|
NUCLEAR REGULATORY COMMISSION
REGION I 475 ALLENDALE ROAD KING OF
PRUSSIA, PENNSYLVANIA 19406-1415 |
September 1, 2004
David
A. Lochbaum
Nuclear
Safety Engineer
Union
of Concerned Scientists
1616
P Street NW Suite 310
Washington,
DC 20036-1495
SUBJECT: QUESTIONS YOU RAISED REGARDING NRC
ACTIONS TO ADDRESS THE SAFETY CULTURE AT THE SALEM AND HOPE CREEK NUCLEAR
GENERATING STATION
Mr.
Lochbaum:
This
letter is in response to your letters dated June 9, 21, and 25, 2004, in which
you suggested U.S. Nuclear Regulatory Commission (NRC) take action to address the
safety culture and performance issues at the Salem and Hope Creek Nuclear
Generating Stations (Stations), up to and including ordering the units
shutdown. You also suggested that if
the NRC decides shutdown of the units is not needed to address these issues, we
should order PSEG to demonstrate tangible improvements in safety culture, and
plant physical condition within an explicit time frame. In your letter dated June 9, you indicated
that the results of third party assessments performed for PSEG and longstanding
corrective action program weaknesses dictated the need for this action. In your letters dated June 21 and 25, you
indicated that the current problems at the Stations are the same as those that
existed in 1995 which resulted in an extended shutdown of the Salem units. In your letter dated June 25, you also
asserted that PSEG=s
presentation during the June 16, 2004, public meeting on work environment at
the Stations was similar to the Salem restart presentation made to the NRC in
December 1995. You requested that the
NRC not treat your letters as petitions under the auspices of 10 CFR Part
2.206, but you preferred a written response from the NRC. This letter is intended to satisfy your
request.
As
you know, late in 2003, the NRC initiated a special review at the Stations to
assess the environment for raising and addressing safety issues. We undertook this review in light of
information received in various allegations and NRC inspections over the past few
years, as well as our annual and mid-year performance reviews in 2003 which
identified a substantive cross-cutting issue in the problem identification and
resolution area. As part of our review,
we conducted in-depth interviews, between October 2003 and June 2004, of over
60 current and former Salem/Hope Creek employees, from various levels of the
organization up to and including nuclear executives. Our review also considered our inspection and assessment record
over the past several years, as well as allegations involving the
Stations. Throughout our review, a
panel of NRC managers, technical staff, program support staff, and
investigators was periodically convened to evaluate the information obtained.
On
January 28, 2004, the NRC Region I issued a letter to PSEG that provided
interim results of our special review.
Our review had accumulated information about a number of events which,
to varying degrees, called into question the PSEG management’s openness to concerns and alternative views, strength of
communications, and effectiveness of the stations= corrective action and feedback processes. Several events had involved disagreements or
differing perspectives of operators and senior PSEG managers regarding plant
operating decisions, particularly as they might impact on continuing plant operation
and outage schedules. At a minimum,
these interviews raised questions about whether management had fully assessed
and addressed the negative impact such disagreements have had on station
personnel.
In
response to our January 28, 2004, letter, PSEG committed to provide significant
financial resources to improve station performance and discussed their plans to
assess the work environment in their February 13, and February 27, 2004,
letters, respectively. In a
March 18, 2004, management meeting, PSEG outlined the methodologies and
provided some preliminary results of three major assessments of the safety
culture and work environment at the station and subsequently communicated the
results in a letter dated May 21, 2004.
These assessments included: (1)
a safety culture survey conducted by Synergy Corporation in December 2003; (2)
a safety culture assessment conducted by the Utility Service Alliance (USA) in
March 2004 to evaluate the Salem and Hope Creek safety culture against
standards of excellence; and (3) an in depth evaluation of the work environment
for raising and addressing safety issues conducted by an Independent Assessment
Team (IAT) between February and April 2004.
