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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/96-09
	ML20133E876
Person / Time
Site:	Hope Creek
Issue date:	01/08/1997
From:	Larry Nicholson; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Storz L; Public Service Enterprise Group
References
	NUDOCS 9701130188
	Download: ML20133E876 (3)
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January 8, 1997

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Mr. L. F. Storz, Senior Vice President

Nuclear Operations -

Public Service Electric & Gas Company

PO Box 236 l

Hancocks Bridge, NJ 08038 i

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SUBJECT: NRC INSPECTION NOS. 50-354/96-09

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Dear Mr. Storz

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i This letter refers to your Decemer 26,1996 correspondence, in response to our December ;

5,1996 letter. ;

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] Thank you for informing us of the corrective and preventive actions documented in your

! letter. These actions will be examined during a future inspection of your licensed program.

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Your cooperation with us is appreciated.

Sincerely,

ORIGINAL SIGNED BY

R0B DEPRIEST FOR:

Larry E. Nicholson, Chief l

Projects Branch 3

Division of Reactor Projects

Docket No. 50-354

9701130188 970108

PDR ADOCK 05000354

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Mr. L. F. Storz 2

cc:

L. Eliason, Chief Nuclear Officer and President - Nuclear Business Unit

E. Simpson, Senior Vice President - Nuclear Engineering

E. Salowitz, Director - Nuclear Business Support

D. Powell, Manager, Licensing and Regulation

A. Tapert, Program Administrator

J. Benjamin, Director - Quality Assurance & Safety Review

M. Bezilla, General Manager - Hope Creek Operations

i cc w/cy of Licensee's Letter:

I C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.

l R. E. Selover, Esquire

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M. Wetterhahn, Esquire

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P. MacFarland Goelz, Manager, Joint Generation Department,

Atlantic Electric Company

i Consumer Advocate, Office of Consumer Advocate

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W. Conklin, Public Safety Consultant, Lower Alloways Creek Township

R. Kankus, Joint Owner Affairs ,

State of New Jersey

State of Delaware

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Mr. L. F. Storz 3

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Distribution w/ copy of Licensee's Response Letter:

Region I Docket Room (with concurrences) ,

PUBLIC l

D. Jaffe, Project Manager, NRR

W. Dean, OEDO

J. Stolz, PDI-2, NRR

L. Nicholson, DRP

S. Barber, DRP

D. Screnci, PAO

Nuclear Safety information Center (NSIC)

NRC Resident inspector

Kay Gallagher, DRP

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DOCUMENT NAME: a: reply.hc

To receive e copy of this document, indicate in the boa: "C" = Copy without attachment / enclosure "E" = Copy eth attachment / enclosure

"N" = No copy

0FFICE RI:DRP g ,l RI:DRP /14 l \g '

RDePriest/Q/

NAME

DATE 1/7f97

LNicholson "' @

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0FFICIAL RECORD COPY

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Pubhe Serwce

Electne and Gas

Company

Louis F. Storz Pubke Service Electnc and Gas Com ny P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700

Senor V.ce President . Nuclear Operatens D C 2 61996

LR-N96435

United States Nuclear Regulatory Commission !

Document Control. Desk '

Washington, DC 20555

Gentlemen:

REPLY TO A NOTICE OF VIOLATION

OFFSITE SAFETY REVIEW STAFFING AND REVIEW ISSUES )

INSPECTION REPORT NO. 50-354/96-09-01 .

HOPE CREEK GENERATING STATION

FACILITY OPERATING LICENSE NPF-57 :

DOCKET NO. 50-354 !

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Pursuant to the provisions of 10CFR2.201, this letter submits the 1

response of Public Service Electric and Gas Company to the notice

of violation issued to the Hope Creek Generating Station (HCGS) !

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in a letter dated December 5, 1996, from L. Nicholson (NRC) to

L. Eliason (PSE&G). !

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Should you have any questions or comments on this transmittal, do l

not hesitate to contact us.

Sincerely,

.

Out2 -

L. F. Storz

Senior Vice President -

Nuclear Operations

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Attachment

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DEC 2 619?fi

Document Control Desk -2-

LR-N96435

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The following items represent commitments that Public Service

Electric & Gas (PSE&G) made to the Nuclear Regulatory Commission

(NRC) relative to this NOV Response to Inspection Report

50-354/96-09-01.

a. To address generic implications, a review of other

practices which could be interpreted as violating the

Technical Specifications (i.e. training, long term

l illness, extended vacation, staffing, etc.) will be

l conducted and appropriate remedies established by

January 31, 1997.

f b. A self-assessment will be performed to evaluate

j effectiveness of corrective actions to assure the new *

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expectations have be achieved. This self-assessment

! will be conducted by June 30, 1997,

c. A sampling of prior LCR's will be performed to assure

proper reviews were applied. This sampling will be

completed by February 27, 1997.

d. A request for the revision of the procedure that

controls the LCR process has been initiated to ensure j

that LCR submittals and revisions that affect the .j

material nature of the LCR are reviewed and approved by

OSR. The procedure revision will be completed by

March 30, 1997.

