ML20113A393
| ML20113A393 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/03/1985 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-85-022, EA-85-22, NUDOCS 8504100276 | |
| Download: ML20113A393 (7) | |
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OPSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038 609 339-4800 Corbin A. McNeill Jr. Vice President - Nuclear April 3, 1985 Mr. James M.
Taylor, Director Office of Inspection and Enforcement U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Taylor:
NRC ENFORCEMENT ACTION 85-22 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company is in receiyt of the referenced Enforcement Action, dated March 25, 1983, and the enclosed Notice of Violation and Proposed Imposition of Civil Penalties.
This letter constitutes our response to that document.
Pursuant to the requirements of 10 CFR 2.201, Attachment A hereto addresses the items of violation identified.
PSEhG management has reviewed Enforcement Action 85-22 and acknowledges that the deficiencies cited had occurred.
We concur with the NRC conclusion that the PSE&G program of short-and long-term corrective actions should preclude recurrence of the violations.
PSE&G management is aggressively pursuing implementation of this program.
The Company will not protest the imposition of the civil penalty.
A check in the amount of $50,000 is enclosed in payment of the civil penalty.
Sincerely,
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Attachment 8504100276 850403 PDR ADOCK 05000272 G
PDR l
jti:Iv The Energy People
Mr. Jr_OOs'M. Thylor~ 4-3-85 P
C Dr. Thomas'~ E. Murley, Regional Administrator Region 1 Mr.' Donald C.
Fischer Licensing Project Manager Senior. Resident Inspector P
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3 STATE OF NEW JERSEY'
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)SS.
' COUNTY OF ESSEX
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. CORBIN A. MCNEILL, Jr., being duly sworn according to law deposes.and says:
I I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in the attached response to the NRC's Notice of Violation and Proposed Imposition of Civil Penalties, Docket Nos. 50-272, 50-311, License Nos. DPR-70, DPR-75, EA 85-22, are true to the best of my knowledge, information and belief.
T CORBIN A. MCNEILL, JR.
Subscribed and sworn to before this 3RD day of April, 1985.
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N ARY PUBEIC OF NEW JJrRSEY
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My Commission expires *
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Ak ATTACHMENT A ww STATEMENT OP VIOLATION
' Item A 10 CFR50.47(b) (15) requires.that adequate provisions exist in the emergency plan to ensure that radiological emergency response training is provided to those who may be called on to assist in an emergency.
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Section 16.1 of the Salem Generating Station Emergency Plan states that. station personnel and personnel assigned to the emergency organization will receive general and specific emergency plan'and. procedure training, respectively, depending on their assignments.
j g Contrary.to.the above:
Certain station personnel and personnel assigned to the
-emergency organization had not received appropriate general and-specific emergency plan-and procedure training, as Levidenced-by the following:
1.
. Four Senior Shif t Supervisors and nine personnel assigned as Communicators 1Ln the emergency organization
.were unable to properly use~the Emergency Classification Guide and accompanying notification forms, as determined by interviews conducted'during the November 5-9, 1984 inspection.
Six personnel assigned to collect data and perform dose
- 2..~ assessment during the initial activation of the emergency organization had not received adequate training, as determined by interviews conducted during the November 5-9, 1984 inspection, in that:
a.
-four'of the six individuals had not received specialized training in radiological assessment; and
- b.
two.of.the six personnel had not received the emergency response training delineated in Section 16 of the emergency plan.
3.
As of September 1983, 16 of 52 emergency response personnel had not received initial classroom training and 36 emergency response personnel had not received the required annual classroom retraining, as identified in
- PSE&G aud it. No. S-8 3-21.
Response to Item A '
l.
PSE&G DOES NOT DISPUTE THE ALLEGED VIOLATION.
L _ _ _ _ _ _ _. _ _ _ _
2.
REASONS FOR THE VIOLATION:
The root cause of this violation was lack of an adequate training program to cover the requirements of the-emergency : plan and a lack of organizational discipline to assure that all emergency response personnel had received the required training.
3.
IMMEDIATE CORRECTIVE ACTIONS AND RESULTS ACHIEVED:
An assessment of essential functions for emergency response was made.
Training of each shift in the use of the Event Classification Guide and notification responsibilities was conducted.
Verbal interviews were administered to assess comprehension and the results were satisfactory.
These actions were completed-in December 1984..
4.
~LONG TERM CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
A comprehensive emergency response training program is being developed.
