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| | issue date = 09/29/1978 | | | issue date = 09/29/1978 |
| | title = Responds to 780906 NRC Ltr Re Deviation Noted in Inspec Rept #50-272/78-18.Util Claims Alleged Violation Was Not & Did Not Represent Noncompliance w/10CFR50.59 Since Subteired Procedures Are Controlled by QA Prog to Comply W/Fsar | | | title = Responds to 780906 NRC Ltr Re Deviation Noted in Inspec Rept #50-272/78-18.Util Claims Alleged Violation Was Not & Did Not Represent Noncompliance w/10CFR50.59 Since Subteired Procedures Are Controlled by QA Prog to Comply W/Fsar |
| | author name = SCHNEIDER W F | | | author name = Schneider W |
| | author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY | | | author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY |
| | addressee name = GRIER R H | | | addressee name = Grier R |
| | addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | | addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| | docket = 05000272, 05000311 | | | docket = 05000272, 05000311 |
Line 15: |
Line 15: |
| | page count = 28 | | | page count = 28 |
| }} | | }} |
| See also: [[followed by::IR 05000272/1978018]]
| |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:.-* Frederick | | {{#Wiki_filter:.- |
| W. Schneider | | Frederick W. Schneider Vice President Production Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 September 29, 1978 Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406 |
| Vice President | |
| Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 | |
| Production
| |
| * -* Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory
| |
| Commission | |
| Office of Inspection | |
| and Enforcement | |
| Region 1 631 Park Avenue King of Prussia, Pennsylvania | |
| 19406 Dear Mr. Grier: NRC INSPECTION | |
| REPORT NO. 50-272/78-18
| |
| SUPPLEMENTAL
| |
| INFORMATION
| |
| NO. 1 UNIT SALEM NUCLEAR GENERATING
| |
| STATION September
| |
| 29, 1978 Pursuant to your letter of September
| |
| 6, 1978 in response to our letter of August 11, 1978, we acknowledge
| |
| that revision to Operational
| |
| Quality Assurance
| |
| Instruction
| |
| Number 5, "Auditing," to a two-year audit cycle constituted
| |
| a noncompliance
| |
| with our FSAR commitment.
| |
| It also was noncompliant
| |
| with Admiriistrative
| |
| Procedure
| |
| 17, "Operational
| |
| Assurance
| |
| Program," which is subject to review and approval by the Corporate
| |
| Quality Assurance
| |
| Department.
| |
| Please be advised that the Operational
| |
| QA Program was not, and can not, be changed by revising subtier procedures
| |
| such as OQI's. The "premature" revision to OQI-5 was identified
| |
| by Corporate
| |
| QAD in March, 1978 and brought to the attention
| |
| of the Salem Generating
| |
| Station by letter dated March 13, 1978. The Manager -Salem Generating
| |
| Station was therefore
| |
| apprised of the noncompliance
| |
| with recommended
| |
| corrective
| |
| action by Corporate
| |
| QAD well in advance of your May 2-5, 1978 inspection.
| |
| This compliance
| |
| was appropriately
| |
| identified, documented
| |
| and seminated
| |
| under the provisions
| |
| and controls of the QA Program and there was no intent to permit this item to remain uncorrected.
| |
| '1811130111
| |
| * ... ... * ... ' '."' Mr. B. H. Grier -2 -9/29/78 As previously
| |
| stated in our response dated August 11, 1978, the subject item of noncompliance
| |
| did not represent
| |
| noncompliance
| |
| with lOCFRS0.59
| |
| since subtiered
| |
| procedures
| |
| are controlled
| |
| by the QA Program to assure continuing
| |
| compliance
| |
| with our FSAR as demonstrated
| |
| in this case. CC: Director-Inspection
| |
| and Enforcement
| |
| Bethesda, Maryland 20014
| |
| UNITED STATES NUCLEAR REGULATORY
| |
| COMMISSION
| |
| REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA
| |
| 19406 Public Service
| |
| Electric and Gas Company ATTN: Mr. F. W. Schneider
| |
| Vice President
| |
| -Production
| |
| 80 Park Place Newark, New Jersey 07101 \. Gentlemen:
| |
| Subject: Inspection.
| |
| 50-272/78-18;
| |
| 50-311/78-13
| |
| SEP 6 1978 This refers to your letter dated August 11, 1978, in response to our letter dated June and July 19, 1978. Your letter requested
| |
| clarification
| |
| of the word "annual".
| |
| As noted in our report, annual (when used to describe.
| |
| the frequency
| |
| for auditing a particular
| |
| activity)
| |
| means that the activity must be audited within 12 months following
| |
| the last review of the area. Further clarification
| |
| is given in your Technical
| |
| Specification, Section 6.5.2.8, Audits, which requires aud.its of the. conformance
| |
| of the facility to the Technical
| |
| Specification;
| |
| and the performance, training and qualifications
| |
| of the facility staff " .*. at least once per 12 months.11 For example, an audit of the performance, training and .qualification
| |
| of personnel pleted on October 15, 1976, is required to be performed
| |
| agai'n by October 15, 1977. . Regarding
| |
| your comments concerning
| |
| the item of noncompliance, although only Procedure
| |
| OQI-5 was changed, this procedure
| |
| effected actual mentation
| |
| of your FSAR commitment
| |
| for an annual audit frequency.
| |
| As noted in our report, superceding
| |
| this FSAR commitment.
| |
| by changing cedure OQI-5 without an evaluation
| |
| in accordance
| |
| with 10 CFR 50.59 stitutes noncompliance.
| |
| We note that your effort to amend OQI-5 to reflect the annual ment and to complete all of the requ.ired
| |
| audits in a timely manner appears as effective
| |
| corrective
| |
| action for this item of noncompliance.
| |
| This action will be examined in a subsequent.inspection
| |
| of your licensed pr.ogram.
| |
| L-*-------
| |
| -*----*-... -, Public.Service
| |
| Electric and Gas Company 2 Your cooperation
| |
| with us is appreciated.
| |
| cc: Sincerely, !lf<P fl .$4_._;r Boyle H. Grier Director F. P. Librizzi, General Manager -Electric Production
| |
| E. N. Schwalje, Manager -Quality Assurance
| |
| R. L. Mittl,
| |
| Managerr -Licensing
| |
| and Environment
| |
| H. J. Midura, Manager -*sa l em Generati_n*g
| |
| Sta ti on
| |
| Frederick
| |
| W. Schneider
| |
| Vice President
| |
| Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373
| |
| Production
| |
| Mr. Boyce H. Grier Director of USNRC August 11, 1978 Off ice of Inspection
| |
| and Enforcement
| |
| Region 1 631 Park Avenue King of Prussia, Pennsylvania
| |
| 19406 Dear Mr. Grier; NRC INSPECTION
| |
| REPORT NO. 50-272/78-18
| |
| MAY 2 -5, 1978 UNIT NO. 1 SALEM NUCLEAR GENERATING
| |
| We have reviewed the report of your inspection
| |
| conducted
| |
| on May 2 -5, 1978, which was transmitted
| |
| with your letter of July 19, 1978, and received on July 24, 1978. Our response to the item of noncompliance
| |
| is as follows: Item A. Infraction, in NRC Inspection
| |
| 50-272/78-18, Appendix A: 10 CFRS0.59, "Changes, tests and experiments", states in part, "The holder of a license authorizing
| |
| operation
| |
| of a production
| |
| or utilization
| |
| facility may ... make changes in the procedures
| |
| as described
| |
| in the safety analysis port ..* without prior Comr.i.ission
| |
| approval, unless the posed change ... involves a change in the technical fications
| |
| incorporated
| |
| in the license or an unreviewed
| |
| safety question ... " Contrary to this requirement, a change was made in a procedure
| |
| described
| |
| in the safety analysis report, namely, the Salem Generating
| |
| Station Operational
| |
| Quality Assurance
| |
| Instruction
| |
| Number 5, "Auditing 11 , without a determination
| |
| of whether or not the change involved an unreviewed
| |
| safety question.
| |
| Reply: The activity described
| |
| in Appendix A, appears to be a standing between the station QA Engineer (SQAE) and the spector, rather than a violation.
| |
| This is explained
| |
| in the following:
| |
| Inspection
| |
| Report No. 50-272/78-18 -2 -8-11-78 Regulatory
| |
| Guide 1.33 and ANSI 45.2.12 are spelled out in Salem FSAR and are the basis for our operational
| |
| audit program. The latest revisions
| |
| of these two standards
| |
| are: (a) Regulatory
| |
| Guide 1.33 "Quality Assurance
| |
| Program quirements (Operation)
| |
| Rev. 1, February 1978." (b) ANSI N45.2.12 "Requirements
| |
| for Auditing of Quality Assurance
| |
| Programs for Nuclear Power Plants -1977." By examining (a) and (b) the SQAE realized that NRC guidance, as well as industry practice on the minimum audit period quirement, has changed from a cycle of one year to a cycle of two years. Therefore, he proposed a revision in the applicable
| |
| FSAR section for Unit 2 to reflect a two year cycle. He then submitted
| |
| this revision to Company management
| |
| for approval and submittal
| |
| to the NRC with the understanding
| |
| that the revised FSAR will apply to both Units 1 and 2. Since the audit cycle could not be changed prior to the approval of the revision of the FSAR, the SQAE prematurely
| |
| revised ""?" ational Quality Instruction
| |
| No. 5 (OQI-5). This instruction
| |
| is not part of the FSAR and its revision did not constitute
| |
| a change --T pursuant to 10CFR50.59.
| |
| During the first week of May 1978, the SQAE realized that the approval of his proposed revision to the FSAR would not be ceived in time to permit him to switch to a two year cycle. For this reason, and because of the inspector's
| |
| comments during his visit, OQI-5 was revised back to a cycle of one year, and the SQAE proceeded
| |
| to complete the audits within one year. We hope this explanation
| |
| is satisfactory
| |
| to show.that
| |
| no tion was involved in our activity.
| |
| Inspection
| |
| Report No. 50-272/78-18 -3 -8-11-78 We would also lik.e to bring to your attention
| |
| an area that needs clarification.