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Document Control Desk -3-

LR-N96435

C Mr. H. J. Miller, Administrator - Region I

U. S. Nuclear Regulatory Commission

475 Allendale Road

King of Prussia, PA 19406

Mr. David Jaffe

Licensing Project Manager - Hope Creek

U. S. Nuclear Regulatory Commission

one White Flint North

Mail Stop 14E21

11555 Rockville Pike

Rockville, MD 20852

Mr. R. Summers

USNRC Senior Resident Inspector (X24)

Mr. K. Tosch, Manager IV

Bureau of Nuclear Engineering

33 Arctic Parkway

CN 415

Trenton, NJ 08625

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ATTACHMENT

REPLY TO NOTICE OF VIOLATION

OFFSITE SAFETY REVIEW STAFFING AND REVIEW ISSUES

INSPECTION REPORT NO. 50-354/96-09

HOPE CREEK GENERATING STATION

FACILITY OPERATING LICENSE NPF-57

DOCKET NO. 50-354 LR-N96435

I. INTRODUCTION

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During the NRC's Resident Inspection conducted at Hope Creek l

Generating Station between September 22, 1996 and

November 9, 1996, a violation of NRC requirements was

identified. As a result, the NRC issued a notice of

violation (VIO 354/96-09-01) in a letter dated December 5,

[ 1996 from L. Nicholson (NRC) to L. Eliason (PSE&G). This

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response addresses the violation.

In accordance with the provisions of 10CFR2.201, Public

Service Electric and Gas Company hereby submits a written

response to the notice of violation which includes: (1) the

reason for the violation; (2) the corrective steps that have

been taken and the results achieved; (3) the corrective

steps that will be taken to avoid further violations; and

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

II. REPLY TO THE NOTICE OF VIOLATION

1. Description of the Notice of Violation i

" Technical Specification 6.5.2, Nuclear Safety Review and

Audit, requires, in part, that Hope Creek will have an Offsite

Safety Review (OSR) staff consisting of at least four ,

dedicated, full time engineers; and, that the OSR staff shall :

review, in part, proposed changes to the Technical

Specifications or the Operating License.

Contrary to the above, OSR staffing and review requirements

were not met for the following two examples:

(i) from September 26, 1996 until October 9, 1996, the Hope

Creek OSR did not have a staff consisting of at least four

dedicated, full-time engineers; and,

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Attachment LR-N96435 {

} Reply to Notice of Violation '

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j (ii) License Change Request (LCR) 95-23, dated October 7, 1995

and LCR 95-23 revision, dated October 27, 1995, were not

reviewed by the OSR.

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j This is a Severity Level IV violation (supplement I) . " ,

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2A. . Response to Notice of Violation - Inadequate OSR' staffing

j levels

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j PSE&G has reviewed the circumstances described by the NRC and ;

j concurs with the facts cited in the first example.

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j i. Description of Event ;

j On September 23, 1996, one of the Offsite Safety Review (OSR) ,

l engineers was voluntarily transferred out of the Nuclear I

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Safety Review organization, thus creating a vacancy in the OSR

! staff. Both permanent and temporary replacements were being

j pursued in accordance with the normal Human Resource

! processes, the interim short term vacancy had not been

j previously interpreted to be a violation of the Technical

i Specification staffing level requirements.

I On October 8, 1996, an NRC inspector identified that there

were fewer than the four full-time engineers currently

j assigned to the Hope Creek OSR staff. The NRC inspector

! considered this interim staffing situation a violation of the

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Technical Specification requirements. Upon identification of

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the issue by the NRC inspector, OSR management filled the

staff position with a qualified engineer on October 8, 1996

{ and an action request in accordance with the corrective action j

i program was generated. As a result of the aforementioned OSR l

j staff engineer transfer, a deficient staffing condition ;

i existed for a total of ten working days. !

A prior violation identified by the NRC (Violation 50-272/96-

05) also involved Technical Specification staffing ,

requirements. Specifically, the staffing issue of that j

violation entailed the crediting of the OSR supervisor as one

of the full time dedicated members of the OSR staff. The

prior violation involved a situation that is distinguishable

from this event, and therefore the previously developed

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Attachment LR-N96435 l

Reply to Notice of Violation l

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corrective actions were not encompassing to address the issue

identified in the current violation.

ii. Reason for the Violation

The OSR staffing deficiency was the result of management work

practices and policies that were less than adequate.

