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See also: [[followed by::IR 05000272/1996005]]


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{{#Wiki_filter:.* \/ .. Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700  
{{#Wiki_filter:.* \/ .. Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President  
Senior Vice President  
-Nuclear Operations MAY 2 2 1996
-Nuclear Operations  
* LR-N96132 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
MAY 2 2 1996 * LR-N96132  
RESPONSE TO NRC NOTICE OF VIOLATION INTEGRATED INSPECTION REPORT 50-272/96-05, 50-311/96-05 SALEM GENERATING STATION UNIT NOS. l AND 2 DOCKET NOS. 50-272 AND 50-311 HOPE CREEK GENERATING STATION UNIT NO. 1 DOCKET NO. 50-354 Inspection Report Nos. 50-272/96-05 and 50-311/96-05 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Electric & Gas Company (PSE&G) on April 22, 1996. Within the scope of this report, a violation of NRC requirements was cited. Pursuant to the provisions of 10CFR2.201, PSE&G submits its response to the aforementioned violation in Attachment I to this letter. This response is applicable to both Salem and Hope Creek Generating Stations.
United States Nuclear Regulatory  
Should there be any questions this submittal, please do not hesitate to contact us. Sincerely, Attachment (1) Q Printedon
Commission  
* Recycled Paper 9607080388 960702 PDR ADOCK 05000272 G PDR   
Document Control Desk Washington, DC 20555 Gentlemen:  
\/ ..
RESPONSE TO NRC NOTICE OF VIOLATION  
* Document Control Desk LR-N96132 c J Mr. T. T. Martin, Administrator  
INTEGRATED  
-Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 MAY 2 2 1996 Mr. L. N.
INSPECTION  
Licensing Project Manager -Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike M.ail Stop 14E21 Rockville, MD 20852 Mr. D. Jaffe., Licensing Project Manager -Hope Creek U. s. Nuclear Regulatory Commission One White Flint North. 11555 Rockville Pike Mail stop 14E21 Rockville, MD 20852 Mr. c. Marschall  
REPORT 50-272/96-05, 50-311/96-05  
-Salem (X24) USNRC Senior Resident Inspector Mr. R. Summers (X24) USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 V. Attachment I LR-N96132 APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating station Units 1 and 2 Hope Creek Generating Station Docket Nos. 50-272 50-311 50-354 License Nos. DPR-70 DPR-75 DPR-57 During an NRC inspection conducted on February 2S, 1996 -April 6, 1996, a violation of NRC requirements was identified.
SALEM GENERATING  
In accordance with the "General statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30, 1995), the violation is listed below: Unit 1 Technical Specification
STATION UNIT NOS. l AND 2 DOCKET NOS. 50-272 AND 50-311 HOPE CREEK GENERATING  
{TS) 6.5.2.2 and Unit 2 TS 6.5.2.2 require, in part, that each Salem unit will have an Offsite Safety Review staff {OSR) and an Onsite Safety Review Group (SRG), consisting of at least four dedicated, full-time engineers.
STATION UNIT NO. 1 DOCKET NO. 50-354 Inspection  
TS 6.5.2.2, for each unit, also requires that the SRG and OSR engineers meet or exceed the qualifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.
Report Nos. 50-272/96-05  
Contrary to the above, during the inspection period the resident inspectors determined that each Salem unit did not have an OSR and SRG consisting of at least four dedicated, full-time engineers; and that the SRG and the OSR engineers did not meet or exceed the quelifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.
and 50-311/96-05  
This is a Severity Level IV violation.
for Salem Nuclear Generating  
PSE&G concurs with the violation, in that not all Specification 6.5.2.2 requirements were met.   
Station Unit Nos. 1 and 2 was transmitted  
* .. . *
to Public  
* Attachment LR-N96132 (1) The reason for the violation.
Electric & Gas Company (PSE&G) on April 22, 1996. Within the scope of this report, a violation  
The root cause of this violation is attributed to failure of management to: 1. Maintain the appropriate controls over organizational structure changes to validate compliance with the licensing bases, and 2. Ensure that all applicable requirements of the ANS Standard were reviewed to verify alignment with the appropriate Nuclear Administrative Procedure (i.e., NC.NA-AP.ZZ-0014(Q), (NAP-14) "Training, Qualification and Certification").
of NRC requirements  
The 1981 Salem TS for both Units 1 and 2 contained an organizational chart identified as: nFIGURE 6.2-1 CORPORATE HEADQUARTERS AND ORGANIZATION FOR MANAGEMENT AND TECHNICAL SUPPORT." This chart described the organizational structure -for both Salem Units 1 and 2, and showed a single "Safety Review Group" reporting to the General Manager -Nuclear Support. Since 1981 a number of License Change Requests (LCR) were submitted to clarify and modify the organizational chart. In 1984, PSE&G submitted LCR 84-24 which also affected TS Section 6. This LCR modified the Nuclear Safety Review organization by creating an Offsite Safety Review (OSR) group and an Onsite Safety Review group. The OSR group was segregated into a Boiling Water Reactor (BWR) group and a Pressurized Water_ Reactor (PWR) group. The NRC's Safety Evaluation Report (SER) for LCR 84-24 (Amendments 62 and 33, which was one report addressing both Salem Units 1 and 2, respectively) acknowledged the change in Safety Review department nomenclature, and stated, in part: 11 **** The SRG, which meets the staff's requirements for an Independent Safety Engineering Group, remains intact except that it now reports to the General Manager-Nuclear Safety Review ........ We find this change acceptable  