| |
| In the middle of page 5 of his report, the spector interpreted "annual" to be "once within each 12 month interval following
| |
| the last previous audit of the same area." We interpret "annual" differently, i.e. "once in a calendar year." In conclusion:
| |
| 1. All audits shown in our implementing
| |
| documents
| |
| will be pleted prior to the end of the annual audit cycle. 2. The latest available
| |
| revisions
| |
| of regulatory
| |
| guidance to which the FSAR is committed, suggest that audits of all safety related functions
| |
| be completed
| |
| within a period of two years. 3. In light of 1. and 2. above, it is suggested
| |
| that the activity described
| |
| in Appendix A of your report is not a violation, but a misunderstanding
| |
| as explained
| |
| in this letter. If you require additional
| |
| information, we will be pleased to discuss it with you. Sincerely, CC: Director -Inspection
| |
| and Enforcement
| |
| Bethesda, Maryland 20014
| |
| UNITED STATES NUCLEAR REGULATORY
| |
| COMMISSION
| |
| REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA
| |
| 19406 Public Service Electric and Gas Company ATTN: Mr. T. J. Martin JUN 1 2 W13-Vice President
| |
| -Engineering
| |
| and Construction
| |
| Mr. F. W.
| |
| * Vice President
| |
| -*Production
| |
| 80 Park Place Newark, New Jersey 07101 Gentlemen:
| |
| Subject: Inspection
| |
| 50-311/78-13;
| |
| 50-272/78-18
| |
| This refers to the inspection
| |
| conducted
| |
| by Mr. J. R. White of this office on May 2-5, 1978, at Salem Nuclear Generating
| |
| Station, of activities
| |
| authorized
| |
| by NRC Permit No. CPPR-53 and DPR-70 and to the discussions
| |
| of our findings*held
| |
| by Mr. White with Mr. H. J. Midura of your staff at the
| |
| of the inspection, and to a subsequent
| |
| telephone
| |
| discussion
| |
| between Mr. White and Mr. J. L. Stillman of your staff on May 15, 1978. * Areas examined during this inspection
| |
| are described
| |
| in the Office of Inspection
| |
| and Enforcement.
| |
| Inspection
| |
| Report which is enclosed with this letter. Within these areas, the inspection
| |
| of selective
| |
| examinations
| |
| of procedures
| |
| and representative
| |
| records, interviews
| |
| with personnel, measurements
| |
| made by the inspector,.
| |
| and observations
| |
| by the inspector.
| |
| * Based on the results of this inspection, it appears that one of your *activities
| |
| was not conducted
| |
| in full compliance
| |
| with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance
| |
| has been categorized
| |
| into the levels as described
| |
| in our correspondence
| |
| to you date*d December 31, 1974. This
| |
| is sent to yob pursuant to the provisions
| |
| of Section 2.201 of the NRC's "Rules of Practice-," Part 2, Title Code of Federal Regulations.
| |
| Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement
| |
| or explanation
| |
| in reply including:*-
| |
| (1) corrective
| |
| steps which have been taken by you and the results (Z) corrective
| |
| steps which will be taken to avoid further items of noncompliance;
| |
| and (3.) the date when full compliance
| |
| will be achieved.
| |
| : .... *-----------.
| |
| .. -. --. -**--=-===================---......,;;;;;,,
| |
|
| |
|
| Service Electric and Gas Company 2 In accordance
| | ==Dear Mr. Grier:== |
| with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures
| | |
| will be placed in the NRC 1 s Public Document Room. If this report contains any information
| | NRC INSPECTION REPORT NO. 50-272/78-18 SUPPLEMENTAL INFORMATION NO. 1 UNIT SALEM NUCLEAR GENERATING STATION Pursuant to your letter of September 6, 1978 in response to our letter of August 11, 1978, we acknowledge that revision to Operational Quality Assurance Instruction Number 5, "Auditing," |
| that you (or your contractor}
| | to a two-year audit cycle constituted a noncompliance with our FSAR commitment. It also was noncompliant with Admiriistrative Procedure 17, "Operational Q~ality Assurance Program," which is subject to review and approval by the Corporate Quality Assurance Department. |
| believe to be proprietary, it is necessary
| | Please be advised that the Operational QA Program was not, and can not, be changed by revising subtier procedures such as OQI's. |
| that you make a written application
| | The "premature" revision to OQI-5 was identified by Corporate QAD in March, 1978 and brought to the attention of the Manager-Salem Generating Station by letter dated March 13, 1978. The Manager - Salem Generating Station was therefore apprised of the noncompliance with recommended corrective action by Corporate QAD well in advance of your May 2-5, 1978 inspection. This |
| within 20 days to this office to withhold such information
| |
| from public disclosure.
| |
| Any such application
| |
| must be accompanied
| |
| by an affidavit
| |
| executed by the owner of the information, which identifies
| |
| the document or part sought to be wi.thheld, and which contains a statement
| |
| of reasons which addresses
| |
| with specificity
| |
| the items which will be considered
| |
| by the Commission
| |
| as listed in subparagraph (b)(4} of Section 2.790. The informatian
| |
| sought to be withheld *shall be incorporated
| |
| as far as possible into a separate part of the affidavit.
| |
| If we do not hear from you in this regard within the specified
| |
| period, the report will be placed in the Public Document Room. Should you have any questions
| |
| concerning
| |
| this inspection, we will be pleased to discuss them with you. * Enclosures:
| |
| Sincerely, Hilbert W. Crocker, Acting Chief Fuel *Facility
| |
| and Materials
| |
| Safety Branch l. Appendix A, Notice of Violation . 2. Office of Inspection
| |
| and Enforcement
| |
| Inspection
| |
| Report Numbers 50-311/78-13;
| |
| cc w/encls: E. N. Schwalje, Manager -Quality Assurance
| |
| Docket No. 50-272 License No. DPR-70 APPENDIX A NOTICE OF VIOLATION
| |
| Based on the results of an NRC inspection
| |
| conducted
| |
| on May 25, 1978, it appears that one of your activities
| |
| was not conducted
| |
| in full compliance
| |
| with NRC r_egulations
| |
| as indicated
| |
| below: This item is an infraction.
| |
| 10 CFR 50.*59,*11 Changes, tests and experiments
| |
| 11 , states in part, 11 The holder*of
| |
| a license authorizing
| |
| operation
| |
| of a production
| |
| or *utilization
| |
| facility may ... make changes in the procedures
| |
| as scribed in the safety analysis report *.* without*prior
| |
| Commission
| |
| approval, unless the proposed change ... involves a change in the technical
| |
| specifications
| |
| in the license
| |
| unre-viewed Safety question.***
| |
| II . Contrary to this requirement, a change was made in a procedure
| |
| described
| |
| in. the safety analysis report, namely the Salem ting Station Operational
| |
| Quality Assurance
| |
| Instruction
| |
| Number 5, 11 Auditing 11 , without a determination
| |
| of whether or not the change e involved.
| |
| an unreviewed
| |
| _safety question.
| |
| --
| |
| Report No. U.S. NUCLEAR REGULATORY
| |
| COMMISSION
| |
| OFFICE OF INSPECTION
| |
| AND ENFORCEMENT
| |
| 50-272/78-18
| |
| 50-311 /78-13 50-272 Region I Docket No. 50-311 -=o=p=R""""'-7=-=o.---
| |
| License No. ---------Priority cPPR-53 ------. Category c A3 -------Licensee:
| |
| Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name: Sa:lem Nuclear Generation
| |
| Station, Units 1 & 2 Inspection
| |
| at: Hancocks Bridge, New Jersey Inspection
| |
| Inspectors: J .JR. White, Radfat.fon
| |
| Specialist
| |
| .-e .... __ Approved by: Inspection
| |
| Summary: date signed * date signed date signed
| |
| on
| |
| *1973 {Repott Nos. 50-311/78-13;
| |
| 50-272/78-18)
| |
| * 1 Areas.Inspected:
| |
| Routine, unannounced
| |
| inspection
| |
| of the pre-operational
| |
| status of the Radiation
| |
| Protection
| |
| Program to be implemented
| |
| for Unit No. 2. Areas examined included organization, inifial and refresher
| |
| training, radiation'
| |
| protection cedures, faci 1 i ty status,. instruments
| |
| and equipment, respiratory
| |
| protection
| |
| and. the implementation
| |
| of ALARA concepts.