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Specifically, prior convention and past practice were used in

that an active pursuit of a replacement was in progress. This

lack of a questioning attitude resulted in the violation of

the Technical Specifications.

28. Response to Notice of Violation - Review of License Change ,

j Request (LCR) package 95-23 l'

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PSE&G has reviewed the circumstances described by the NRC and

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concurs with the facts cited in the second example.

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i. Description of the Event

During an examination of license change request (LCR) reviews

performed by OSR, the NRC inspector identified that LOR 95-23

was not appropriately reviewed by OSR. Technical

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Specification S 6. 5.2 and procedures NC.NA-AP. ZZ-0035 (Q) ,

" Nuclear Licensing and Reporting" and ND.SN-AP.ZZ-0001 (Q) , !

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" Independent Safety Review Program", require, in part, that !

l the OSR review proposed changes to the Technical l

l Specifications to evaluate technical merit and verify the

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adequacy of the significant hazards analysis. Specifically, a

substantial draft of the LCR was reviewed by OSR on October 5,

i 1995; however, the subsequent submittal of October 7, 1995 and

l a revision thereto on October 27, 1995 were not formally

l reviewed by OSR.

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l ii. Reason for the Violation l

The deficient review of LCR 95-23 was the result of management

! work practices and administrative controls in place that were

l less than adequate to comply with Technical Specification

requirements. The document was reviewed by OSR on October 5,

l 1995 and its technical content was subsequently modified by a i

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letter from Engineering on October 6, 1995 (NE-95-1595) . The l

version of the LCR reviewed by SORC and submitted to the NRC

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Attachment LR-N96435

Reply to Notice of Violation

on October 7, 1995 captured the engineering changes; however,

an additional formal review was not conducted by OSR.

Likewise, a revision to the LCR submitted on October 27, 1995,

was not formally reviewed by OSR.

Prior practice was that an additional formal review was not

needed or warranted for modified submittals unless it was

determined that the significant hazards analysis was effected.

The incorporated engineering information and revised amendment

request were judged to not effect the significant hazards

analysis and therefore they were not routed back to OSR for

formal review. The practice was to communicate subsequent

changes to OSR through document routing and verbal follow-up,

which was the case for LCR 95-23. Both documents were

subsequently transmitted to the OSR organization as recorded

on the correspondence distribution routing sheets attached to I

the October 7 and 27, 1995 submitttls. l

3. Corrective Steps That Have Been Taken and Results Achieved

a. The open OSR staffing position was immediately filled

with a qualified staff member.

b. Management expectations regarding staffing vacancies l

and compliance with Technical Specification staffing I

requirements has been communicated to quality assurance

management, including OSR and NSR management, thereby

heightening management awareness,

c. LCR 95-23 as submitted on October 7 and 27, 1995, has

been formally reviewed by OSR, with no concerns j

identified,

d. The practice regarding formal OSR reviews of LCR's has

been clarified. Specifically, the need to have any

subsequent material changes that effect the proposed

marked-up Technical Specification pages or the

significant hazards review, has been contmun.cated to

the OSR and Licensing organizations, thereL 3

heightening employee awareness.

e. A review of other OSR review activities similar to the

LCR review process has been conducted to ensure that

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! Attachment LR-N96435

Reply to Notice of Violation

OSR is reviewing the materially complete document at

the time of the OSR formal review. No other process

weaknesses were identified.

4. Corrective Steps that Will Be Taken to Avoid Further

Violations

a. To address generic implications, a review of other

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practices which could be interpreted as violating the

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Technical Specifications (i.e., training, long term

i illness, extended vacation, staffing, etc.) will be

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conducted and appropriate remedies established by

January 31, 1997.

b. A self-assessment will be performed to evaluate

i effectiveness of corrective actions to assure the new

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expectations have be achieved. This self-assessment

will be conducted by June 30, 1997.

c. A sampling of prior LCR's will be performed to assure

proper reviews were applied. This sampling will be

completed by February 27, 1997.

d. A request for the revision of the procedure that

controls the LCR process has been initiated to ensure

that LCR submittals and revisions that affect the

material nature of the LCR are reviewed and approved by

OSR. The procedure revision will be completed by

March 30, 1997.

5. Date When Full Compliance Will Be Achieved

PSE&G is now in full compliance with the OSR staffing

requirements at Hope Creek and Salem. PSE&G has

formally reviewed LCR 95-23 and is therefore in

compliance with the OSR review requirements.

Additional committed reviews assure full compliance.

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ML20133E876

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