was cited. Pursuant to the provisions  
... "* Regarding the OSR group, these organizational changes resulted in inappropriately crediting the supervisor of the Off-Site Safety Review_Engineering Group as a "dedicated engineer" toward the safety review function, and also failed to maintain the segregation between the Salem and Hope Creek groups. This resulted in a lack of clear delineation of responsibilities, wnich led-to dedicate four full-time engineers to the Salem OSR group, and four full-time engineers to the Hope Creek OSR group . I I I   
of 10CFR2.201, PSE&G submits its response to the aforementioned  
'.J .* *
violation  
* Attachment LR-N96132 Certain individuals assigned to.the OSR and SRG positions do not hold a Bachelor's Degree in Engineering or related sciences.
in Attachment  
Subsection 4.1 of the ANS standard, though not explicitly referenced in the Technical Specifications (TS) states that experience may be evaluated and used in lieu of a degree. PSE&G's position was that Subsection 4.1 may be used to establish alternative qualifications and compliance with other subsections of Section 4 of the ANS Standard.
I to this letter. This response is applicable  
This interpretation is supported by the intent of the ANS Standard, and by the generally accepted principles for inclusion of, and adherence to, "referenced" documents.
to both Salem and Hope Creek Generating  
Subsection 4.1 also states that, when experience is substituted for education, the other compensating factors must be documented and approved by the Plant Manager. Although the appropriate documentation was approved, the approval was not obtained as prescribed in the ANS Standard.
Stations.  
(2) The corrective steps that have been taken. 1. On April 19, 1996, the OSR organization was segregated and assigned into two separate groups of four dedicated, time engineers.
Should there be any questions  
One group is dedicated to Hope Creek; the other is dedicated to Salem Station. A single supervisor provides oversight and direction to both groups and reports to the Manager -Nuclear Safety Review. 2. A qualification matrix has been developed for OSR engineers identifying the specialty areas in which they possess the appropriate years of professional levei experience.
this submittal, please do not hesitate to contact us. Sincerely, Attachment  
: 3. The SRG and OSR staff engineer's education equivalency forms have been approved by the Salem and Hope Creek Plant Managers.
(1) Q Printedon  
: 4. Prior to the issuance of this violation, PSE&G submitted two LCRs, on January 11, 1996, to relocate the review and audit functions of Section 6.5 of the Salem and Hope Creek Generating Stations Technical Specifications to the PSE&G QA program. (3) The corrective steps that will be taken to avoid further violations.
* Recycled Paper 9607080388  
: 1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted.
960702 PDR ADOCK 05000272 G PDR   
The results of this review will be used to determine additional corrective actions. The review will be completed by June 28, 1996 .   
\/ .. * Document Control Desk LR-N96132 -2 -c J Mr. T. T. Martin, Administrator  
... *'* .
-Region I U. s. Nuclear Regulatory  
* Attachment LR-N96132 -4 2. PSE&G will evaluate NAP-14 to assure that qualification and* documentation approval requirements, as specified in the ANS Standard, are clearly reflected within the procedure.
Commission  
This action will be completed by July 1, 1996. 3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996. (4) The date when full compliance will be achieved.
475 Allendale  
PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled; This vacant position is expected to be filled by June 30, 1996. In addition, PSE&G is also requesting*to change the Quality Assurance program via 10CFR50.54a to allow realignment of the Quality Assurance (QA), NSR, and Nuclear Review Board (NRB) functions.
Road King of Prussia, PA 19406 MAY 2 2 1996 Mr. L. N.  
It is expected that this request will be submitted by May 31, 1996. This request will also specify that QA. (only those assigned to perform the independent review function) , and NRB personnel will meet or exceed the qualification requirements of applicable sections of ANSI/ANS 3.1 -1981, "American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants." By this action the appropriateness of applying Section 4.1 to other subsections of. Section 4 of *the ANS Standard will be clearly established.   
Licensing  
.... ,. -The following lists all commitments made by PSE&G, in letter LR-N96132, with their respective due dates. 1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted.
Project Manager -Salem U. s. Nuclear Regulatory  