| |
| The-inspection
| |
| consisted
| |
| of 26
| |
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Rept Summarizes Liquid & Gaseous Releases & Solid Waste Shipments from Salem Generating Station for Period of Jan-June 1999 ML18107A5181999-08-26026 August 1999 Forwards Ninety Day Rept for ISI Activities Conducted at Sgs,Unit 2 During Ninth Extended Outage & Tenth Refueling Outage.List of Encl,Provided ML18107A5061999-08-26026 August 1999 Provides First Feedback from Observation of NRC Insp Under Pilot Nuclear Power Plant Insp Program.Attached Are Completed Insp Feedback Forms for Procedure 71111, Attachment 21 & Procedure 71151 ML18107A4981999-08-26026 August 1999 Forwards Response to NOV That Resulted from Predecisional Enforcement Conference Conducted on 990624.Corrective Actions:Communications to Supervisors Reinforced Employee Right & Duty to Raise Nuclear Safety Issues ML18107A5051999-08-24024 August 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Request IAW Requirements of 10CFR50.91(b) & Has No Comments Re Amend to FOL Change Request S99-02 to Modify TS Re Penetration Valves ML18107A4921999-08-23023 August 1999 Provides Suppl Info Re 971024 Amend Request to Modify TS 3/4 7.7, Auxiliary Bldg Exhaust Air Filtration Sys. Util Withdraws from Request All Proposed Changes Associated with Filter Testing,Per Issuance of GL 99-02 ML18107A4911999-08-20020 August 1999 Forwards Revised Plant Attribute Libraries for Salem & Hope Creek Generating Stations,Iaw 10CFR50,App E,Vi, Emergency Response Data Sys, 3.b.Changes Are Identified by Rev Bars ML18107A4861999-08-19019 August 1999 Forwards NPDES Discharge Monitoring Rept, for Salem Generating Station for Month of Jul 1999.Rept Required by & Prepared Specifically for EPA & Nj Dept of Environ Protection ML18107A4831999-08-18018 August 1999 Submits Licensee Comments on NRC 990730 Ltr Which Provided Notification of Close Out of TAC Numbers MA0567 & MA0568 Re GL 92-01,Rev 1,Suppl 1 ML18107A4801999-08-13013 August 1999 Requests That Pse&Gs Contact in NUREG-0383, Directory of Compliance for Radioactive Matl Packages, Be Changed ML18107A4751999-08-0505 August 1999 Forwards Fitness for Duty Performance Data Rept for Six Month Period Ending 990630 ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML18107A4531999-07-20020 July 1999 Forwards Discharge Monitoring Rept for Salem Generating Station, for June 1999.Rept Is Required by & Prepared for EPA & Nj Dept of Environ Protection ML18107A4431999-07-0606 July 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Pse&G License Change Request S98-17 Re Permissible Enrichment Values for New Fuel Storage & Has No Comments ML20196J6301999-07-0101 July 1999 Requests Addl Info Re Status of Decommissioning Funding for Limerick Generating Station,Units 1 & 2,Peach Bottom Atomic Power Station,Units 1,2 & 3 & Salem Nuclear Generating Station,Units 1 & 2 ML18107A4181999-06-30030 June 1999 Submits Response to NRC Request for Info Re Y2K Readiness at Npps,Per GL 98-01,suppl 1.Disclosure Encl ML20209B6751999-06-29029 June 1999 Ack Receipt of from Dr Powell in Response to NRC Re Fitness for Duty.Attachment 2 of Will Be Withheld from Public Disclosure,Per 10CFR2.790 ML18107A4131999-06-25025 June 1999 Provides Further Clarification of Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting Station SBO & Loca/Loop Loading Requirements,Per Util 990426 Ltr & Discussion with NRC ML18107A4091999-06-22022 June 1999 Forwards Discharge Monitoring Rept for May 1999,containing Info as Required by Permit NJ0005622.Rept Prepared Specifically for EPA & Nj Dept of Environ Protection ML18107A4061999-06-21021 June 1999 Provides Supplemental Info to Proposed License Amend, Modifying TS 3/4 7.7, Auxiliary Bldg Exhaust Air Filtration Sys. Info Re Acceptance Criterion Discussed ML18107A3691999-06-11011 June 1999 Forwards Corrected Monthly Operating Rept for Apr 1999 for Salem Generating Station,Unit 1.Original Submittal Contained Typo for year-to-date Value for Numbers of Hours Generator Was on Line (Service Hours) ML18107A3641999-06-0404 June 1999 Requests Enforcement Discretion for TS 3/4.6.2.3 Re Containment Cooling Sys for Salem Generating Station,Unit 1 ML18107A3561999-06-0303 June 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Pse&G License Change Request S99-05 & Has No Comments ML18107A3611999-05-27027 May 1999 Forwards Responses to NRC 990301 & 990323 RAIs for Salem & Hope Creek Generating Stations Relating to GL 96-05 ML18107A3301999-05-24024 May 1999 Forwards Suppl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves. Encl Contains Methodology Used in Determination of Pressure Locking Susceptibility of PORVs Block Valves ML18107A3371999-05-21021 May 1999 Forwards NPDES Discharge Monitoring for Salem Generating Station for Apr 1999, Containing Info as Required by Permit NJ0005622 ML18107A3291999-05-20020 May 1999 Forwards Redacted Response to NRC 990322 RAI Re Notification of Licensed Operator That Tested Positive for Alcohol. Attachment 2 Withheld,Per 10CFR2.790(a)(6) ML18107A3031999-05-18018 May 1999 Provides Summary of Changes to NRC Commitments That Have Been Made But Not Reported by Other Means,Iaw with NEI Process for Managing NRC Commitments ML18107A2891999-05-13013 May 1999 Forwards Rev 36 to Pse&G Nuclear Business Unit Emergency Plan. Rev 36 Incorporates Changes to Section 1-3,6 & 7 & 9-17.Attached Copy Includes All Sections of EP for Completeness ML18107A2951999-05-12012 May 1999 Submits SG Tube Plugging Rept,Per Plant TS 4.4.6.5.a.Total of 47 Tubes Were Plugged During SG Tube Insps,Which Were Completed During Plant Tenth RFO ML18107A2861999-05-11011 May 1999 Forwards Rev 0 to NFS-0174, COLR for Salem Unit 2 Cycle 11. COLR Rept Was Received by Util as Part of Reload SE ML18107A2481999-04-29029 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Salem & Hope Creek Generating Stations. Rept Summarizes Results of Radiological Environ Surveillance Program for 1998 ML18107A2511999-04-27027 April 1999 Submits 30-day Fuel Clad Temp Rept for Salem Generating Station,Units 1 & 2.Rept Describes Changes to Calculated Peak Clad Temp (PCT) for Plant Large & Small LOCA & Small Break LOCA Analyses ML18107A2631999-04-26026 April 1999 Provides Clarification on Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting SBO & Loca/ LOOP Loading Requirements ML18107A2371999-04-26026 April 1999 Forwards Corrected Response to NRC RAI Re Licensee Request for Change to TS Permissible Enrichment Values for New Fuel Storage.Incorrect Attachment Was Provided with Util 990412 Ltr to Nrc.Encl Supersedes 990412 Submittal 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18107A5601999-10-18018 October 1999 Submits 30-day Fuel Clad Temp Rept,Iaw 10CFR50.46.Rept Describes Changes to Calculated Peak Clad Temp (PCT) for Salem Generating Station Large & Small Break LOCA Analyses ML18107A5531999-10-0808 October 1999 Forwards Summary Rept of Plant Startup & Power Ascension Testing for Sgs,Unit 2 Cycle 11,per Requirements of TS 6.9.1.1 ML18107A5561999-10-0707 October 1999 Requests Relief Associated with Containment Examinations at Hope Creek & Salem Generating Stations.Attachment 1 Includes Proposed Alternatives & Supporting Justification for Relief Requests ML18107A5501999-10-0505 October 1999 Provides Current Status of Pse&G Actions Re GL 98-01, Y2K Readiness of Computer Sys at Npps, for Salem Nuclear Generating Station,Units 1 & 2 & Hope Creek Nuclear Generating Station ML18107A5521999-10-0505 October 1999 Encourages NRC to Support Abb Combustion Engineering Nuclear Power Request for Priority Review of Generic TR Re Crossflow Ultrasonic Flow Measurement Sys ML18107A5591999-10-0505 October 1999 Informs That Nj Dept of Environ Protection Has No Comments on License Change Request S99-07 for Sgs,Units 1 & 2 ML18107A5341999-09-22022 September 1999 Provides Data Re Operator Licensing Exam for Salem & Hope Creek Station,In Response to NRC Form 536 (7-1999) ML20212B3631999-09-14014 September 1999 Forwards Rev 13 to Salem - Hope Creek Security Plan,Iaw 10CFR50.54(p).Summary of Proposed Changes to Plan,Encl. Encl Withheld ML18107A5321999-09-13013 September 1999 Forwards Revised 10CFR50.92 Evaluation to Clarify Util Response to Question Number 1 Re Amend to Modify TS 3/4 8.1, AC Power Sources. ML18107A5331999-09-13013 September 1999 Provides Notification That PSEG Intends to Utilize ASME Code Case N-481 During Second ISI Interval at Sgs Units 1 & 2 ML18107A5351999-09-13013 September 1999 Informs That NRC Has Reviewed Pse&G Request Proposing to Modify TS Which Allow EDG to Be Operated for 24 Surveillance Test During Any Mode,Iaw 10CFR50.91(b) & Has No Comments ML18107A5231999-09-0808 September 1999 Forwards Salem Generating Station Semiannual Radioactive Effluent Release Rept for Jan-June 1999. Rept Summarizes Liquid & Gaseous Releases & Solid Waste Shipments from Salem Generating Station for Period of Jan-June 1999 ML18107A5221999-09-0808 September 1999 Requests Approval to Use ASME Code Case N546,which Provides Alternative Qualification Requirements That Allow Personnel Most Familiar with Walkdown of Plant Sys,Like License Operators to Perform VT-2 Examinations ML18107A4981999-08-26026 August 1999 Forwards Response to NOV That Resulted from Predecisional Enforcement Conference Conducted on 990624.Corrective Actions:Communications to Supervisors Reinforced Employee Right & Duty to Raise Nuclear Safety Issues ML18107A5181999-08-26026 August 1999 Forwards Ninety Day Rept for ISI Activities Conducted at Sgs,Unit 2 During Ninth Extended Outage & Tenth Refueling Outage.List of Encl,Provided ML18107A5061999-08-26026 August 1999 Provides First Feedback from Observation of NRC Insp Under Pilot Nuclear Power Plant Insp