ML20133E876
| 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) | |
See also: IR 05000354/1996009
Text
. -
--
. - .
'
o
.
1
$
'a
4
,
,
I
January 8, 1997
.
I
)
Mr. L. F. Storz, Senior Vice President
Nuclear Operations
-
Public Service Electric & Gas Company
PO Box 236
l
Hancocks Bridge, NJ 08038
4
SUBJECT:
NRC INSPECTION NOS. 50-354/96-09
'
I
'
Dear Mr. Storz
1
.1
i
i
This letter refers to your Decemer 26,1996 correspondence, in response to our December
{
5,1996 letter.
4
'
'
]
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.
I
'
Your cooperation with us is appreciated.
d
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
ADOCK 05000354
G
pm
,_
-
.. . . . . . . . -.. .. . .. .... -. . - - . - -
..
.
.- .
. .. _
. . . . _
. ..
.
.
"
>
.
I
i
-
l
,
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
cc w/cy of Licensee's Letter:
i
I
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
l
R. E. Selover, Esquire
l
M. Wetterhahn, Esquire
!
P. MacFarland Goelz, Manager, Joint Generation Department,
Atlantic Electric Company
i
Consumer Advocate, Office of Consumer Advocate
W. Conklin, Public Safety Consultant, Lower Alloways Creek Township
'
R. Kankus, Joint Owner Affairs
,
State of New Jersey
State of Delaware
!
l
i
l
!
l
.-.
. _
_ _ . _ - . - - _ -
- - . _ . -
_ _ . - . - - . - . .
.
84
.
Mr. L. F. Storz
3
1
Distribution w/ copy of Licensee's Response Letter:
Region I Docket Room (with concurrences)
,
PUBLIC
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
i
l
l
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
NAME
RDePriest/Q/
LNicholson "' @
[
'
DATE
1/7f97
1/2f/97
I
0FFICIAL RECORD COPY
I
,-
, .
.
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
'
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
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)
in a letter dated December 5,
1996, from L. Nicholson (NRC) to
'
L. Eliason (PSE&G).
Should you have any questions or comments on this transmittal, do
not hesitate to contact us.
Sincerely,
.
Out2
-
L.
F.
Storz
Senior Vice President -
Nuclear Operations
Attachment
g' ema. a w,
Ittu:ychw1 Purast
GM c+cq.o.g g
.
_ .
__ . ..
. . _ _ _ _ .
__
. _.
_ . _
___
_
_
. __
. . -
. .
DEC 2 619?fi
Document Control Desk
-2-
LR-N96435
,
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
l
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.
f
!
l
i
<
,
.e
. .
obc 2 C li 6
4
,
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
l
- -
-- --. .. .
_~.- -
.-
..
.
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
!
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
'
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,
Page 1 of 5
._ _
_ _.
,
--
1 .<
. .
,
.i
i
,
Attachment
LR-N96435
{
}
Reply to Notice of Violation
'
i
i
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.
I,
j
This is a Severity Level IV violation (supplement I) . "
,
!
!
2A. . Response to Notice of Violation - Inadequate OSR' staffing
'
j
levels
i
j
PSE&G has reviewed the circumstances described by the NRC and
j
concurs with the facts cited in the first example.
i
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
,
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
Technical Specification requirements.
Upon identification of
-
j
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
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
Page 2 of 5
.
.-
.- -
- . . - . . -
.s
)
. .
I
.
i
Attachment
LR-N96435
Reply to Notice of Violation
r
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.
'
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
l
'
PSE&G has reviewed the circumstances described by the NRC and
l
concurs with the facts cited in the second example.
>
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
Specification S 6. 5.2 and procedures NC.NA-AP. ZZ-0035 (Q) ,
i
" Nuclear Licensing and Reporting" and ND.SN-AP.ZZ-0001 (Q) ,
!
" Independent Safety Review Program", require, in part, that
!
,
l
the OSR review proposed changes to the Technical
l
Specifications to evaluate technical merit and verify the
'
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.
1
l
ii.
Reason for the Violation
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
'
letter from Engineering on October 6,
1995 (NE-95-1595) .
The
version of the LCR reviewed by SORC and submitted to the NRC
!
Page 3 of 5
t
l
l
l
- _ -
,.
-
,
,
- --,. -.
..
.
-
-
..
. .
.
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
the October 7 and 27, 1995 submitttls.
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
and compliance with Technical Specification staffing
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
Page 4 of 5
.__.._____._._.______.-.__.,_.___._______..__m_
- .4
. .
I
t
.
l
!
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
practices which could be interpreted as violating the
,
!
Technical Specifications
(i.e.,
training, long term
i
illness, extended vacation, staffing, etc.) will be
l
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
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.
Page 5 of 5
l
_ _
_
_ _
_ . _ _ . _ _ _
, _ . _ _ _ .
_