The results of this review will be used to determine additional corrective actions. The review will be completed by June 28, 1996. 2. PSE&G will evaluate NAP-14 to assure that qualification and documentation approval requirements, as specified in the ANS standard, are clearly reflected within the procedure.
Commission  
This action will be completed by July l, 1996. 3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996. 4. PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was
One White Flint North 11555 Rockville  
* segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled. This vacant position is expected to be filled by June 30, 1996.}}
Pike M.ail Stop 14E21 Rockville, MD 20852 Mr. D. Jaffe., Licensing  
Project Manager -Hope Creek U. s. Nuclear Regulatory  
Commission  
One White Flint North. 11555 Rockville  
Pike Mail stop 14E21 Rockville, MD 20852 Mr. c. Marschall  
-Salem (X24) USNRC Senior Resident Inspector  
Mr. R. Summers (X24) USNRC Senior Resident Inspector  
Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering  
33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
V. Attachment  
I LR-N96132 -1 -APPENDIX A NOTICE OF VIOLATION  
Public Service Electric and Gas Company Salem Nuclear Generating  
station Units 1 and 2 Hope Creek Generating  
Station Docket Nos. 50-272 50-311 50-354 License Nos. DPR-70 DPR-75 DPR-57 During an NRC inspection  
conducted  
on February 2S, 1996 -April 6, 1996, a violation  
of NRC requirements  
was identified.  
In accordance  
with the "General statement  
of Policy and Procedure  
for NRC Enforcement  
Actions," (60 FR 34381; June 30, 1995), the violation  
is listed below: Unit 1 Technical  
Specification  
{TS) 6.5.2.2 and Unit 2 TS 6.5.2.2 require, in part, that each Salem unit will have an Offsite Safety Review staff {OSR) and an Onsite Safety Review Group (SRG), consisting  
of at least four dedicated, full-time  
engineers.  
TS 6.5.2.2, for each unit, also requires that the SRG and OSR engineers  
meet or exceed the qualifications  
described  
in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.  
Contrary to the above, during the inspection  
period the resident inspectors  
determined  
that each Salem unit did not have an OSR and SRG consisting  
of at least four dedicated, full-time  
engineers;  
and that the SRG and the OSR engineers  
did not meet or exceed the quelifications  
described  
in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.  
This is a Severity Level IV violation.  
PSE&G concurs with the violation, in that not all  
Specification  
6.5.2.2 requirements  
were met.   
* .. . * * Attachment  
LR-N96132 -2 -(1) The reason for the violation.  
The root cause of this violation  
is attributed  
to failure of management  
to: 1. Maintain the appropriate  
controls over organizational  
structure  
changes to validate compliance  
with the licensing  
bases, and 2. Ensure that all applicable  
requirements  
of the ANS Standard were reviewed to verify alignment  
with the appropriate  
Nuclear Administrative  
Procedure (i.e., NC.NA-AP.ZZ-0014(Q), (NAP-14) "Training, Qualification  
and Certification").  
The 1981 Salem TS for both Units 1 and 2 contained  
an organizational  
chart identified  
as: nFIGURE 6.2-1 CORPORATE  
HEADQUARTERS  
AND  
ORGANIZATION  
FOR MANAGEMENT  
AND TECHNICAL  
SUPPORT." This chart described  
the organizational  
structure -for both Salem Units 1 and 2, and showed a single "Safety Review Group" reporting  
to the General Manager -Nuclear Support. Since 1981 a number of License Change Requests (LCR) were submitted  
to clarify and modify the organizational  
chart. In 1984, PSE&G submitted  
LCR 84-24 which also affected TS Section 6. This LCR modified the Nuclear Safety Review organization  
by creating an Offsite Safety Review (OSR) group and an Onsite Safety Review group. The OSR group was segregated  
into a Boiling Water Reactor (BWR) group and a Pressurized  
Water_ Reactor (PWR) group. The NRC's Safety Evaluation  
Report (SER) for LCR 84-24 (Amendments  
62 and 33, which was one report addressing  
both Salem Units 1 and 2, respectively)  
acknowledged  
the change in Safety Review department  
nomenclature, and stated, in part: 11 **** The SRG, which meets the staff's requirements  
for an Independent  
Safety Engineering  
Group, remains intact except that it now reports to the General Manager-Nuclear  
Safety Review ........ We find this change acceptable  
... "* Regarding  
the OSR group, these organizational  
changes resulted in inappropriately  
crediting  
the supervisor  
of the Off-Site Safety Review_Engineering  
Group as a "dedicated  
engineer" toward the safety review function, and also failed to maintain the segregation  
between the Salem and Hope Creek groups. This resulted in a lack of clear delineation  
of responsibilities, wnich led-
to dedicate four full-time  
engineers  
to the Salem OSR group, and four full-time  
engineers  
to the Hope Creek OSR group . I I I   
'.J .* * * Attachment  
LR-N96132 -3 -Certain individuals  
assigned to.the OSR and SRG positions  
do not hold a Bachelor's  
Degree in Engineering  
or related sciences.  
Subsection  
4.1 of the ANS standard, though not explicitly  
referenced  
in the Technical  