Program.Attached Are Completed Insp Feedback Forms for Procedure 71111, Attachment 21 & Procedure 71151 ML18107A5051999-08-24024 August 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Request IAW Requirements of 10CFR50.91(b) & Has No Comments Re Amend to FOL Change Request S99-02 to Modify TS Re Penetration Valves ML18107A4921999-08-23023 August 1999 Provides Suppl Info Re 971024 Amend Request to Modify TS 3/4 7.7, Auxiliary Bldg Exhaust Air Filtration Sys. Util Withdraws from Request All Proposed Changes Associated with Filter Testing,Per Issuance of GL 99-02 ML18107A4911999-08-20020 August 1999 Forwards Revised Plant Attribute Libraries for Salem & Hope Creek Generating Stations,Iaw 10CFR50,App E,Vi, Emergency Response Data Sys, 3.b.Changes Are Identified by Rev Bars ML18107A4831999-08-18018 August 1999 Submits Licensee Comments on NRC 990730 Ltr Which Provided Notification of Close Out of TAC Numbers MA0567 & MA0568 Re GL 92-01,Rev 1,Suppl 1 ML18107A4801999-08-13013 August 1999 Requests That Pse&Gs Contact in NUREG-0383, Directory of Compliance for Radioactive Matl Packages, Be Changed ML18107A4751999-08-0505 August 1999 Forwards Fitness for Duty Performance Data Rept for Six Month Period Ending 990630 ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML18107A4431999-07-0606 July 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Pse&G License Change Request S98-17 Re Permissible Enrichment Values for New Fuel Storage & Has No Comments ML18107A4181999-06-30030 June 1999 Submits Response to NRC Request for Info Re Y2K Readiness at Npps,Per GL 98-01,suppl 1.Disclosure Encl ML18107A4131999-06-25025 June 1999 Provides Further Clarification of Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting Station SBO & Loca/Loop Loading Requirements,Per Util 990426 Ltr & Discussion with NRC ML18107A4061999-06-21021 June 1999 Provides Supplemental Info to Proposed License Amend, Modifying TS 3/4 7.7, Auxiliary Bldg Exhaust Air Filtration Sys. Info Re Acceptance Criterion Discussed ML18107A3691999-06-11011 June 1999 Forwards Corrected Monthly Operating Rept for Apr 1999 for Salem Generating Station,Unit 1.Original Submittal Contained Typo for year-to-date Value for Numbers of Hours Generator Was on Line (Service Hours) ML18107A3641999-06-0404 June 1999 Requests Enforcement Discretion for TS 3/4.6.2.3 Re Containment Cooling Sys for Salem Generating Station,Unit 1 ML18107A3561999-06-0303 June 1999 Informs That Nj Dept of Environ Protection Bureau of Nuclear Engineering Has Reviewed Pse&G License Change Request S99-05 & Has No Comments ML18107A3611999-05-27027 May 1999 Forwards Responses to NRC 990301 & 990323 RAIs for Salem & Hope Creek Generating Stations Relating to GL 96-05 ML18107A3301999-05-24024 May 1999 Forwards Suppl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves. Encl Contains Methodology Used in Determination of Pressure Locking Susceptibility of PORVs Block Valves ML18107A3291999-05-20020 May 1999 Forwards Redacted Response to NRC 990322 RAI Re Notification of Licensed Operator That Tested Positive for Alcohol. Attachment 2 Withheld,Per 10CFR2.790(a)(6) ML18107A3031999-05-18018 May 1999 Provides Summary of Changes to NRC Commitments That Have Been Made But Not Reported by Other Means,Iaw with NEI Process for Managing NRC Commitments ML18107A2891999-05-13013 May 1999 Forwards Rev 36 to Pse&G Nuclear Business Unit Emergency Plan. Rev 36 Incorporates Changes to Section 1-3,6 & 7 & 9-17.Attached Copy Includes All Sections of EP for Completeness ML18107A2951999-05-12012 May 1999 Submits SG Tube Plugging Rept,Per Plant TS 4.4.6.5.a.Total of 47 Tubes Were Plugged During SG Tube Insps,Which Were Completed During Plant Tenth RFO ML18107A2861999-05-11011 May 1999 Forwards Rev 0 to NFS-0174, COLR for Salem Unit 2 Cycle 11. COLR Rept Was Received by Util as Part of Reload SE ML18107A2481999-04-29029 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Salem & Hope Creek Generating Stations. Rept Summarizes Results of Radiological Environ Surveillance Program for 1998 ML18107A2511999-04-27027 April 1999 Submits 30-day Fuel Clad Temp Rept for Salem Generating Station,Units 1 & 2.Rept Describes Changes to Calculated Peak Clad Temp (PCT) for Plant Large & Small LOCA & Small Break LOCA Analyses ML18107A2371999-04-26026 April 1999 Forwards Corrected Response to NRC RAI Re Licensee Request for Change to TS Permissible Enrichment Values for New Fuel Storage.Incorrect Attachment Was Provided with Util 990412 Ltr to Nrc.Encl Supersedes 990412 Submittal ML18107A2631999-04-26026 April 1999 Provides Clarification on Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting SBO & Loca/ LOOP Loading Requirements ML18107A2411999-04-22022 April 1999 Forwards Draft Revised Pages 4.1 & 4.2 of Nuclear Business Unit Emergency Plan for Hope Creek & Salem Generating Stations.Changes Are Noted in Italics ML18107A1841999-04-14014 April 1999 Forwards PSEG Annual Rept for 1998, & PECO Annual Rept for 1998. Stockholders Annual Rept of Each Owner & Cash Flow Statements Showing 1998 Actual & 1999 Projected Cash Flow with Explanation Encl ML18107A1981999-04-12012 April 1999 Responds to 990312 RAI Re Request for Change to TSs Permissible Enrichment Values for New Fuel Storage,Which Was Submitted on 990202 ML18107A1691999-04-12012 April 1999 Forwards Proprietary & non-proprietary Epips,Including Rev 17 to EPIP 807,rev 1 to NC.EP-EP.ZZ-0801(Q) & Rev 2 to NC.EP-EP.ZZ-0806(Q) & Revised EPIPs Table of Contents. Proprietary Info Withheld ML20205K4541999-04-0808 April 1999 Forwards Revised Info Re 990330 NRC Nuclear Power Reactor Licensee Financial Qualifications & Decommissioning Funding Assurance Status Rept ML18106B1491999-04-0505 April 1999 Forwards Drafts of Proposed Changes to Pages 4.1 & 4.2 of Emergency Plan,Which Are Contained on Page 4.2 & Noted in Italics & Underlined ML20205F8981999-03-31031 March 1999 Provides Info Re Status of Decommissioning Funding for LGS, Units 1 & 2,PBAPS,Units 1,2 & 3 & Sgs,Units 1 & 2,per Requirements of 10CFR50.75(f)(1) ML18106B1431999-03-31031 March 1999 Forwards Pse&G Rept on Financial Min Assurance for Period Ending 981231 for Hope Creek,Salem,Units 1 & 2 & Pbaps,Units 2 & 3,IAW 10CFR50.75 ML18107A2201999-03-30030 March 1999 Forwards Final Exercise Rept for 980303,full-participation Plume Exposure Pathway Exercise & 980505-07, full-participation Ingestion Pathway Exercise of Offsite Radiological Emergency Response for Salem & Hope Creek 1999-09-08
[Table view] Category:UTILITY TO NRC
MONTHYEARML18095A4881990-09-17017 September 1990 Requests Regional Waiver of Compliance from Tech Spec 3.6.2.3, Containment Cooling Sys. Waiver Requested in Order to Allow Replacement of Containment Fan Cooler Unit Motor #22 W/O Requiring Plant Shutdown ML18095A4901990-09-13013 September 1990 Provides Supplemental Info Applicable to Clarification of 10CFR50,App R Exemption Request Re Fire Suppression Sys for Panel 335,per NRC Request ML20059E6821990-09-0404 September 1990 Forwards Info Re Temporary Mod to Security Plan Concerning Protected Area.Info Withheld ML18095A4641990-08-31031 August 1990 Forwards Revised Response to NRC Bulletin 88-004 Re Potential pump-to-pump Interaction.Util Pursuing Permanent Solution to Issue & Will Implement Appropriate Permanent Field Change by End of Unit 1 10th Refueling Outage ML18095A4621990-08-31031 August 1990 Provides Revised Response to Generic Ltr 89-13, Svc Water Problems Affecting Safety-Related Equipment. Only HXs Exhibiting Unsatisfactory Test Results Will Be Inspected & Possibly Cleaned ML18095A4431990-08-30030 August 1990 Forwards Salem Generating Station Semiannual Radioactive Effluent Release Rept,Jan-June 1990 & Rev 6 to Odcm. ML18095A4531990-08-30030 August 1990 Forwards RERR-28, Salem Generating Station Semiannual Radioactive Effluent Release Rept for Jan-June 1990 & Revised Odcm.W/O Revised ODCM ML18095A4391990-08-29029 August 1990 Forwards Semiannual Rept Re fitness-for-duty Performance Data for 6-month Period Ending 900630,per 10CFR26.71(d).Rept Includes Testing Results,Random Testing Program Results & Confirmed Positive Tests for Specific Substances ML18095A4421990-08-28028 August 1990 Clarifies 900710 Request for Amends to Licenses DPR-70 & DPR-75,changing Sections I & M.Under Proposed Change,Section I Should Be Changed to Read Section 2.J for License DPR-70 & Section M Changed to Read Section 2.N for License DPR-75 ML20059B6611990-08-22022 August 1990 Confirms That 10 Anchor/Darling Model S350W Swing Check Valves Installed at Plant,Per NRC Bulletin 89-002.All 18 Valves Inspected & Retaining Block Studs Replaced W/Upgraded Matl.No Crack Noted on Any Studs Which Were Replaced ML20059C2861990-08-21021 August 1990 Provides Correction to 900810 Response to Request for Addl Info Re Util Request for Restatement of OL Expiration Dates ML18095A4151990-08-10010 August 1990 Forwards Response to Request for Addl Info Re Reinstatement of OL Expiration Dates Based on Original Issuance of Ols. Advises That Correct Expiration Date for OL Proposed to Be 200418 ML18095A4091990-08-0909 August 1990 Forwards Responses to NRC Comments Re Plant Simulator Certification for 10CFR55.45(b)(2),per 891228 Ltr ML18095A4061990-08-0808 August 1990 Forwards Corrected marked-up Pages for Tech Spec Table 3.3-11 Re Subcooling Margin Monitor & Reactor Vessel Level Instrumentation Sys,Per 900223 Ltr.Administrative Changes Made as Indicated ML18095A3861990-07-30030 July 1990 Forwards Listing of Station Blackout Major Audit Items Resolution Scope,Per Station Blackout Schedule Commitment ML18095A3661990-07-26026 July 1990 Forwards Decommissioning Repts for Hope Creek,Peach Bottom & Salem Nuclear Generating Stations ML18095A3761990-07-26026 July 