ML18081A427

Responds to NRC 790829 Ltr Re Violations Noted in IE Insp Rept 50-272/79-07.Corrective Actions:Qa Supervisor Will Closely Review Audit Schedule & Take Necessary Steps to Insure That Audits Are Completed in Timely Manner

ML18081A427
Person / Time
Site:	Salem
Issue date:	09/20/1979
From:	Schneider F Public Service Enterprise Group
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18081A426	List: ML18081A427
References
NUDOCS 7910290093
Download: ML18081A427 (3)

Text

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k W. Schneider Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373

• ~sident Production September 20, 1979

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Mr. Boyce H. Grier Director of USNRC Off ice of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Grier:

NRC INSPECTION 50-272/79-07 INSPECTION DATE FEBRUARY 6-9, 1979 SALEM NO. 1 UNIT .

We have reviewed the report of your investigation conducted on February 6-9, 1979, which was transmitted with your letter of August 29, 1979 and received on September 4, 1979. Our response

• to the items of noncompliance in Appendix A of your Investigation Report is as follows:

Reply to deficiency in NRC Inspection *s0-272/79-07, Appendix A, Item A:

10 CFR 50, Appendix B, Criterion XVIII, Audits, states "A comprehensive system of planned and periodic auditp shall be carried out to verify compliance with all aspects of the quality assurance program and to de-termine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or check lists by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by the management having responsibility in the area audited. Followup action, including r~audit of deficient areas, shall be taken where indicated."

The station's administrative procedure AP-17, Operational Quality Ass~rda~ce Pr~gra~, which implem~nhts t~e system of planned and h ~

perio ic audits in accordance wit written procedures stated t e following in the specified paragraphs:

18.6.2 "Applicable elements of the Audit Subjects (in the) quality assurance program shall be audited at least annually or at least once within the life of the activity, whichever is shorter. 11

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Boyce H. 9rier* 9-20-79 18.7.2 "Frequency of Scheduled Audits Organizations responsible for the operation, maintenance, con-trol or administration of the Salem Station shall be subject to audit under this program not less frequently.than that shown in Reference 2.19."

Ref. 219 Audit Schedule of AP-11-stated-ima-~t-he-Statton

~~~~~~~~~~Quarity Assurance *csQAE) establishes and maintains audit schedules implemented by OQI-5.

OQI-5, Revision 2, "Audits," states in Section 4.0, "The audit period used at the station is from August of each year to July of the following year. Audits are scheduled by the SQAE to be accomplished during this audit period. As required during the audit period special audits may be assigned, or the scheduled audit may be shifted on the schedule to be accomplished at another time during the audit period .*. " the target of completion of audits is generally 60 days from the time of initiation."

Contrary to this requirement, the periodic audit "Radiation Safety and Chemistry," audit subject "N-1," was not carried out and performed in accordance with the written procedures estab-lished, in that the audit is scheduled to be performed at least once per year, but was not performed between April 28, 1977 and February 9, 1979, the time of this inspection .

• The following corrective action has been initiated:

1. The cause of the deficiency was an oversight on the part of the Station QA Supervisor. The assumption was made by the supervisor that the audit was going to be completed on schedule. When the audit was not com-pleted, the supervisor did not take the proper cor-rective action.

2. To correct the situation, the audit has been resched-uled to be performed during August 1979, and again in August 1980. The anticipated date for completion of the current audit is September 21, 1979.

3. To prevent future items of noncompliance, the QA Super-visor will closely review the audit schedule and take the necessary steps to ensure that audits are completed in a timely manner.

4. We are in compliance now. The Radiation Safety and Chemistry Audit will be completed by September 21, 1979.

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Bcryce*H. Gr.ier 9-20-79 Reply to deficiency in NRC Inspection 50-272/79-07, Appendix A, Item B:

10 CFR 71. 3, "Requirement for license," states, "No licensee subject to the regulations in this part shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed ma+/-erial-exG:eJ?>t--as:--------~

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a-u-t--h0r+/-z-ed-i-n-a generarTicense or specific license issued by the Commission or as exempted in this part."

Contrary to this requirement, licensed materials were delivered to a carrier for transport without authori-zation by a general license or specifi~ license issued by the Commission; or without being exempted from this part, on December 13, 1978.

The following corrective action has been initiated:

1. The cause of the deficiency was an error in inter.pre...;

tation of 10CFR71.12 (b); "Radioactive Shipment".

Refueling Instruction OI I-2. 7. 6, 'iNew Fuel Transfer and Shipment", was written to comply with the require-ments of 10CFR71.12 and to provide instructions for the handling of fuel assel'!lblies during preparation for off-si te shipment. * *

2. To correct the situation, a permanent change (P-1) was written for OI I-2.7.6 to add a requirement to. verify the proper notification has been made and the document required is available prior to off-site shipment.

3. To prevent items of noncompliance, supervisors con-cerned with radioactive shipments will close].y super-vise the evolution and ensure adherence to the revised OI I-2.7.6.

4. We are in compliance now.

If you require additional information, we will be pleased to dis-cuss it with you.

GC Diredtor, Office of Inspection and Enforcement USNRC Washington, DC 20555