Specifications (TS) states that experience  
may be evaluated  
and used in lieu of a degree. PSE&G's position was that Subsection  
4.1 may be used to establish  
alternative  
qualifications  
and compliance  
with other subsections  
of Section 4 of the ANS Standard.  
This interpretation  
is supported  
by the intent of the ANS Standard, and by the generally  
accepted principles  
for inclusion  
of, and adherence  
to, "referenced" documents.  
Subsection  
4.1 also states that, when experience  
is substituted  
for education, the other compensating  
factors must be documented  
and approved by the Plant Manager. Although the appropriate  
documentation  
was approved, the approval was not obtained as prescribed  
in the ANS Standard.  
(2) The corrective  
steps that have been taken. 1. On April 19, 1996, the OSR organization  
was segregated  
and assigned into two separate groups of four dedicated, time engineers.  
One group is dedicated  
to Hope Creek; the other is dedicated  
to Salem Station. A single supervisor  
provides oversight  
and direction  
to both groups and reports to the Manager -Nuclear Safety Review. 2. A qualification  
matrix has been developed  
for OSR engineers  
identifying  
the specialty  
areas in which they possess the appropriate  
years of professional  
levei experience.  
3. The SRG and OSR staff engineer's  
education  
equivalency  
forms have been approved by the Salem and Hope Creek Plant Managers.  
4. Prior to the issuance of this violation, PSE&G submitted  
two LCRs, on January 11, 1996, to relocate the review and audit functions  
of Section 6.5 of the Salem and Hope Creek Generating  
Stations Technical  
Specifications  
to the PSE&G QA program. (3) The corrective  
steps that will be taken to avoid further violations.  
1. A sampling review of previously  
reviewed material for which the qualifications  
of the original reviewer have been called into question will be conducted.  
The results of this review will be used to determine  
additional  
corrective  
actions. The review will be completed  
by June 28, 1996 .   
... *'* . * Attachment  
LR-N96132 -4 2. PSE&G will evaluate NAP-14 to assure that qualification  
and* documentation  
approval requirements, as specified  
in the ANS Standard, are clearly reflected  
within the procedure.  
This action will be completed  
by July 1, 1996. 3. The lessons learned from this event will be communicated  
to the appropriate  
Nuclear Business Unit personnel  
to emphasize  
the need to assure that organizational  
structural  
changes are made consistent  
with the facility licensing  
bases. This will be completed  
by June 15, 1996. (4) The date when full compliance  
will be achieved.  
PSE&G achieved partial compliance  
with the Salem Technical  
Specifications  
on April 19, 1996, when the OSR group was segregated  
and four dedicated, full-time  
engineers  
were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time  
engineers  
assigned to it with the fourth position to be filled; This vacant position is expected to be filled by June 30, 1996. In addition, PSE&G is also requesting*to  
change the Quality Assurance  
program via 10CFR50.54a  
to allow realignment  
of the Quality Assurance (QA), NSR, and Nuclear Review Board (NRB) functions.  
It is expected that this request will be submitted  
by May 31, 1996. This request will also specify that QA. (only those assigned to perform the independent  
review function) , and NRB personnel  
will meet or exceed the qualification  
requirements  
of applicable  
sections of ANSI/ANS 3.1 -1981, "American  
National Standard for Selection, Qualification  
and Training of Personnel  
for Nuclear Power Plants." By this action the appropriateness  
of applying Section 4.1 to other subsections  
of. Section 4 of *the ANS Standard will be clearly established.   
.... ,. -The following  
lists all commitments  
made by PSE&G, in letter LR-N96132, with their respective  
due dates. 1. A sampling review of previously  
reviewed material for which the qualifications  
of the original reviewer have been called into question will be conducted.  
The results of this review will be used to determine  
additional  
corrective  
actions. The review will be completed  
by June 28, 1996. 2. PSE&G will evaluate NAP-14 to assure that qualification  
and documentation  
approval requirements, as specified  
in the ANS standard, are clearly reflected  
within the procedure.  
This action will be completed  
by July l, 1996. 3. The lessons learned from this event will be communicated  
to the appropriate  
Nuclear Business Unit personnel  
to emphasize  
the need to assure that organizational  
structural  
changes are made consistent  
with the facility licensing  
bases. This will be completed  
by June 15, 1996. 4. PSE&G achieved partial compliance  
with the Salem Technical  
Specifications  
on April 19, 1996, when the OSR group was * segregated  
and four dedicated, full-time  
engineers  
were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time  
engineers  
assigned to it with the fourth position to be filled. This vacant position is expected to be filled by June 30, 1996.
}}

