ML18102A236

Responds to NRC 960422 Ltr Re Violations Noted in Insp Repts 50-272/96-05,50-311/96-05 & 50-354/96-05 on 960225-0406. Corrective actions:960419 Osr Segregated & Assigned Into Two Groups & Qualification Matrix Developed for Osr Engineers

ML18102A236
Person / Time
Site:	Salem, Hope Creek
Issue date:	05/22/1996
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A235	List: ML18102A236
References
2.201, LR-N96132, NUDOCS 9607080388
Download: ML18102A236 (7)

Text

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\/ .. Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations MAY 2 2 1996 LR-N96132 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION INTEGRATED INSPECTION REPORT 50-272/96-05, 50-311/96-05 SALEM GENERATING STATION UNIT NOS. l AND 2 DOCKET NOS. 50-272 AND 50-311 HOPE CREEK GENERATING STATION UNIT NO. 1 DOCKET NO. 50-354 Inspection Report Nos. 50-272/96-05 and 50-311/96-05 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public s~rvice Electric & Gas Company (PSE&G) on April 22, 1996.

Within the scope of this report, a violation of NRC requirements was cited.

Pursuant to the provisions of 10CFR2.201, PSE&G submits its response to the aforementioned violation in Attachment I to this letter. This response is applicable to both Salem and Hope Creek Generating Stations.

Should there be any questions regard:~*ng this submittal, please do not hesitate to contact us.

Sincerely, Attachment (1)

• Q Printedon

• ~ Recycled Paper 9607080388 960702 PDR ADOCK 05000272 G PDR

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Document Control Desk MAY 2 2 1996

• LR-N96132 c J Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olsh~n, Licensing Project Manager - Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike M.ail Stop 14E21 Rockville, MD 20852 Mr. D. Jaffe., Licensing Project Manager - Hope Creek U. s. Nuclear Regulatory Commission One White Flint North.

11555 Rockville Pike Mail stop 14E21 Rockville, MD 20852 Mr. c. Marschall - Salem (X24)

USNRC Senior Resident Inspector Mr. R. Summers (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

V.

Attachment I LR-N96132 APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Nos. 50-272 Salem Nuclear Generating station 50-311 Units 1 and 2 50-354 Hope Creek Generating Station License Nos. DPR-70 DPR-75 DPR-57 During an NRC inspection conducted on February 2S, 1996 - April 6, 1996, a violation of NRC requirements was identified. In accordance with the "General statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30, 1995), the violation is listed below:

Unit 1 Technical Specification {TS) 6.5.2.2 and Unit 2 TS 6.5.2.2 require, in part, that each Salem unit will have an Offsite Safety Review staff {OSR) and an Onsite Safety Review Group (SRG), consisting of at least four dedicated, full-time engineers. TS 6.5.2.2, for each unit, also requires that the SRG and OSR engineers meet or exceed the qualifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.

Contrary to the above, during the inspection period the resident inspectors determined that each Salem unit did not have an OSR and SRG consisting of at least four dedicated, full-time engineers; and that the SRG and the OSR engineers did not meet or exceed the quelifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.

This is a Severity Level IV violation.

PSE&G concurs with the violation, in that not all Te~hnical Specification 6.5.2.2 requirements were met.

• ..~ .

Attachment LR-N96132 (1) The reason for the violation.

The root cause of this violation is attributed to failure of management to:

1. Maintain the appropriate controls over organizational structure changes to validate compliance with the licensing bases, and

2. Ensure that all applicable requirements of the ANS Standard were reviewed to verify alignment with the appropriate Nuclear Administrative Procedure (i.e., NC.NA-AP.ZZ-0014(Q),

(NAP-14) "Training, Qualification and Certification").

The 1981 Salem TS for both Units 1 and 2 contained an organizational chart identified as: nFIGURE 6.2-1 CORPORATE HEADQUARTERS AND OFF~SITE ORGANIZATION FOR MANAGEMENT AND TECHNICAL SUPPORT." This chart described the organizational structure -for both Salem Units 1 and 2, and showed a single "Safety Review Group" reporting to the General Manager - Nuclear Support. Since 1981 a number of License Change Requests (LCR) were submitted to clarify and modify the organizational chart.

