ML18093A836

Responds to NRC 880420 Ltr Re Violations Noted in Insp Repts 50-272/88-09,50-311/88-09 & 50-354/88-07.Corrective Actions: Audit Conducted of Contractor & Effective Program Implementation Verified

ML18093A836
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	05/19/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88077, NUDOCS 8805240261
Download: ML18093A836 (4)

Text

Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4199 Vice President -

Nuclear Operations May 19, 1988 NLR-N88077 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/88-09, 50-311/88-09 AND 50-3 54/88-07 SALEM AND HOPE CREEK GENERATING STATIONS FACILTY OPERATING LICENSE NOS. DPR-70, DPR-75 AND NPF-57 Public Service Electric and Gas Company (PSE&G) is in receipt of your April 20,1988 letter which transmitted a Notice of Violation

• concerning a failure to comply with Technical Specification

§ 6. 5.2.4.2.

Pursuant to the requirements of 10CFR2.201, our response to the Notice of Violation is provided in Attachment 1.

Sincerely, Attachment

• 8805240261 880519 PDR ADOCK 05000272 Q DCD

.c Document Control Desk Mr. G. w. Rivenbark 2

USNRC Licensing Project Manager - Hope Creek 05-19-88 Mr. G. w. Meyer USNRC Senior Resident Inspector - Hope Creek j .

Mr. D. C. Fischer USNRC Licensing Project Manager - Salem Mr~ R. w. Borchardt USNRC Senior Resident Inspector - Salem Mr. w. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road

• Trenton, NJ 08628

• ATTACHMENT 1 10CFR2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM AND HOPE CREEK GENERATING STATIONS RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-272/88-09, 50-311/88-09 AND 50-354/88-07 As described in Appendix A of your letter dated April 20, 1988, Technical Specification §6.5.2.4.2 (for Salem and §6.5.2.4.3 for Hope Creek) requires, in part, that audits of activities required by the Operations Quality Assurance Program meet the Criteria of Appendix "B", 10 CFR 50, be performed ~t least once per 24 months. This requirement is implemented by the licensee in its "Master Audit Plan, QA Audit Group, Nuclear Quality Assurance, Rev. 2 document dated November 23, 1986 which requires an annual audit of Meteorological Program as part of the annual audit of Radiation Protection Services.

Contrary to these requirements, the Meteorological Program was not audited on an annual basis as required. The Meterological Program has not been audited since 1984.

1. PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.

We acknowledge that a portion of the Meterological Program (J. E. Healy, Co-contractor) has not been audited since 1984, however, th~ remaining functions of the program have been audited as required. The Meteorological Program functions and responsibilities are as follows:

Radiation Protection Services - Overall coordination of the program.

Operations Department - Compliance with Technical Specification requirements and surveillance associated with the Meterological Program.

J. E. Healy Company (Contractor) - Calibration of Met. tower instrumentation, preventive maintenance of tower sensors and verification of control room wind instrumentation accuracy.

Meteorological Evaluation Services (Contractor) - Validation of Meteorological data and identification of discrepancies including review and verification of system calibration, maintenance and operations log.

• .

The Master Audit Plan requires that the Meterological Program be included within the annual audit of Radiation Protection Services organization. The intent of this requirement is to audit those functions of the Meterological Program not included within other audits conducted within the year. The annual audit of the Radiation Protection Services failed to include the Meteorological Program and therefore the functions of J. E. Healy Company (contractor) were not audited as planned. The remaining functions and re8ponsibilities for implementing the Meteorological Program have been audited and effectiveness of program implementation verified, as identified below.

Audit No. Date Organization/Activity Audited S-84-42 6/84 Met. Evaluation Serv. (contractor)/audit NM-8 5-014 6/8 5 of overall Met. Program and interface NM-8 6-043 6/8 6 responsibilities.

NM-8 6-34 10/8 6 Operations/Tech Spec audits including NM-88-43 2/88 compliance with Met. instrumentation surveillence requirements.

NM-8 5-050 12/8 5 Follow-up audits including verification NM-8 6-012 4/8 6 of actions resultant from Meteorological Program audit including interface responsibilities.

2. THE ROOT CAUSE OF THE VIOLATION WAS PERSONNEL ERROR.

The audit team leader failed to adequately scope the Radiation Protection Services Audit to include evaluation of the Meteorological Program, as required by the Master Audit Plan. In addi'tion, supervisory review of the developed Audit Plan was inadequate in that it failed to id~ntify the pmission.

3. IMMEDIATE CO~CTIVE ACTIONS Subsequent to identification of the omitted area a audit was conducted of the contractor and effective program implementation was verified.

4. ACTION TAKEN TO PREVENT RECURRENCE A review of the Audit Program has shown that the identified omission of the Meteorological Program contractor activities was an isolated occurrence. The omission has been discussed with the individual audit team leader and supervisor and their individual responsibilities were reinforced. Similar reinforcement of required program implementation has been accomplished with all audit personnel.

5. WE ARE IN FULL COMPLIANCE.