1990 Forwards Decommissioning Repts & Certification of Financial Assurance for Plants ML18095A3721990-07-24024 July 1990 Forwards Rept & Certification of Financial Assurance for Decommissioning for Plants,Per 10CFR50.75 ML18095A3751990-07-18018 July 1990 Provides Status of Commitments Made to NRC by Util in 900109 Ltr Re NUREG-0737,Item II.D.1,per 900628 Telcon ML18095A3741990-07-18018 July 1990 Provides Supplemental Info Re Facility sub-cooling Margin Monitor ML18095A3611990-07-18018 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. ML18095A3621990-07-18018 July 1990 Forwards Corrected Tech Spec Page 3/4 3-5 for License Change Request 89-12 Submitted on 891227 & 900521 ML18095A3591990-07-13013 July 1990 Corrects Typo in 900702 Response to Generic Ltr 90-04 Re Schedule for Completion of Remaining Open Items ML18095A3471990-07-11011 July 1990 Responds to NRC 900611 Ltr Re Violations Noted in Insp Repts 50-272/90-14 & 50-311/90-14.Corrective Actions:Directive from Radiation Protection Mgt to All Radiation Protection Personnel Issued Re Control of Compliance Agreement Sheets ML18095A3451990-07-10010 July 1990 Forwards Addl Info Re License Change Request 89-03 Re Reactor Trip Sys Instrumentation ML18095A3461990-07-10010 July 1990 Responds to NRC 900608 Ltr Re Violations Noted in Insp Repts 50-272/90-12 & 50-311/90-12.Corrective Actions:Assessment of ECCS & Component Performance Undertaken & ECCS Flow Testing Procedure Upgraded to Address Human Factors ML18095A3491990-07-10010 July 1990 Forwards Jn Steinmetz of Westinghouse 900614 Ltr Re Reassessment of Util Response to Bulletin 88-002 ML18095A3481990-07-10010 July 1990 Submits Supplemental Rept Identifying Root Cause of Missed Commitment & Corrective Actions to Assure Future Compliance Re Implementation of Mods to Facility PASS ML18095A3441990-07-0909 July 1990 Provides Written Notification Re Change in Calculated Peak Clad Temp,Per 900606 Verbal Notification ML18095A3281990-07-0202 July 1990 Responds to NRC 900530 Ltr Re Violations Noted in Insp Repts 50-272/90-09 & 50-311/90-09.Corrective Actions:Util Intends to Use Nuclear Shift Supervisor as Procedure Reader & EOP, Rev 2 Under Development ML18095A3301990-07-0202 July 1990 Responds to Generic Ltr 90-04 Re Status of Licensee Implementation of Generic Safety Issues.Table Describing Status of Generic Safety Issue Implementation Encl ML18095A3391990-06-29029 June 1990 Forwards Correction to 890913 License Change Request 88-09, Consisting of Tech Spec Page 3/4 4-13 ML18095A3221990-06-28028 June 1990 Provides Supplemental Info Re 900223 Proposed Revs to Tech Specs for Reactor Vessel Level Instrumentation Sys.Tables 3.3-11a & 3.3-11b Should Be Combined Into Single Table ML18095A3231990-06-28028 June 1990 Responds to NRC 900518 Ltr Re Violations Noted in Insp Repts 50-272/90-10,50-311/90-10 & 50-354/90-07.Two Noncited Violations Disputed.Util fitness-for-duty Program Exceeds Part 26 Requirements for Positive Blood Alcohol Limits ML18095A3241990-06-28028 June 1990 Forwards Retyped Pages to 871224 License Change Request 87-15 & Modified,Per 900620 Ltr ML18095A3211990-06-26026 June 1990 Requests 30-day Extension Until 900730 to Provide Completion Schedule to Resolve Audit Findings Re Station Blackout ML18095A3161990-06-25025 June 1990 Forwards Supplemental Info Re Response to Generic Ltr 88-14. All Committed Actions Complete as of 900613 ML18095A3141990-06-25025 June 1990 Provides Schedule Change for Implementation of Control Room Mods.Schedule Modified to Address Overhead Annunciator Human Engineering Discrepancies During Phase III ML18095A3201990-06-25025 June 1990 Responds to NRC 900524 Ltr Re Violations Noted in Insp Repts 50-272/90-11 & 50-311/90-11.Corrective Actions:All Overdue Operations & Maint Procedure Files Reviewed for Outstanding Rev Requests & Procedure Upgrade Program Initiated ML18095A3001990-06-20020 June 1990 Provides Addl Info Re Application for Amend to Licenses DPR-70 & DPR-75 Concerning Turbine Valve Surveillance Interval,Per 900320 Request.Util Adding Direction to Personnel If Unnacceptable Flaws Found ML20043H6221990-06-20020 June 1990 Provides Supplemental Info Re NRC Bulletin 88-008 for Fifth Refueling Outage.Detailed Test Rept Being Prepared to Document Results of Each Individual Insp Re Insulation, Hangers & High Energy Break Areas ML18095A2991990-06-20020 June 1990 Forwards Westinghouse Affidavit Supporting 900412 Request for Withholding Proprietary Info from Public Disclosure Per 10CFR2.790 ML18095A2721990-06-0808 June 1990 Responds to NRC 900329 Ltr Re Weaknesses Noted in Insp Repts 50-272/90-80 & 50-311/90-80.Corrective Actions:Fire Doors Placed on Blanket Preventive Maint Work Order & Damaged Fire Doors Will Be Repaired Immediately ML18095A2711990-06-0606 June 1990 Submits Info in Support of 900522 Verbal Request for Relief from Requirements of ASME Section XI ML18095A2611990-06-0101 June 1990 Forwards Corrected Operating Data Rept, Page for Apr 1990 Monthly Operating Rept ML18095A2521990-06-0101 June 1990 Forwards Application in Support of Request for Renewal of NJPDES Permit NJ0005622,per Requirements of Subsection 3.2 of Plant Environ Protection Plan,Nonradiological ML18095A2591990-06-0101 June 1990 Forwards Corrected Unit Shutdown & Power Reductions, Page for Apr 1990 Monthly Operating Rept ML18095A2411990-05-30030 May 1990 Submits Special Rept 90-4 Addressing Steam Generator Tube Plugged During Fifth Refueling Outage.Plugging Completed on 900516.Cause of Tube Degradation Attributed to Normal Wear Due to Erosion/Corrosion Factors ML18095A2431990-05-30030 May 1990 Informs of Util Plans Re Facility Cycle 6 Reload Core, Expected to Achieve Burnup of 16600 Mwd/Mtu.All Postulated Events within Allowable Limits Based on Review of Basis of Cycle 6 Reload Analysis & Westinghouse SER ML18095A2531990-05-29029 May 1990 Provides Addl Info Re End of Life Moderator Temp Coefficient.Feedback Used in Steam Line Break Has No Relationship to Full Power Moderator Density Coefficient 1990-09-04
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Frederick W. Schneider Vice President Production Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 September 29, 1978 Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
NRC INSPECTION REPORT NO. 50-272/78-18 SUPPLEMENTAL INFORMATION NO. 1 UNIT SALEM NUCLEAR GENERATING STATION Pursuant to your letter of September 6, 1978 in response to our letter of August 11, 1978, we acknowledge that revision to Operational Quality Assurance Instruction Number 5, "Auditing,"
to a two-year audit cycle constituted a noncompliance with our FSAR commitment. It also was noncompliant with Admiriistrative Procedure 17, "Operational Q~ality Assurance Program," which is subject to review and approval by the Corporate Quality Assurance Department.
Please be advised that the Operational QA Program was not, and can not, be changed by revising subtier procedures such as OQI's.
The "premature" revision to OQI-5 was identified by Corporate QAD in March, 1978 and brought to the attention of the Manager-Salem Generating Station by letter dated March 13, 1978. The Manager - Salem Generating Station was therefore apprised of the noncompliance with recommended corrective action by Corporate QAD well in advance of your May 2-5, 1978 inspection. This non-compliance was appropriately identified, documented and dis-seminated under the provisions and controls of the QA Program and there was no intent to permit this item to remain uncorrected.
'1811130111
Mr. B. H. Grier 9/29/78 As previously stated in our response dated August 11, 1978, the subject item of noncompliance did not represent noncompliance with 10CFRS0.59 since subtiered procedures are controlled by the QA Program to assure continuing compliance with our FSAR as demonstrated in this case.
CC: Director-Inspection and Enforcement Bethesda, Maryland 20014
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA 19406 SEP 6 1978 Public Service Electric and Gas Company ATTN: Mr. F. W. Schneider Vice President - Production 80 Park Place Newark, New Jersey 07101
\.
Gentlemen:
Subject:
Inspection. 50-272/78-18; 50-311/78-13 This refers to your letter dated August 11, 1978, in response to our letter dated June 12~ and July 19, 1978.
Your letter requested clarification of the word "annual". As noted in our report, annual (when used to describe. the frequency for auditing a particular activity) means that the activity must be audited within 12 months following the last review of the area. Further clarification is given in your Technical Specification, Section 6.5.2.8, Audits, which requires aud.its of the. conformance of the facility to the Technical Specification; and the performance, training and qualifications of the facility staff " . * . at least once per 12 months. 11 For example, an audit of the performance, training and .qualification of personnel com-pleted on October 15, 1976, is required to be performed agai'n by October 15, 1977. .
Regarding your comments concerning the item of noncompliance, although only Procedure OQI-5 was changed, this procedure effected actual imple-mentation of your FSAR commitment for an annual audit frequency. As noted in our report, superceding this FSAR commitment. by changing Pro-cedure OQI-5 without an evaluation in accordance with 10 CFR 50.59 con-stitutes noncompliance.
We note that your effort to amend OQI-5 to reflect the annual require-ment and to complete all of the requ.ired audits in a timely manner appears as effective corrective action for this item of noncompliance.
This action will be examined in a subsequent.inspection of your licensed pr.ogram.
Public.Service Electric and Gas 2 Company Your cooperation with us is appreciated.
