ML18102A236

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
Issue date:	05/22/1996
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A235	List: ML18102A236
References
2.201, LR-N96132, NUDOCS 9607080388
Download: ML18102A236 (7)

See also: IR 05000272/1996005

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 -2 -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 -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.