ML18086A761

Responds to NRC 810212 Ltr Re Violations Noted in IE Insp Rept 50-272/80-31.Corrective Actions:Operating Instructions Revised.Lead Engineer Will Publish New Index/List of Effective Revisions After Each Addition

ML18086A761
Person / Time
Site:	Salem
Issue date:	03/09/1981
From:	Schneider F Public Service Enterprise Group
To:	Brunner E, Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18086A760	List: ML18086A761
References
NUDOCS 8107080041
Download: ML18086A761 (6)

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- ; o k W. Sohne;d., Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Vice President Production March 9, 1981 Mr. Boyce H. Grier, Director Off ice of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa. 19406 Attention: Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Gentlemen:

. NRC INSPECTION 50-272/80-31 SALEM GENERATING STATION UNIT NO. 1 We have reviewed the report of your inspe~tion conducted by Dr. Jin W. Chung during the period November 17-21, 1980.

Our response to the item of noncompliance identified in Appendix A is as follows:

Item of Violation Technical Specification 6.8 addresses the requirements of plant procedures in that paragraph 6.8.l states in part, "Written procedures shall be established, implemented and maintained covering the activities referenced below: a. The applicable procedures recommended in Appendix 'A' of Regulatory Guide 1.33,

'Revision 2, February 1978 ... "; paragraph 6.8.2 states in part:

"Each procedure ... of 6.8.l above ... shall be reviewed by the SORC .** prior to implementation and reviewed periodically as set forth in administrative procedures." and, paragraph 6.8.3 states in part: " .*. The change is documented, reviewed by SORC ..* within fourteen days of implementation." Administrative Control Pro-cedure AP-3, 'Station Documents', Revision 9, requires that the station procedures be reviewed at least every two years.

Contrary to the above, station procedures and changes thereto, were either improperly implemented or not reviewed in the following instances:

Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission 3/9/81 Item Of Violation Part (a)

Procedures in the Control Room Master Files listed below, had not been reviewed during the last two year review cycle:

OI II-1.3.1, Revision 3, May 3, 1977 QI II-3.3.3, Revision 8, May 12, 1978 OI II-11.3.3, Revision 3, June 2, 1977 OI II-15.3.2, Revision 2, March 8, 1978 lPD-2.9.001, Revision 0, October 27, 1976 ReplX to Item Of Violation Part (a)

1. Operating Instruction II-1.3.1, Revision 3, May 3, 1977, has been revised twice since this revision. The current revision is Revision 5, December 17, 1979, which is within the two year review cycle.

2. Operating Instructions II-3.3.3, Revision 8, II-11.3.3, Revision 3, and II-15.3.2, Revision 2 have not been reviewed in the required two year cycle. All Operating Instructions are being revised to incorporate all of the on-the-spot changes and outlined* in a new format. .The Lead Engineer has been designated responsible for ensuring that procedure reviews and revisions are completed in the required two year cycle.

The addition of personnel to the staff has been done in order to expedite the revision process. All revisions should be completed by June 1, 1981.

3. lPD-2.9.001, Revision O, was not reviewed within the two year cycle due to personnel error. The Performance Department is currently revising their program to include provisions f9r a systematic review process, scheduling and computer program. The procedure noted has been reviewed. We are in compliance now.

Item of Violation Part (b)

The Index/List of Effective Revisions, Station Manual Books 2 and 4, in the Control Room Master Copies was not up to date and did not reflect the corresponding revision numbers and dates of the procedures in the Control Room Files as required by Administrative Procedure AP-1, Paragraph 5.6, Index and List of Effective Pages .

.. * *fl.

Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission 3/9/81 Reply To Item Of Violation Part (b)

The personnel responsible for placing the Operating Instruction revision in the Control Room Master Copies were not aware of the requirements of the Station Plant Manual, Volume I, Section 1, General Information. The Lead Engineer will publish a new Index/List of Effective Revisions each time a revision is made to the Operating Instructions. The Index should be completed by June 1, 1981.

NOTE AP-1 is only for the Administrative Procedure Program.

Item Of Violation Part (c)

The following procedure revision numbers and dates in the Control Room Master Files were pencil-changed without any objective evidence of review or corresponding references to SORC review as required by Administrative Procedure AP-3, Section 6.0, Control of Station Materials:

OI II-1,3.1: Revision 3, May 3, 1977 in the procedure was deleted and Revision 4 was entered by pencil.

OI II-3.3.2: Revision 7, February 18, 1977 was deleted and Revision 8 was entered by pencil.

Reply To Item Of Violation Part (c)

The Index/List of Effective Revisions was pencil changed to reflect the current revision number. The Index/List of Effective Revisions is not required to have the SORC review meeting number. This is on the last page of each Operating Instruction.

1. OI II-1.3.1, Revision 5, is the current revision, which was reviewed by SORC on December 17, 1979.

2. OI II-3.3.2, Revision 8, is the current revision, which was reviewed by SORC on June 19, 1978.

A new Index/List of Effective Revisions will be issued with each new revision to the Operating Instructions.

Item Of Violation Part (d)

The following "on-the-spot" permanent changes to procedures were not reviewed by SORC within fourteen days of their implementation.

Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission . 3/9/81 OI II-3.3.1, Permanent Change (P-3), May 3, 1979; P-4, May 10, 1979; P-5, May 11, 1979 OI IV-16.3.1, P-6, September 6, 1980 OI V-1.3.1, P-7, April 29, 1979, was reviewed on November 13, 1979 by SORC Reply To Item Of Violation Part (d)

In accordance with the Station Plant Manual, Volume I, Section 1, "General Information", the green copies of permanent "on-the-spot" changes are maintained in the Control Room. Each permanent "on-the-spot" change listed above has had the proper review by SORC within fourteen days as required. The SORC Secretary retains the original white copies for the record file and for inclusion in the next revision of each Operating Instruction and are available at the site for review.

Item Of Violation Part (e)

Emergency Communication System Operating Instruction IV-12.3.1, Revision 2, July 9, 1980, had not been reviewed by SORC prior to

• implementation. This is a procedure type listed in Regulatory Guide 1.33, Appendix A, Item lm.

Reply To Item Of Violation Part (e)

The Emergency Communication System Operating Instruction was not reviewed by SORC. This was an apparent administrative oversight.

The procedure has been reviewed by SORC. We are in compliance now.

Sincerely, CC Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

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• STATE OF NEW JERSEY COUNTY OF ESSEX SS: COUNTY OF ESSEX FREDERICK W. SCHNEIDER, being duly sworn according to law deposes and says:

I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our response dated March 9, 1981, to Inspection Report 50-272/80-31 are true to the best of my knowledge, information, and belief.

' FREDERICK W. SCHNEIDER Subscribed and sworn to before me r./-, '-. 1

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My Commission expires on (L' C(-. I,,  !~-/.) "--:!

STATE OF NEW JERSEY )

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FREDERICK W. SCHNEIDER, being duly sworn according to law deposes and says:

I am a Vice President of Public Service Electric and Gas Company, and* as such,. I find the matters set forth in our response dated March 9, 1981, to Inspection Report 50~272/80-31 are true to the best of my knowledge, information, and belief.

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~ERICK ~- SCHNEIDER Subscrib~d and sworn to before me this 9'f~ day of }J (~:L*i cA , 1981

/ Notary Public of New Je~sey M;{ Commission expires on dJd. I If<f:-...3