Sincerely,
!lf<P fl .$4_._;r Boyle H. Grier Director cc:
F. P. Librizzi, General Manager - Electric Production E. N. Schwalje, Manager - Quality Assurance R. L. Mittl, Gener~l Managerr - Licensing and Environment H. J. Midura, Manager - *sa l em Generati_n*g Sta ti on L-*------- -*----*-
Frederick W. Schneider Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Vice President Production August 11, 1978 Mr. Boyce H. Grier Director of USNRC Off ice of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406 Dear Mr. Grier; NRC INSPECTION REPORT NO. 50-272/78-18 MAY 2 - 5, 1978 UNIT NO. 1 SALEM NUCLEAR GENERATING ST.?-l~TION We have reviewed the report of your inspection conducted on May 2 - 5, 1978, which was transmitted with your letter of July 19, 1978, and received on July 24, 1978. Our response to the item of noncompliance is as follows:
Item A. Infraction, in NRC Inspection 50-272/78-18, Appendix A:
10 CFRS0.59, "Changes, tests and experiments", states in part, "The holder of a license authorizing operation of a production or utilization facility may ... make changes in the procedures as described in the safety analysis re-port ..* without prior Comr.i.ission approval, unless the pro-posed change ... involves a change in the technical speci-fications incorporated in the license or an unreviewed safety question ... "
Contrary to this requirement, a change was made in a procedure described in the safety analysis report, namely, the Salem Generating Station Operational Quality Assurance Instruction Number 5, "Auditing 11 , without a determination of whether or not the change involved an unreviewed safety question.
Reply:
The activity described in Appendix A, appears to be a misunder-standing between the station QA Engineer (SQAE) and the in-spector, rather than a violation. This is explained in the following:
Inspection Report 8-11-78 No. 50-272/78-18 Regulatory Guide 1.33 and ANSI 45.2.12 are spelled out in Salem FSAR and are the basis for our operational audit program. The latest revisions of these two standards are:
(a) Regulatory Guide 1.33 "Quality Assurance Program re-quirements (Operation) Rev. 1, February 1978."
(b) ANSI N45.2.12 "Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants - 1977."
By examining (a) and (b) the SQAE realized that NRC guidance, as well as industry practice on the minimum audit period re-quirement, has changed from a cycle of one year to a cycle of two years. Therefore, he proposed a revision in the applicable FSAR section for Unit 2 to reflect a two year cycle. He then submitted this revision to Company management for approval and submittal to the NRC with the understanding that the revised FSAR will apply to both Units 1 and 2.
Since the audit cycle could not be changed prior to the approval of the revision of the FSAR, the SQAE prematurely revised Oper-
""?" ational Quality Instruction No. 5 (OQI-5). This instruction is not part of the FSAR and its revision did not constitute a change
--T pursuant to 10CFR50.59.
During the first week of May 1978, the SQAE realized that the approval of his proposed revision to the FSAR would not be re-ceived in time to permit him to switch to a two year cycle. For this reason, and because of the inspector's comments during his visit, OQI-5 was revised back to a cycle of one year, and the SQAE proceeded to complete the audits within one year.
We hope this explanation is satisfactory to show.that no viola-tion was involved in our activity.
Inspection Report 8-11-78 No. 50-272/78-18 We would also lik.e to bring to your attention an area that needs clarification. In the middle of page 5 of his report, the in-spector interpreted "annual" to be "once within each 12 month interval following the last previous audit of the same area."
We interpret "annual" differently, i.e. "once in a calendar year."
In conclusion:
- 1. All audits shown in our implementing documents will be com-pleted prior to the end of the annual audit cycle.
- 2. The latest available revisions of regulatory guidance to which the FSAR is committed, suggest that audits of all safety related functions be completed within a period of two years.
- 3. In light of 1. and 2. above, it is suggested that the activity described in Appendix A of your report is not a violation, but a misunderstanding as explained in this letter.
If you require additional information, we will be pleased to discuss it with you.
Sincerely, CC: Director - Inspection and Enforcement Bethesda, Maryland 20014
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA 19406 JUN 1 2 W13-Public Service Electric and Gas Company ATTN: Mr. T. J. Martin Vice President - Engineering and Construction Mr. F. W. Schneid~r
- Vice President -*Production 80 Park Place Newark, New Jersey 07101 Gentlemen:
Subject:
Inspection 50-311/78-13; 50-272/78-18 This refers to the inspection conducted by Mr. J. R. White of this office on May 2-5, 1978, at Salem Nuclear Generating Station, of activities authorized by NRC Permit No. CPPR-53 and DPR-70 and to the discussions of our findings*held by Mr. White with Mr. H. J. Midura of your staff at the concl~sion of the inspection, and to a subsequent telephone discussion between Mr. White and Mr. J. L. Stillman of your staff on May 15, 1978.
- Areas examined during this inspection are described in the Office of Inspection and Enforcement. Inspection Report which is enclosed with this letter. Within these areas, the inspection consi~ted of selective examinations of procedures and representative records, interviews with personnel, measurements made by the inspector,. and observations by the inspector.
- Based on the results of this inspection, it appears that one of your
- activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance has been categorized into the levels as described in our correspondence to you date*d December 31, 1974. This notic~ is sent to yob pursuant to the provisions of Section 2.201 of the NRC's "Rules of Practice-," Part 2, Title 10~ Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including:*- (1) corrective steps which have been taken by you and the results ~chieved; (Z) corrective steps which will be taken to avoid further items of noncompliance; and (3.) the date when full compliance will be achieved.
P~blic Service Electric and Gas 2 Company In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC s Public Document Room. If this 1
report contains any information that you (or your contractor} believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be wi.thheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Commission as listed in subparagraph (b)(4} of Section 2.790. The informatian sought to be withheld *shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
- Sincerely, Hilbert W. Crocker, Acting Chief Fuel *Facility and Materials Safety Branch
Enclosures:
- l. Appendix A, Notice of Violation .
- 2. Office of Inspection and Enforcement Inspection Report Numbers 50-311/78-13; 50-272/78~18 cc w/encls:
E. N. Schwalje, Manager - Quality Assurance
Docket No. 50-272 License No. DPR-70 APPENDIX A NOTICE OF VIOLATION Based on the results of an NRC inspection conducted on May 25, 1978, it appears that one of your activities was not conducted in full compliance with NRC r_egulations as indicated below: This item is an infraction.
10 CFR 50.*59,* Changes, tests and experiments states in part, 11 11 11 The holder*of a license authorizing operation of a production or
- utilization facility may ... make changes in the procedures as de-scribed in the safety analysis report *.* without*prior Commission approval, unless the proposed change ... involves a change in the technical specifications incorpo~ated in the license ~ran unre-viewed Safety question.*** II .
Contrary to this requirement, a change was made in a procedure described in. the safety analysis report, namely the Salem Genera-ting Station Operational Quality Assurance Instruction Number 5, e
11 Auditing 11 , without a determination of whether or not the change involved. an unreviewed _safety question.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-272/78-18 Report No. 50-311 /78-13 50-272 Docket No. 50-311
-=o=p=R""""'-7=-=o.--- c License No. cPPR-53 Priority . Category A3 Licensee: Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name: Sa:lem Nuclear Generation Station, Units 1 & 2 Inspection at: Hancocks Bridge, New Jersey Inspection conduct~ -;;May~a Inspectors: ~. k~
J .JR. White, Radfat.fon Specialist date signed
.- e date signed Approved by:
Inspection Summary:
Insp~ction on M~y 2~5~ *1973 {Repott Nos. 50-311/78-13; 50-272/78-18)
- 1 Areas.Inspected: Routine, unannounced inspection of the pre-operational status of the Radiation Protection Program to be implemented for Unit No. 2. Areas examined included organization, inifial and refresher training, radiation' protection pro-cedures, faci 1i ty status,. instruments and equipment, respiratory protection and. the implementation of ALARA concepts. The- inspection consisted of 26 inspector"-hours on site by on NRC inspector~.
Results: Of the seven areas inspected there was one item of: noncompliance identified (Infraction - implementing a change in an FSAR listed audit practice and procedure without a determination of safety related status contrary to 10 CFR 50.59, Paragraph J 2, Docket No. 50-272).
- e-Regi on I Form 12 (Rev. April 77)
DETAILS
- l. Persons Contacted
- H. J. Midura, Manager, Salem Nuclear Generating Station
- L. K. Miller, Performance Engineer
- J. L. Stillman-, Station Quality Assurance Engineer
- M. F. Metcalf, Resident Quality Assurance Engineer
- N. L. Millis, Nuclear Operations - Health Physicist
- J. C. Gueller, Performance Supervisor, Health Physics and Chemistry
- A. W. Kapple, Quality Assurance, Staff Assistant B. Leap, Senior Quality Assurance Specialist T. Spencer, Quality Assurance Specialist D. Lyons, Quality Assurance Specialist J. Wood, Technical Foreman, Health Physics D. Godlewski, Technical Foreman, Health Physics -
J. Lloyd, Station Training Coordinator
- denotes those present at the exit interview conducte'd May 5, 1978.
- 2. Organization The licensee's representative indicated to the inspector, that the following organization chart depicted both the current and expected organizational support for the radiation protection program at Salem Nuclear Generating Station (SNGS).
Manager - SNGS Performance En ineer Performance Supervisor (l) Performance Supervisor (l)
Instrument and Control Health Physics and I Chemistry (RPM)
Instrument Foreman Tec hnic1ans I Technical Fdreman (5) 1 Technicians - Nuclear (9) r I I Technical Assistants (14)
I' Technical Helpers (15)
_J
3 The licensee's representative stated that to support Unit 2 operation there would be two more Technical Foreman and an increased number of Technical Assistants. An increase in the number of Technicians -
Nuclear is expected pending qualification of some Technical Assistants with ANSI Nl8.l-1972, "Selection and Training of Nuclear Power Plant Personnel. 11 During the course of this review, the inspector verified the following:
The Performance Supervisor - Health Physics and Chemistry is the designated Radiation Protection Manager (RPM); and does fully meet the qualifications for RPM as set forth in Regulatory Guide 1.8, "Personnel Selection and Training. 11 The RPM reports directly to the Performance Engineer, a high level of station management who does not have any functional responsibilities pertaining to the operational or production aspects of SNGS.
