ML20138G628
| ML20138G628 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/26/1996 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N96435, NUDOCS 9701020125 | |
| Download: ML20138G628 (9) | |
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l Public Service Electnc and Gas t
Company Louis F. Storz Public Service Electric and Gas Company P O. Box 236. Hancocks Bridge, NJ 08038 609-339-5700 sono ve.e..
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DEC 2 61998 LR-N96435 8
United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 t
Gentlemen:
REPLY TO A NOTiCF OF VIOLATION OFFSITE SAFETY REVIEW STAFFING AND REVIEW ISSUES f
INSPECTION REPORT NO. 50-354/96-09-01 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 I
DOCKET NO. 50-354 i
Pursuant to the provisions of 10CFR2.201, this letter submits the 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).
I Should you have any questions or comments on this transmittal, do not hesitate to contact us.
Sincerely, j
W
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L.
F. Storz Senior Vice President -
Nuclear Operations 310000 1
9701020125 961226 dl PDR ADOCK 05000354 G
PDR y
Attachment
@ Pnntedon Recycled Paper
ps-1 DEC 2 61996 i
Document Control Desk LR-N96435 The followina items represent commitments that Public Service Electric & Gs (PSE&G) made to the Nuclear Regulatory Commission (NRC) relative to this NOV Response to Inspection Report
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50-354/96-09-01.
j a.
To address generic implications, a review of other practices which could be interpreted as violating the Technical Specifications (i.e. training, long term illness, extended vacation, staffing, etc.) will be conducted and appropriate remedies established by January 31, 1997.
b.
A self-assessment will be performed tc evaluate effectiveness of corrective actions to assure the new l
expectations have be achieved.
This self-assessment l
will be conducted by June 30, 1997.
i c.
A sampling of prior LCR's will be performed to assure i
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 initiat<sd 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 t
March 30, 1997.
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DEC 2 6 MS Document Control Desk LR-N96435 C
Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road
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King of Prussia, PA 19406 i
Mr. David Jaffe Licensing Project Manager - Hope Creek j
U.
S. Nuclear Regulatory Commission
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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 i
Trenton, NJ 08625 I
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I DEC 2 61996 Document Control Desk LR-N96435 JJK/
i BC Senior Vice President - Nuclear Engineering (N19)
General Manager - Hope Creek Operations (H07)
Director - QA/NSR (X01) i Operations Manager - Hope Creek'(H01)
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Manager - Nuclear Safety Review (N38)
Manager - Joint Owners / External Affairs Interface (N28)
Onsite Safety Review Engineer - Hope Creek (H11)
Manager - Licensing and Regulation (X09)
Principal Engineer Licensing - Salem (X09)
Principal Engineer Licensing - Hope Creek (X09)
Station Licensing Engineer - Hope Creek (XO9)
R.E. Selover, Esq. (Newark, 5G)
Perry Robinson, Esq.
Records Management (N21) r Microfilm Copy File Nos.
1.2.1, 3.1 (:HC IR 50-354/96-09) l 1
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ATTACHMENT REPLY TO NOTICE OF VIOLATION OFFSITE SAFETY REVIEW STAFFING AND REVIEW ISSUES INSPECTION REPORT NO. 50-354/96-09
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HOPE CREEK GENERATING STATION l
FACILITY OPERATING LICENSE NPF-57 l
DOCKET NO. 50-354 LR-N96435 l
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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 De: ember 5, l
1996 from L. Nicholson (NRC) to L. Eliason (PSE&G).
This response addresses the violation.
In accordance with the provisions of 10CFR2.201, Public l
Service-Electric and Gas Company hereby submits a written l
response to the notice of violation which includes:
(1) the
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reason for the violation; (2) the corrective steps that have i
been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and j
(4) the date when full compliance will be achieved.
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II.
REPLY TO THE NOTICE OF VIOLATION
- 1. Description of the Notice of Violation i
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" Technical Specification 6.5.2, Nuclear Safety Review and j
Audit, requires, in, art, that Hope Creek will have an Offsite l
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 i
Specifications or the operating License.
l 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, l
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Reply to Notice of Violation i
i (ii) License Change Request (LCR) 95-23, dated October 7, 1995 l
and LCR'95-23 revision, dated October 27, 1995, were not l
reviewed by the OSR.
l This is a Severity Level IV violation (Supplement I). "
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2A.
Response to Notice of Violation - Inadequate OSR staffing levels 1
PSE&G has reviewed the circumstances described by the NRC and concurs with the facts cited in the first example.
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Description of Event i
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 J
staff.
Both perm 6nent and temporary replacements were being pursued in accordence with the normal Human Resource processes, the interim short term vacancy had not been i
previously interpreted to be a violation of the Technical l
Specification staffing level requirements.
1 On October 8, 1996, an NRC inspector identified that there were fewer than the four full-time engineers currently 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 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 program was generated.
As a result of the aforementioned OSR staff engineer transfer, a deficient staffing condition 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 l
violation entailed the crediting of the OSR supervisor as one of the full time dedicated members of the OSR staff.
The i
prior violation involved a situation that is distinguishable from this event, and therefore the previously developed J
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Attachment LR-N96435 Reply to Notice of Violation i
corrective actions were not encompassing to address the issue identified in the current violation.
11.
Reason for the Violation l
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 vio3ation of the Technical Specifications.
l 2B. Response to Notice of Violation - Review of License Change l
Request (LCR) package 95-23 PSEAG has reviewed the circumstances described by the NRC and concurs with the facts cited in the second example.
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- i. Description of the Event I
t During an examination of license change. request (LCR) reviews performed by OSR, the NRC inspector identified that LCR 95-23 i
was not appropriately reviewec' by OSR.
Technical Specification S 6. 5.2 and procedures NC.NA-AP.ZZ-0035 (Q),
" Nuclear Licensing and Reporting" and ND.SN-AP.ZZ-0001 (Q),
" Independent Safety Review Program", require, in part, that the OSR review proposed changes to the Technical 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, 1995; however, the subsequent submittal of October 7, 1995 and a revision thereto on October 27, 1995 were not formally reviewed by OSR.
11.
Reason for the Violacion The deficient review of LCR 95-23 was the result of management work practices and administrative controls in place that were less than adequate to comply with Technical Specification l
requirements.
The document was reviewed by OSR on October 5, 1995 and its technical content was subsequently modified by a letter from Engineering on October 6, 1995 (NE-95-1595).
The I
version of the LCR reviewed by SORC and submitted to the NRC l
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Attachment LR-N96435 Reply to Notice of Violation on Octcber 7,_1995 capqured the engineering changes; however, an adr'1tional formal review was not conducted by OSR.
Like01se, a revision to the LCR submitted on' October 27, 1995, was not formally revir.wed 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 LCP 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 submittals.
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 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 communicated to the OSR and Licensing organizations, thereby 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 l
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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 WilliBe Taken to Avoid Further Violations a.
To addrese generic implications, a review of other
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practices which could be interpreted as violating the Technical Specifications (i.e.,
training, long term illness, extended vacation, staffing, etc.) will be conducted and appropriate remedies established by January 31, 1997.
b.
A self-assessment will be performed to evaluate effectiveness of corrective actions to assure the new expectations have be achieved.
This-self-assessment will Le 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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