Revision as of 20:08, 31 July 2019

Responds to NRC 960422 Ltr Re Violations Noted in Insp Repts 50-272/96-05,50-311/96-05 & 50-354/96-05 on 960225-0406. Corrective actions:960419 Osr Segregated & Assigned Into Two Groups & Qualification Matrix Developed for Osr Engineers
ML18102A236
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 05/22/1996
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A235 List:
References
2.201, LR-N96132, NUDOCS 9607080388
Download: ML18102A236 (7)
v • d • e


Text

.* \/ .. Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President

-Nuclear Operations MAY 2 2 1996

  • LR-N96132 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION INTEGRATED INSPECTION REPORT 50-272/96-05, 50-311/96-05 SALEM GENERATING STATION UNIT NOS. l AND 2 DOCKET NOS. 50-272 AND 50-311 HOPE CREEK GENERATING STATION UNIT NO. 1 DOCKET NO. 50-354 Inspection Report Nos. 50-272/96-05 and 50-311/96-05 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Electric & Gas Company (PSE&G) on April 22, 1996. Within the scope of this report, a violation of NRC requirements was cited. Pursuant to the provisions of 10CFR2.201, PSE&G submits its response to the aforementioned violation in Attachment I to this letter. This response is applicable to both Salem and Hope Creek Generating Stations.