All Technicians, Nuclear, are regarded as technicians in responsible positions and are fully qualified in accordance with ANSI Nl8.l-1971.
The responsibilities of the members of the Performance Depart-ment relating to their functional areas in radiation protection are fully described in the Performance Department Manual (PDM) in accord with the specifications of ANSI 18.7-1972 (1976),
"Administrative Controls for Nuclear Power Plants. 11 The inspector did note the following discrepancies in the PDM:
- a. The qualifications statement for the Performance Supervisor -
Health Physics and Chemistry (RPM) does not reflect that the individual is required to meet the specifications as set forth in Regulatory Guide 1.8, "Personnel Selection and Training. 11
- b. The Corporate Health Physicist is still designated as the Per-formance Supervisor - Health Physics and Chemistry.
- c. The qualifications statement for Technician - Nuclear does not reflect that each technician is to be qualified in accordance with ANSI Nl8.l-1971.
4 The licensee's representative indicated that the PDM was currently being revised and that the matters covered in the inspector's com-ments would be considered. in the revision process.
The inspector indicated that this item would be further reviewed at a subsequent inspection of the facility. (78-13-01)
The licensee representative stated that the Technical Specification 6.3 requirement to have an individual qualified in radiation pro-tection procedures on site when fuel is in the reactor was currently met by having a Technician, Nuclear on site continually; and that the same practice would extend to Unit No. 2 after fuel load.
The inspector reviewed the licensee's audit program as required by Unit No. l Technical Specification 6.5.2.8, 11 Audits 11 , and noted the following:
- a. Regulation 10 CFR 50.59, 11 Changes, tests and experiments 11 ,
states, in part: 11 (a) (1) The holder of a license authorizing operation of a production or utilization facility may . . '.
make changes in the procedures as described in the safety*
analysis report.* . . without prior Commission approval, unless the proposed change . . . involved a change in the technical* specifications incorporated in the license or an unreviewed safety question. (2) A proposed change . * .
shall be deemed to involve.an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident of malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for an accident or malfunctio~ of a different type than any evaluated pre-viously in the safety an~lysis report may be created; or (iii) if the margin of safety as defined in the basis for any technical specification is reduced. (b) The licensee shall maintain records of changes in procedures . . * {in-cluding} a written safety evaluation which provides the-basis for the determination that the change does not in-volve an unreviewed safety question. 11
- b. The licensee's Final Safety Analysis Report (FSAR), Ap-pendix D, Section 5.18, Audits, states:
11 11 11 Under the dir-ection of the station Manager, the SQAE {Station Quality Assurance Engineer} is responsible for a system of planned periodic audits to verify plant compliance with all aspects
5 e.
of the OPQA {Operational Quality Assurance} program and station administrative procedures. The audit program will be established in accordance with ANSI N45.2.12. Audits will be performed by qualified personnel (SQAE and other super-visory personnel, as assigned) who are independent of the area or function being examined, and will involve coverage of safety related site activities as they are taking place, as well as review of records and documentation in accordance with an established periodic program. The frequency of audit will depend upon the criticality of each function and will be adjusted in view of problems encountered. However, audits will be scheduled on an annual basis as a minimum. 11
- c. ANSI N45.2.12, Requirements for Auditing of Quality As-11 surance Program for Nuclear Power Plants, Section 3.4.2 11 states: Audits will be regularly scheduled on the basis 11 of the status and importance of the activities to assure the adequacy of, and conformance with, the program. Ap-plicable elements of the quality assurance program shall be audited at least annually or at least once within the life of the activity, whichever is shorter. 11 The inspector noted that such statements indicate that the ap-plicable audits must be performed at least once within each 12 month interval following the last previous audit of the same area.
Upon review by the inspector, it was noted that the licensee had revised the "Salem Generating Station Operational Quality As-surance Instruction No. 5 - Auditing as of January 30, 1978, to 11 indicate the fo.llowing audit cycles for various elements in the quality assurance program:
Audit Cycle Audit Cycle Records & Documents Procurement & Storage A. l Document Control 2 years B. l Procurement Control 2 years A.2 Records Management 2 years B.2 Spare Parts Control 2 years A.3 Reports Management 2 years
6 Audit Cycle Audit Cycle Fuel-Waste-Refueling Testing & Inspection C. l Refueling 2 years D.l Startup Testing 2 years C.2 In Core Fuel Man. 2 years D.2 In-Service Insp. 2 years C.3 Rad. Waste Man. 2 years D.3 Measuring &Test 2 years C.4 SNM Safeguards 2 years Equipment Trng-Security-Safety Plant Maintenance E.l Security Program 2 years F.l Repair & Modifi- 2 years E.2 Rad. &Safety 2 years cation
&Chemistry E.3 Emergency Plan 2 years F.3 Tech. Spec. Re- Annual E.4 Training &Qual. Annual quirements F.4 Corrective Action 6 months The SQAE stated to the inspector that such change was done in order to align the licensee's program w*ith the recommendations of ANSI Nl8.7-1976, "Administrative Controls for Nuclear Power Plant, 11 but that a determination had not been made in accord with 10 CFR 50.59 to establish that the change did not involve an unreviewed safety question.
The inspector noted that the implementation of this procedure revision resulted in at least 24 audits.not being completed within the 12 month period fallowing the last previous audit of the same area, as is noted by the following:
ANNUAL AUDIT INTERVALS First 12 Month Second 12 Month Interval Interval-Status Audit No. Date Initiated Subject/Number Date Completed as of May 5, 1978 76-1-B .1-1 9/1/76 Procurement Control/B.l l 0/6/76 Not Done 76-1-F.l-2 9/1 /76 Repair & Modification - l 0/28/76 Initiated 4/1/87
- Cleanliness/F.l.b 76-1-E.4-3 9/1/76 Personnel Training and Quali- l 0/15/76 Not Done fication - Training/E.4.a 76-1-A.2-4 9/7/76 Records Management - Maintenance 10/21 /76 Not Done Equipment History File/A.2
{Special}
76-1-A.3-5 10/4/76 Reports Management - Nan-Routine 11/23/76 Not Done Event Reports/A.3.b 76-1-C.l-6 10/4/76 Ex Core Fuel Management/c.1.a 11/4/76 Not Done 76-1-D.3-7 10/4/76' Inservice Inspection/D.3 l /28/77 Initiated 5/1/78 76-1-F.3-8 10/4/76 Tech. Spec. Requirements - Organi- 11/3/76 Not Done zation and Administration/F.3.a 76-1-C.4-9 11/1/76 SNM Safeguards and Accountability/c.4 12/2/76 Not Done 76-1-E.3-10 11/1/76 Emergency Planning - Facilities, 2/22/77 Not Dane Equipment, Test & Drills/E.3.c
ANNUAL AUDIT INTERVALS First 12 Month Second 12 Month Interval Interval-Status Audit No. Date Initiated Subject/Number Date Completed as of May 5, l-978 76-1-F.2-ll 11/1/76 Special Processes - Welding-NDE/F.2 2/22/77 Not Dor:ie 76-1-0.2-12 12/l /76 Pre-Service Inspection/D.2 8/l /77 76-1-E.4-13 12/l /76 Personne.l Training and Qualification/ See Audit Not Done E.4.b 76-1-E.4-3 76-1-F.3-14 12/1/76 Tech. Spec. Requirements - Environmental 2/7/77 Initiated Protection/F. 3. d 1/11/78 77-1-8.2-15 1/3/77 Spare Parts Control - Issue of Spares/B.2 2/7 /77 Not Done 77-1-D.l-16 l /3/77 Startup Testing/D.l 4/28/77 Not Done 77-1-E.3-17 l /3/77 Emergency Planning - Fire Prevention/ Not Done Protection/E.3.a 77-1-F.l-18 l /3/77 Repair and Modification - Design Changes 5/20/77 Initiated and Modification/F.l.a 4/1/78 77-1-F.4-.19 l /3/77 Corrective Action - Outstanding Items
- Initiated Followup/F.4.a 3/1/78 77-1-A.3-20 2/1/77 Reports Management - Review of Audits 2/16/77 Not Done and Annual Reports/A.3.a 77-1-D.4-21 2/1/77 Changes, Tests and Experiments/D.4
77-1-A.l-22 3/8/77 Document Control/A.l 8/25/77 Initiated 3/1/78
e ANNUAL AUDIT lNTERYALS First 12 Month Second 12 Month Interval Interva 1-Sta.tus Audit No. Date Initiated Subject/Number Date Completed as of May 5, 1978 77-1-C. 1-23 3/8/77 Excore Fuel Management - Spent Fuel 3/18/77 Not Done Packaging &Shipping/C.l.b 77-1-E.2-24 3/8/77 Radiation Safety &Chemistry/E.2 4/28/77 Not Done 77-1-F.l-25 3/8/77 Repair &Modification - Maintenance 12/16/77 Initiated 4/1/78
/F.l.c .
77-1-A.2-26 4/5/77 Records Management/A.2 5/18/77 Not Done 77-1-C.3-27 4/5/77 Radioactive Waste/C.3 6/7/77 Completed 3/22/78 77-1-E.l-28 4/5/77 Security Program - Physical Pro- 7/15/77 Initiated 4/1/78 tection/E. l 77-1-F.3-29 4/5/77 Tech. Spec. Requirements - Refueling 4/28/77 Not Done Operations/F.3.c 77-1-B.3-30 5/5/77 Materials Handling and Ccintrol/B.3 6/3/77 Not Done 77-1-D.6-31 5/5/77 Measuring and Test Equipment Control 7/13/77 D.3 Initiated and Calibration/D.6 5/l/78 **
77-1-E.3-32 5/5/77 Emergency Planning - Strike Con-
- Not Done tengency Plan/E.3.d 77-1-C.2-33 6/6/77 In Core Fuel Management/C.2 6/27 /77 Not Done 77-1-D.5-34 6/6/77 Surveillance Testing/D.5
77-1-F.4-35 6/6/77 Corrective Action - Event Followup/
- Not Done F.4.b 77-1-E.3-36 6/27 /77 Emergency Planning - Emergency 8/15/77 Not Done Planning Offsite/E.3.b
ANNUAL AUDIT INTERVALS First 12 Month Second 12 Month Interval Interval-Status Audit No. Date Initiated Subject/Number Date Comp 1eted as of May 5, l978; 77-1-F.l-37 6/27 /77 Repair &Modification - Construction
- Initiated 4/1/78 Testing/Design Change/F.l.d 77-1-F.3-38 6/27 /77 Tech. Spec. Requirements - Review of 8/23/77 Not Done Plant Operations Review of Limiting Conditions for Operation/F.3.b
- A licensee Quality Assurance Specialist stated that these particular audits were postponed by Station Quality Assurance Engineer.