In 1984, PSE&G submitted LCR 84-24 which also affected TS Section

6. This LCR modified the Nuclear Safety Review organization by creating an Offsite Safety Review (OSR) group and an Onsite Safety Review group. The OSR group was segregated into a Boiling Water Reactor (BWR) group and a Pressurized Water_ Reactor (PWR) group. The NRC's Safety Evaluation Report (SER) for LCR 84-24 (Amendments 62 and 33, which was one report addressing both Salem Units 1 and 2, respectively) acknowledged the change in Safety Review department nomenclature, and stated, in part:

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• The SRG, which meets the staff's requirements for an 11 Independent Safety Engineering Group, remains intact except that it now reports to the General Manager-Nuclear Safety Review ........ We find this change acceptable . . . "*

Regarding the OSR group, these organizational changes resulted in inappropriately crediting the supervisor of the Off-Site Safety Review_Engineering Group as a "dedicated engineer" toward the safety review function, and also failed to maintain the segregation between the Salem and Hope Creek OS~ groups. This resulted in a lack of clear delineation of responsibilities, I wnich led- ~otne-failure to dedicate four full-time engineers to I I

the Salem OSR group, and four full-time engineers to the Hope Creek OSR group .

'.J .

• Attachment LR-N96132 Certain individuals assigned to.the OSR and SRG positions do not hold a Bachelor's Degree in Engineering or related sciences.

Subsection 4.1 of the ANS standard, though not explicitly referenced in the Technical Specifications (TS) states that experience may be evaluated and used in lieu of a degree.

PSE&G's position was that Subsection 4.1 may be used to establish alternative qualifications and compliance with other subsections of Section 4 of the ANS Standard.

This interpretation is supported by the intent of the ANS Standard, and by the generally accepted principles for inclusion of, and adherence to, "referenced" documents. Subsection 4.1 also states that, when experience is substituted for education, the other compensating factors must be documented and approved by the Plant Manager. Although the appropriate documentation was approved, the approval was not obtained as prescribed in the ANS Standard.

(2) The corrective steps that have been taken.

1. On April 19, 1996, the OSR organization was segregated and assigned into two separate groups of four dedicated, full-time engineers. One group is dedicated to Hope Creek; the other is dedicated to Salem Station. A single supervisor provides oversight and direction to both groups and reports to the Manager - Nuclear Safety Review.

2. A qualification matrix has been developed for OSR engineers identifying the specialty areas in which they possess the appropriate years of professional levei experience.

3. The SRG and OSR staff engineer's education equivalency forms have been approved by the Salem and Hope Creek Plant Managers.

4. Prior to the issuance of this violation, PSE&G submitted two LCRs, on January 11, 1996, to relocate the review and audit functions of Section 6.5 of the Salem and Hope Creek Generating Stations Technical Specifications to the PSE&G QA program.

(3) The corrective steps that will be taken to avoid further violations.

1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted. The results of this review will be used to determine additional corrective actions.

The review will be completed by June 28, 1996 .

• '* . Attachment - 4

• LR-N96132

2. PSE&G will evaluate NAP-14 to assure that qualification and*

documentation approval requirements, as specified in the ANS Standard, are clearly reflected within the procedure. This action will be completed by July 1, 1996.

3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to re-emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996.

(4) The date when full compliance will be achieved.

PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled; This vacant position is expected to be filled by June 30, 1996.

In addition, PSE&G is also requesting*to change the Quality Assurance program via 10CFR50.54a to allow realignment of the Quality Assurance (QA), NSR, and Nuclear Review Board (NRB) functions. It is expected that this request will be submitted by May 31, 1996. This request will also specify that QA. (only those assigned to perform the independent review function) , and NRB personnel will meet or exceed the qualification requirements of applicable sections of ANSI/ANS 3.1 - 1981, "American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants." By this action the appropriateness of applying Section 4.1 to other subsections of. Section 4 of *the ANS Standard will be clearly established.

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,. - The following lists all commitments made by PSE&G, in letter LR-N96132, with their respective due dates.

1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted. The results of this review will be used to determine additional corrective actions.

The review will be completed by June 28, 1996.

2. PSE&G will evaluate NAP-14 to assure that qualification and documentation approval requirements, as specified in the ANS standard, are clearly reflected within the procedure. This action will be completed by July l, 1996.

3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to re-emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996.

4. PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was

• segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled. This vacant position is expected to be filled by June 30, 1996.