Should there be any questions this submittal, please do not hesitate to contact us. Sincerely, Attachment (1) Q Printedon

  • Recycled Paper 9607080388 960702 PDR ADOCK 05000272 G PDR

\/ ..

  • Document Control Desk LR-N96132 c J Mr. T. T. Martin, Administrator

-Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 MAY 2 2 1996 Mr. L. N.

Licensing Project Manager -Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike M.ail Stop 14E21 Rockville, MD 20852 Mr. D. Jaffe., Licensing Project Manager -Hope Creek U. s. Nuclear Regulatory Commission One White Flint North. 11555 Rockville Pike Mail stop 14E21 Rockville, MD 20852 Mr. c. Marschall

-Salem (X24) USNRC Senior Resident Inspector Mr. R. Summers (X24) USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 V. Attachment I LR-N96132 APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating station Units 1 and 2 Hope Creek Generating Station Docket Nos. 50-272 50-311 50-354 License Nos. DPR-70 DPR-75 DPR-57 During an NRC inspection conducted on February 2S, 1996 -April 6, 1996, a violation of NRC requirements was identified.

In accordance with the "General statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30, 1995), the violation is listed below: Unit 1 Technical Specification

{TS) 6.5.2.2 and Unit 2 TS 6.5.2.2 require, in part, that each Salem unit will have an Offsite Safety Review staff {OSR) and an Onsite Safety Review Group (SRG), consisting of at least four dedicated, full-time engineers.

TS 6.5.2.2, for each unit, also requires that the SRG and OSR engineers meet or exceed the qualifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.

Contrary to the above, during the inspection period the resident inspectors determined that each Salem unit did not have an OSR and SRG consisting of at least four dedicated, full-time engineers; and that the SRG and the OSR engineers did not meet or exceed the quelifications described in Section 4.4 and 4.7, respectively, of ANS 3.1-1981.

This is a Severity Level IV violation.

PSE&G concurs with the violation, in that not all Specification 6.5.2.2 requirements were met.

  • .. . *
  • Attachment LR-N96132 (1) The reason for the violation.

The root cause of this violation is attributed to failure of management to: 1. Maintain the appropriate controls over organizational structure changes to validate compliance with the licensing bases, and 2. Ensure that all applicable requirements of the ANS Standard were reviewed to verify alignment with the appropriate Nuclear Administrative Procedure (i.e., NC.NA-AP.ZZ-0014(Q), (NAP-14) "Training, Qualification and Certification").

The 1981 Salem TS for both Units 1 and 2 contained an organizational chart identified as: nFIGURE 6.2-1 CORPORATE HEADQUARTERS AND ORGANIZATION FOR MANAGEMENT AND TECHNICAL SUPPORT." This chart described the organizational structure -for both Salem Units 1 and 2, and showed a single "Safety Review Group" reporting to the General Manager -Nuclear Support. Since 1981 a number of License Change Requests (LCR) were submitted to clarify and modify the organizational chart. In 1984, PSE&G submitted LCR 84-24 which also affected TS Section 6. This LCR modified the Nuclear Safety Review organization by creating an Offsite Safety Review (OSR) group and an Onsite Safety Review group. The OSR group was segregated into a Boiling Water Reactor (BWR) group and a Pressurized Water_ Reactor (PWR) group. The NRC's Safety Evaluation Report (SER) for LCR 84-24 (Amendments 62 and 33, which was one report addressing both Salem Units 1 and 2, respectively) acknowledged the change in Safety Review department nomenclature, and stated, in part: 11 **** The SRG, which meets the staff's requirements for an Independent Safety Engineering Group, remains intact except that it now reports to the General Manager-Nuclear Safety Review ........ We find this change acceptable

... "* Regarding the OSR group, these organizational changes resulted in inappropriately crediting the supervisor of the Off-Site Safety Review_Engineering Group as a "dedicated engineer" toward the safety review function, and also failed to maintain the segregation between the Salem and Hope Creek groups. This resulted in a lack of clear delineation of responsibilities, wnich led-to dedicate four full-time engineers to the Salem OSR group, and four full-time engineers to the Hope Creek OSR group . I I I

'.J .* *

  • Attachment LR-N96132 Certain individuals assigned to.the OSR and SRG positions do not hold a Bachelor's Degree in Engineering or related sciences.