- A licensee Quality Assurance Specialist ~tated that as of the date of initiation of the Second Audit Cycle (second 1211 month interval), audits D.3 - "In-Service Inspection, 11 D.4 - 11 Changes, Tests and Experiments , D.5 - 11 Surveillance Testing, 11 and D.6 - 11 Measuring and Test Equip-ment Control and Calibration, 11 are incorporated in revised audit D.3 - 11 Measuring and Test Equipment. 11
11 The inspector noted that changing the procedure which implements the FSAR commitment regarding audit performance from an annual to a 2 year requirement, without determining whether such a;* change constituted an unreviewed safety question was contrary to the requirements of 10 CFR 50.59 and constituted an item of noncom-pliance. . (78-18-01) .
The licensee 1s Station Quality Assurance Engineer (SQAE) stated that the failure to meet the FSAR commitment was acknowledged by the licensee and that immediate effort*would be made to complete all audits required in the second 12 month interval by August, 1978. .
- 3. Radiation Protection Procedures The inspector reviewed all of the licensee 1s implemented Radiation Protection Procedures against the requirements of Unit No. l 1s Techncial Specifications, 6.8, 11 Procedures 11 , 6.11, 11 Radiation Pro-tection Program *. and ANSI Nl8.7-1972. (1976), 11 Adminis.trative 11 Controls for Nuclear Power Pl ants. 11
- It was verified by the inspector that:
a) all procedures had been approved by the Station Operations Review Committee in accordance with Unit No .. l 1s Technical Sped ficati on 6. 5, Review and Audi t 11 11 b) the procedure* format was as described by ANSI Nl8.7-1972 (1976);
c) the proce.dures reflected As Low As Reasonably Achievable (ALARA} concepts in accord with Regulatory Guide 8.8, 11 In-formation Relevant to. Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Reason-ably Achievable";
d) an administrative guide for procedure* preparation (PDM, Section 3.3, 11 Document Control detailed the development~ review and 11
)
implementation of Radiation Protection Procedures in accord with ANSI Nl8 ..7-1972 (1976).
rn the course of theinspector 1s review. of Radiation Protection Procedures, the inspector noted that there. were no procedures developed relating to the following areas:
12 MPC-Hour Accountability Extremity Monitoring Beta Dose Rate Determination Overexposure Investigation Lost, Damaged, or Off-Scale Dosimeter or TLD Evaluation Bioassay Nasal Smears Various Respiratory Protection Procedures Decontamination of Personnel The licensee's representative indicated that these areas would be reviewed and procedures would be developed as necessary.
The inspector indicated that this area would be reviewed in a
. subsequent inspection. (78-13-03)
The inspector noted the following discrepancies in the procedures that were implemented by the licensee:
Procedure 15.3.009, "Current Radiation Exposure Record, 11 indicates that only permanent station employees need to have their exposure recorded on a Form NRC-5. The inspector p~inted out that the procedure needs to indicate that all persons who are subject to exposure at the licensee s facility 1
must have their exposure recorded on Form NRC-5 in accordance with the requi'rements of 10 CFR 20.401, Records of surveys, 11 radiation monitoring, and disposal. 11 Procedure 15.4.008 and 15.4.009, Airborne Particulate" and 11 "Airborne Iodine" respectively, does not indicate that air samples, to be meaningful, must be related to actual personnel exposure, i.e., taken in the expected breathing zone of person-nel. The inspector pointed out that such an air sampling program was necessary to fully comply with the requirements of 10 CFR 20.103, "Exposure of individuals to concentrations of radioactive materials in air in restricted areas."
13 Procedure 15.3.009, "Radioactive Material Shipping" was noted by the inspector as not reflecting the current regulatory requirements of 49 CFR Parts 170-189 "Department of Trans-portation Hazardous Material Regulations;" and 10 CFR 71, "Packaging of Radioactive Material for Transport and Trans-portation of Radioactive Material Under Certain Conditions."
The inspector pointed out to the licensee the provisions in 10
- CFR 71 regarding the shipment of radioactive material in excess of Type A quantities; and the necessity of promulgating an NRC approved quality assurance program satisfying each of the applicable criter*ia specified in 10 CFR 71, Appendix E, "Quality Assurance Criteria for Shipping Packages for Radio-active Material."
The licensee stated that these procedures would be reviewed and amended as necessary.
The inspector indicated that these items would be reviewed in a subsequent inspection. (78-13-04)
- 4. Instruments and Equipment The inspector reviewed the licensee's inventory of radiation monitoring instruments, as listed below:
Instrument Quantity AMS-2 6 Dosimeter Charqers 7 E-140N (Count Rate Meter) 6 E-520 13 High Volume Air Samplers 20 Low.Volume Air Samplers 3 PIC-6 24 RAP-1 (Air Pump) 9 RAS-1 (Regulated Air Sampler) 8 RM-14 29 RM-16 2 R0-2 6 Teletector 7 RD-17 (High Level Detector) 2 PNR-4 2 PNC-4 2 PRM-4A 10 SAM-2 (Stabilized Assay Meter) 2 AC-218 (Beta Probe) l SAC-4 (Scint. Alpha Counter) l
. LCS-1 (Scaler) 2
14 Instrument Quantity BC-4 (Beta Counter) l MP-1 (Pulser) l HD-28 (Air Sampler) 3 FC-2 (Gas-Flow Counter) l SH-4 (Sample Holder) 3 MS-2 (Scaler) 4 PAC-4G 2 LS-6 (Shield) l AM-33! (Air Monitor) 3 PMC-4 (Portal Monitor) 2 PMC-48 (Portal Monitor) 7 HFM-3 (Hand-Foot Monitor) 2 LM-3 (Laundry Monitor) l HP-177 20 HP-210 10 Prima II I 4 NP-2 (Neutron Monitor) 2 Self Alarming Dosimeter Charger 9 TLD 3000 Self Reading Dosimeter 600 TLD Reader l The inspector noted that the instruments were capable of measuring various types of radioactive emissions over a sufficient range; and that the instruments appeared in sufficient quantity to initially support two operating units, provided all of the instruments are op-erational.
- The licensee indicated that additional equipment woulcf.be acquired as necessary to support the operation of the facility.
- 5. Training The inspector reviewed the following aspects of the licensee's training program:
A. Health Physics Training Program - The licensee currently utilizes a consulting service to augment the technical training of Technical Assistants and Technical Helpers.
The training course includes the following elements:
e
15 Plant System and Design Basic Math and Physics Health Physics to include personnel monitoring, surveys, radiological fundamental, instrum~ntation, ALARA con-cepts, emergency response, radioactive material handling, and respiratory protection License Conditions Federal Regulations On-the-job training provisions The inspector verified that the personnel currently holding the position of Technicians - Nuclear have completed an initial training program; but found that there was no refresher (or retraining) at this time in accordance with ANSI Nl8.7-1971.
The licensee's representative acknowledged the lack of a for-malized retraining program and indicated that such a program would be developed in time to support the Unit 2 operation.
The inspector indicated that this item would be reviewed in a subsequent inspection. , (78-13-05)
B. General Employee Training (GET) - The licensee has implemented a GET program which encompasses the following areas:
General Radiation Protection Emergency Plan Security Plan Quality Assurance Occupational Safety The program is conducted by lectures given by members of the station's training staff; and usually amounts to approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of instruction.
For those persons who are to be radiation workers, GET is augmented by 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of additional instruction, which is delineated in Administrative Procedure AP-24, Radiological 11 Safety Program. 11 The inspector noted that various ALARA concepts are included in the training program; and that a retraining program is being currently developed with implementation expected in about 3 months.
16 The licensee's training coordinator indicated that the training staff is expected to increase from 4 to 6 people to support Unit 2 operation.
- 6. Respiratory Protection Program The inspector noted that as of the time of the inspection, the licensee did not have a respiratory protection program in accord with 10 CFR 20. 103. The licensee's representative indicated that an approved program was expected to be implemented by September, 1978. The inspector stated that pursuant to 10 CFR 20.103(e), the licensee must inform the Director, Region I, (Philadelphia) 30 days before the date that respiratory pro-tection is first used under the provisions of 10 CFR 20.103.
The licensee representative acknowledged this requirement and in-dicated that the licensee would comply.
The inspector indicated that the respiratory protection program would be reviewed in a subsequent inspection. (78-13-06)
- 7. Facility Layout The inspector reviewed several elements of the Unit 2 layout to determine agreement with the FSAR.
The inspector noted that currently the radiation protection offices are located in a trailer complex adjoining the west side of Unit 1 turbine structure. It was pointed out by the inspector that failure to have adequate facilities located conveniently to those areas and functions controlled by Health Physics Performance Group would tend to compromise and jeopardize various radiological con-trols, particularly during outage conditions.
The licensee representative stated that facilities would be designed into the 100' elevation of the Service Building between the Unit 1 and Unit 2 containments; and the the Health Physics Performance Group would be expected to move into these facilities by January, 1979.
The inspector indicated that this area would be reviewed in a sub~
sequent inspection. (78-13-07)
.17
- 8. Exit Interview The inspector met with the licensee's representatives (denoted iri paragraph 1) at the conclusion of the inspection on May 5, 1978.
The inspector summarized the scope and findings of the inspection as noted in this report.