months to 2 years.
A frequency of 2 years is proposed to be added to the QA program for all audits, except audits of the Security and Emergency plans.
The New Jersey Department of Environmental Protection and Energy's Bureau of Nuclear Engineering (BNE) has reviewed the request in accordance with the requirements of 10 CFR 50.9l(b).
Our comments are delineated below.
We note that PSE&G' s letter justifies this change on the basis that added flexibility in scheduling audits will be gained so that resources can be allocated to areas with perceived weaknesses.
However, PSE&G includes this change as a Cost Beneficial Licensing Action.
PSE&G estimates that under "optimal conditions" the proposed change will yield a $2.4 million cost savings.
From this, we conclude that, overall, PSE&G intends to reduce the resources committed to their audit program, not reallocate resources to weaknesses.
The purpose of this change should be clarified.
We concur with the proposed change for the Hope Creek Station.
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Conversely, the change should not be approved for the Salem station at this time.
In response to operating events, NRC violations and PSE&G's own initiative, reorganization of plant staff including numerous personnel changes are underway at Salem. At this critical time, extending audits of Salem activities to a 2 year frequency is clearly not appropriate.
It would make sense to apply auditing resources saved at Hope Creek to performing better audits at Salem on the existing frequency.
Please contact Rich Pinney at (609) 987-2086 or Suren Singh at (609) 987-2039 if you need further information.
c :
A. McMahon N.J. DEPE M. c. Modes Sincerely, Kent W. Tosch, Manager Bureau of Nuclear Engineering NRC Materials Section Branch Chief D. Chawaga NRC Region 1 State Liaison Officer
- c. Marschall NRC Sr. Resident Inspector J. Stone NRC Project Manager F. Thomson PSE&G