ML20238E167
| ML20238E167 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/01/1987 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8709140183 | |
| Download: ML20238E167 (4) | |
Text
e GPU Nuclear Corporation 7 Nuclear
- = : r 388 Forked River, New Jersey 08731-0388 609 971-4000 Writers Direct Dial Number:
September 1,1987 William V. Johnston, Acting Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Dear Mr. Johnston:
Subject:
Oyster Creek Nuclear Generating Station i
Docket No. 50-219 1'
Response to Letter, Johnston to Fiedler, July 7,1987
Reference:
IE Inspection Report 50-219/83-26 GPUN Response to IR 83-26 dated March 28, 1984 IE Inspection Report 50-219/84-28 GPUN Response to IR 84-28 dated March 15, 1985 IE Inspection Report 50-219/85-01 GPUN Response to IR 85-01 dated April 18, 1985 IE Inspection Report 50-219/87-13 l
Your letter of July 7,1987 detailed two commitments made by GPUN to the USNRC during and after IE Inspection 87-17.
You stated that if GPUN's planned actions were different from those which the NRC docketed in your letter, GPUN was to respond promptly.
This letter is being written to address those commi tments.
Several concerns need to be addressed.
The order of their presentation does not imply an order of importance.
1.
The following action was taken to demonstrate to the NRC Inspector who performed IE Inspection 87-17 that GPUN is responsive to NRC concerns, even at those times when the concerns are not based on i
regulatory requirements. All Technical Specification Amendments issued since January 1985 were reviewed and 0yst. r Creek Licensing files were searched to determine if the Licensing file in and of itself would provide documentation that the requisite implementing procedures had been issued.
In those instances where the Licensing file alone did not provide the documentation, a Licensing Action Item i
was written to retrieve the information.
This does not imply that any procedures had not been written as required, nor does it imply that a non-Quality Assurance filing system needs to achieve the auditability described in 10CFR50 Appendix B Criterion 17.
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1 GPU Nuclear Corporation is a subsidiary of the General Public Utihties Corporation l
2 2.
A Licensing policy has been disseminated which will require the issuance of two Licensing Action Items for each Tech Spec Change issued: one when the request is made, and a second when the amendment is received.
However, this is an internal GPUN administrative control.
It was not intended as a commitment, but rather as a technique to be utilized to assure continuity in Licensing file documentation.
GPUN does not consider this policy a commitment, and as such may revise the technique utilized to track procedure changes at any time without prior NRC approval.
GPUN agrees that procedure revisions resulting from Technical Specification amendments are required, but does not believe that the administrative process need produce an auditable program.
3.
As identified and discussed in the seven references listed, there appears to be a misunderstanding between GPUN and the NRC on the Licensing Action Item system.
As stated by GPUN on several occasions, the Licensing Action Item system is a tracking system and not a corrective action system.
It provides a management tool on a routine basis, to inTorm the various GPUN managers and directors of open commitments.
It does not assign action, nor assure completeness of actions taken.
These activities are under the responsibility of the assigned organization and are open to audit by the Quality -
Assurance Department.
All auditable records are maintained in full accordance with all regulatory requirements by the respective departments.
There is no regulatory requirement to establish, maintain, or verify completeness of a solely administrative system to accomplish all record retention goals.
Although improvements in effectiveness are constantly being evaluated, GPUN has no plans to significantly alter the Licensing Action Item system.
4.
Your letter restated information provided by a Licensing Engineer to a Region-based inspector as a GPUN commitment.
We would like to correct this point.
Licensing engineers routinely provide information to the NRC, but it is Company policy that formal commitments can only be supplied by a GPUN Officer.
This will normally be provided as a written statement placed on the docket, but may be made verbally during an inspection exit or other meeting with your staff.
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i1 If any further information is required please contact Mr. John Rogers of my l
staff at (609)971-4893.
arn Very truly yours, l
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f5 v S. UmQ LT R. L. Long Ei)(
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Vice President & Director j
Planning & Nuclear Safety Ej l
l RLL/JR/dmd (0918A) 3 cc: Mr. William T. Russell, Administrator l
Region I U.S. Nuclear Regulatory Commission 631 Park Avenue i
King of Prussia, PA 19406
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l Mr. Alexander W. Dromerick, Project Manager
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U.S. Nuclear Regulatory Commission Division of Reactor Projects I/II 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 Mail Stop No. 316 NRC Resident Inspector l
Oyster Creek Nuclear Generating Station Forked River, NJ 08731
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