ML20032A766
| ML20032A766 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/22/1981 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-81-071, EA-81-71, NUDOCS 8111020355 | |
| Download: ML20032A766 (3) | |
Text
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Public Serwce Electnc and Gas Cornpany Frederick W. Schneider 80 Park PLua, New.u k, NJ 07101 201 430 7373 Mmhng Address. P.O. Box 670, Newark, NJ 07101 Vice Presi@nt - Production and Assistant to Senior Vice Presi&nt -
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October 22, 1981 Mr. Victor Stello, Jr.,
Director p
A Office of Inspection and Enforcement U.S.
Nuclear Regulatory Commission b
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Washington, D.C.
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Dear Mr. Stello:
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SALEM GENERATING STATION UNIT NOS. 1^2
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pf, @'y DOCI'ET NO. 50-272 & 50-311 4.
Public Service Electric and Gas Company is in receipt of your letter of September 24, 1981, and the enclosed Notice of Violations and Proposed Imposition of Civil Penalty.
This letter constitutes our response to that document.
Pursuant to 10CFR2.201, ATTACHMENT A hereto addresses the three items listed in the Appendix to your letter.
The management cf PSE&G has reviewed your letter.
We consider the i tems of noncompliance to be a ser ious matter.
Immediately after becoming aware of the incidents, the NRC Resident Inspector's office was notified and remedial action was taken by corporate and station management.
These remedial actions are described in the responses to the violations.
We feel our prompt attention to the incident, timely corrective actions taken and our notification of the NRC Resident Inspector, demonstrate our concern for this incident, our desire to insure that these situations do not occur again and our ability and willingness to comply with NRC requirements.
Pu
.nt to 10CFR2.205, ATTACHMENT B hereto addresses our contention tha_ certain errors are contained in the Notice of Violations.
Although we are not protesting the factual occt-rence of the incidents, we are protesting the Severity Level in all instances.
Therefore, the remittance of $40,000 is being withheld until further review of ATTACHMENT B by the NRC and final disposition is determined.
ATTACHMENT C to this letter discusses the NRC's concern that PSE&G did not provide effective management oversight of the contractor security organization.
02023/(( Q 2 Egg
s', i Salem Generating Station 10/22/81 Units Nos. 1&2 Docket No. 50-272 & 50-311 The information contained in ATTACHMENTS A, B and C concern a subject matter which is exempt from disclosure according to Section
- 2. 790 (d) of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Accordingly, these should receive limited distribution. In closing, our overall response to these incidents demonstrates that imposition of a civil penalty of $40,000 is unjustified and excessive._ We believe that assessment of a civil _ penalty is not nece'~+'.ry to compel us to improve the performance of the Salem Generating Station Security Program. Further, we do not believe tnat the imposition of a civil penalty is a responsible and effective means of regulation within the language, goals and underlying purposes of the proposed general statement of policy and procedure for enforcement actions. Sincerely, /0 ? i l Attachment l
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A g STATE OF NEW JERSEY) ) SS: COUNTY OF ESSEX ) Frederick'W. Schneider, being duly sworn according to law deposes and says: I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated October 23, 1981, including Attachments A, B, and C, to Mr. Victor Stello, Jr. concerning Security Violations and Imposition of Civil Penalties, are true to the best of my knowledge, information, and belief. ~ 3.. TREDERICK W. SCHNEIDER-Subscribed and sworn to before me thisdMND day of -/L[itif,1981. /1 AtAL S. Ad M 066LJ Notary Public 'of New Jersey My Commission expires on d/. /,[ff3 i 4 0}}