ML19031B587

12/16/1977 Letter Response to Items of Noncompliance Identified in Inspection Report No. 05000272/1977036

ML19031B587
Person / Time
Site:	Salem
Issue date:	12/16/1977
From:	Schneider F Public Service Electric & Gas Co
To:	Grier B NRC/IE, NRC Region 1
References
IR 1977036
Download: ML19031B587 (3)

Text

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9erick W. Schneider *Public Service Electric and Gas Company 80 Park Place Newark, N_.J. 07101 201/430-7373 Vice President Producticin December i6, 1977 Mr. Boyce H. Griei Director of USNRC Off ice of Inspection and Enforcement Region 1 631 Park Avenue King of.Prussia, Pennsylvania

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Dear Mr. Grier:

. *NRC INSPECTION REPORT NO. 50-272/77-36 INSPECTION DATE NOVEMBER 8-10, 1977 UNIT NO. 1 SALEM NUCLEAR GENERATING STATION we have reviewed your inspecti6n report dated Nov~mber 23, 1977, and recieved on November 28, 1977. The following inform~tibn is provided as response to the items of noncompliance identified in your report:

• Item A, Deficiency Technical Specification 6.8_.2 requires that procedures identified in 6.8.l which includes administrative procedures be periodically reviewed as set forth in Administrative Procedures.

Contrary to the above, as of November 10, 1977, periodic review requirements for administrative procedures had not been es-tablished.

It~rn A, Respohs~

The Administrative Procedures (AP's) are implementing documents for. the Operational Quality Assuranc_e Program, AP-17, *which does have a periodic review commitment that includes its implementing documents. There~ore, ~ review commitment for AP's does exist~

However, to clarify this rnatter,.AP-1, "Adrniriistrative Proced0re Program", will be revised to include periodic review requirements specifically for AP's. This revision will be implemented by February,15, 1978.

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• ~ Dir.. rJ'f U.SNRC 12-16-77 Item B, Infraction 9 Technical Specification 6.3.1 states, in part, "Each member of the facility staff shall meet. or exceed the minimum qualifications of ANSI Nl8.l-1971 for comparable positions .. ;.'"

• ANSI Nl8.l-1971, Section 4.5.2 states, "Technicians .in responsible positions shall have a minimum of two years of working experience in their speciality. These personnel should have a minimum of one year of related technical training in addi~ion to their experience.

Contrafy to the above, a review of records and discussion with personnel on November 10, 1977, indicates th~t not all technicians responsible for maintenance, calibration, and surveillance of safety-related systems, possess* a minimum of pne year of r~lated technical training in addition to their expetience.

Item B, Response Our commitment io meet or exceed the minimum requirements of ANSI

'NlS .1-1971, "Standards for Selection and Training fo Personnel for Nuclear Power Plants", for the Salem station staff was based on complying with the 11 shall" requirements of the Standard .. This clearly doe~ not include the portion of Section 4.5.2, cited above as an infraction, which is a "should" recommendation.

Section 2.2.1 of Nl8.l-1971 defines the word "shall" as a re-quirement and the word "should" as a recomrr..endation. It further states that "In order to conform to this Standard, staff selection and training shall be in accordance with its requirements but not necessarily with its recommendations." We therefore feel that we are in compliance with our commitment and no corrective action is necessary.

The Company recognizes that highly-qualified and well-trained personnel are necessary to ensure safe and efficient operation of a nuclear generating station. To achieve and maintain this end, we practice preemployment screening, establish training programs, and perform periodic performance appraisals of employees. With respect to training, we are expanding our program at Salem by extending the Electric Production Department Apprentice Training Program to appropriate station personnel. Please be assured that we are committed to prbviding and maintairiing qualified and well-trained employ~es at our Salem Station.

If you have any questions concerning these matters, we will be pleased to discuss them with you.

cc Dr. Ernest Volgenau Bethesda, Maryland 20014

19/ l DEC 23 PM 12 34

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