Performance will be evaluated through examinations and Quality Assurance reviews.. Discipline to assure attendance at training will be enforced.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by September 1985.
STATEMENT OF VIOLATION Item B L
10 CFR 50.47(b)(14) requires that the emergency plan contain provisions to ensure that periodic exercises are conducted to evaluate major portions of emergency response capabilities and that deficiencies identified as a result of exercises or drills will be corrected.
10 CPR 50.54(t) requires that all nuclear power reactor licensees provide for the development, revision, implementation, and maintenance'of their emergency preparedness prog ra ms.
To this end, the licensee shall provide for a review of its emergency preparedness program every 12 months by perscns who have no direct responsiblity for implementation.
The review shall include an evaluation for adequacy of licensee drills, exercises, capabilities, and procedures.
The results of the review, along with recommendations for improve-ments shall be documented, reported to the licensee's corporate and plant nanagement, and retained for a period of five years.
,,- 3 s
Contrary. to the above As of November 9, 1984, the emergency preparedness program was not adequately implemented and maintained in that several deficiencies in' the - program were identified by PSE&G personnel during. quality assurance audits and. emergency drills conducted in 1983 and 1984, but actions-were not taken to promptly correct the identified deficiencies, as evidenced. by the following:
l '. During an audit conducted in September 1983, (PSE&G Audit No.
S-83-21),
a.
- The audit team identified that the Operations Support Center was not activated during the September 1983 ' drill because of a lack of-training.
A similar deficiency was again identified by PSE&G during an August 1984 drill.
The PSE&G observer noted that the Operations Support Center Coordinator had not received adequate training in his responsibilities.
This deficiency remained uncorrected and was identified during the October 1984 emergency exercise.
b.
The audit team identified deficiencies in the training of personnel required to perform in the emergency organization during a radiological emergency.
As a result of' deficiencies observed by PSE&G during a subsequent. training drill, an investigation was conducted which disclosed that numerous personnel had either received no training or had not recei ved the required annual retraining.
Howe ve r, the deficiencies remained uncorrected and were identified during the October 1984 annual excercise.
2.
During an audit conducted in July 1984 (PSE&G Audit No.
S-84-24), the audit team identified deficiencies with emergency communications equipment, eme rge ncy communications drills and callout tests, and telephone number updating.
The audit team also found that emergency equipment in the Control Room, Technical Support Center, Emergency Operations Facility, and Emergency Van was either missing or different than required in the procedures.
Subsequently, during August and Septemor 1984 drills, PSE&G observers identified deficiencies with both communications hardware and practices.
Howe ve r, the deficiencies remained uncorrected and were identified during the October 1984 annual exercise.
~3.
During an August 1984 drill, PSE&G evaluators identified deficiencies with the ability of individuals to use the Emergency Classification Guide (ECG) to identify the appropriate level of emergency.
These deficiencies remained uncorrected and were identified during the October 1984 annual exercise.
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4.
During) the performance of monthly communication drills between September L1983 and October.1984, dedicated notification telephone lines to the responsible states and surrounding counties were repeatedly identified as inoperative, in that:
a...the dedicated notification telephone line to the State of Delaware was inoperable, when tested, 8 of 11 times thereby indicating the inadequacy of the installed communications provisions.
b.
dedicated. telephone lines to several counties were also inoperable during the same. period; e.g., the line to. Kent County, Delaware was inoperable 7 of the ll-times tested.
These deficiencies remained uncorrected and were identified during the November 1984 NRC inspection.
Response to' Item B:
1.
PSE&G DOES NOT DISPUTE THE ALLEGED VIOLATION.
2.
REASONS FOR THE VIOLATION:
The root cause of the violation was insufficient manage-ment attention to timely resolution of identified deficiencies.
3.
IMMEDIATE CORRECTIVE ACTIONS AND RESULTS ACHIEVED:
'None.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
PSE&G's emergency preparedness organization has been
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significantly strengthened with. senior and experienced management personnel to assure adequate attention to deficiency resolution and the routine operation of the
' department.
The deficiencies and their corrective action programs have been entered on a tracking system.
Procedures are being developed to identify, track and close out these doficiencies, and to provide for issue escalation to senior management when' normal methods have not resolved the i:
issues.
The ef fectiveness of these ' actions will be audited by Quality Assurance.
5.
DATE WHEN PULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will' be achieved by September 1985.
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