Subsection 4.1 of the ANS standard, though not explicitly referenced in the Technical Specifications (TS) states that experience may be evaluated and used in lieu of a degree. PSE&G's position was that Subsection 4.1 may be used to establish alternative qualifications and compliance with other subsections of Section 4 of the ANS Standard.

This interpretation is supported by the intent of the ANS Standard, and by the generally accepted principles for inclusion of, and adherence to, "referenced" documents.

Subsection 4.1 also states that, when experience is substituted for education, the other compensating factors must be documented and approved by the Plant Manager. Although the appropriate documentation was approved, the approval was not obtained as prescribed in the ANS Standard.

(2) The corrective steps that have been taken. 1. On April 19, 1996, the OSR organization was segregated and assigned into two separate groups of four dedicated, time engineers.

One group is dedicated to Hope Creek; the other is dedicated to Salem Station. A single supervisor provides oversight and direction to both groups and reports to the Manager -Nuclear Safety Review. 2. A qualification matrix has been developed for OSR engineers identifying the specialty areas in which they possess the appropriate years of professional levei experience.

3. The SRG and OSR staff engineer's education equivalency forms have been approved by the Salem and Hope Creek Plant Managers.
4. Prior to the issuance of this violation, PSE&G submitted two LCRs, on January 11, 1996, to relocate the review and audit functions of Section 6.5 of the Salem and Hope Creek Generating Stations Technical Specifications to the PSE&G QA program. (3) The corrective steps that will be taken to avoid further violations.
1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted.

The results of this review will be used to determine additional corrective actions. The review will be completed by June 28, 1996 .

... *'* .

  • Attachment LR-N96132 -4 2. PSE&G will evaluate NAP-14 to assure that qualification and* documentation approval requirements, as specified in the ANS Standard, are clearly reflected within the procedure.

This action will be completed by July 1, 1996. 3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996. (4) The date when full compliance will be achieved.

PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled; This vacant position is expected to be filled by June 30, 1996. In addition, PSE&G is also requesting*to change the Quality Assurance program via 10CFR50.54a to allow realignment of the Quality Assurance (QA), NSR, and Nuclear Review Board (NRB) functions.

It is expected that this request will be submitted by May 31, 1996. This request will also specify that QA. (only those assigned to perform the independent review function) , and NRB personnel will meet or exceed the qualification requirements of applicable sections of ANSI/ANS 3.1 -1981, "American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants." By this action the appropriateness of applying Section 4.1 to other subsections of. Section 4 of *the ANS Standard will be clearly established.

.... ,. -The following lists all commitments made by PSE&G, in letter LR-N96132, with their respective due dates. 1. A sampling review of previously reviewed material for which the qualifications of the original reviewer have been called into question will be conducted.

The results of this review will be used to determine additional corrective actions. The review will be completed by June 28, 1996. 2. PSE&G will evaluate NAP-14 to assure that qualification and documentation approval requirements, as specified in the ANS standard, are clearly reflected within the procedure.

This action will be completed by July l, 1996. 3. The lessons learned from this event will be communicated to the appropriate Nuclear Business Unit personnel to emphasize the need to assure that organizational structural changes are made consistent with the facility licensing bases. This will be completed by June 15, 1996. 4. PSE&G achieved partial compliance with the Salem Technical Specifications on April 19, 1996, when the OSR group was

  • segregated and four dedicated, full-time engineers were assigned to the Salem OSR group. The Hope Creek Station OSR group has three dedicated, full-time engineers assigned to it with the fourth position to be filled. This vacant position is expected to be filled by June 30, 1996.
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