This last assessment was in direct response to the interim findings
documented in our January 28, 2004, letter.
The reports of these assessments are available on the NRC Web Site
at www.nrc.gov/reading-rm/adams.html using
accession number ML040610856. The
assessments identified the need for improvement of the work environment and
equipment reliability. These
assessments also identified that better implementation of station processes,
such as corrective actions and work management, were important to achieving
improvements. Subsequently, PSEG
managers discussed their plans to address Safety Conscious Work Environment
(SCWE) issues in a June 16, 2004, management meeting with the NRC staff and in
a letter dated June 25, 2004, in which they indicated the methods they
intended to use to improve the work environment at the station.
On
July 30, 2004, the NRC Region I issued a letter to PSEG that provided the final
results of our review. This in-depth
review confirmed our interim results and generally agreed with the results of
PSEG's self-assessments. Specifically,
we did not identify any serious safety violations; however, we concluded that
there were numerous indications of weaknesses in corrective actions and
management efforts to establish an environment where employees are consistently
willing to raise safety concerns. Some
PSEG staff and managers felt that the company had emphasized production to a
point which negatively impacted the handling of emergent equipment issues and
associated operational decision-making.
Additionally, management had not been consistent in its support of
Station staff identifying concerns and providing alternate views. We found examples of unresolved conflict and
poor communication between management and staff, as well as underlying staff
and management frustration with poor equipment reliability. The equipment issues stemmed, in part, from
weaknesses in implementation of station processes such as work management and
corrective action. The letter also
indicated that the NRC staff was continuing to review certain discrete issues
and events to establish whether violations of regulatory requirements, beyond
those already identified in NRC reports and correspondence, occurred.
The
NRC has taken pro-active steps to engage PSEG before the work environment and
related issues manifest themselves in significant plant events or serious
safety violations. Our activities have
included the conduct of an extensive review of the work environment at the
Stations which included the issuance of a very significant letter to PSEG
articulating interim results of our review and requesting PSEG perform an
in-depth assessment of the issues.
Throughout the last couple of years, the NRC has increased the frequency
of senior management site visits and meetings with PSEG to ensure that the
company has identified the Station=s performance issues and has developed appropriate
improvement plans. In addition to the
oversight provided for by the Reactor Oversight Process, the NRC plans to: 1)
establish an internal NRC coordination team, involving regional and
headquarters experts in reactor oversight, SCWE and related performance
attributes, to coordinate NRC review efforts and assist in evaluation of
licensee self-assessment efforts; 2) review PSEG=s detailed improvement plans to identify SCWE and related
performance attributes for further NRC review; and 3) enhance existing baseline
inspections by adjusting inspection scope, as necessary, to verify the
effectiveness of licensee improvement efforts in these areas. In order to provide this appropriate level
of NRC oversight for Salem and Hope Creek, the NRC's Executive Director for
Operations approved a deviation from the NRC's Action Matrix on August 23, 2004
that authorized the staff to provide a greater level of oversight for the
Stations than would typically be called for by the Regulatory Response Column
of the Action Matrix. The NRC plans to
continue with this heightened oversight until PSEG has concluded that
substantial, sustainable progress has been made; and the NRC has completed a
review, the results of which confirm PSEG=s assessment results.
In
response to your letter, we have evaluated your assertions that the existing
performance issues at the Stations are the same as those that resulted in the
extended shutdown of the Salem units in the mid 1990s. In the years preceding the Salem dual unit
shutdown in 1995, the NRC conducted four augmented inspection teams (AITs) in a
four year period due to station problems, the depth and breadth of which the
NRC considered significant. As a result
of these performance problems, the NRC issued a confirmatory action letter to
PSEG and conducted oversight activities of the Salem units in accordance with
NRC Inspection Manual Chapter 0350, AOversight of Operating Reactor Facilities in an Extended
Shutdown as a Result of Significant Performance Problems.@ This process
provided a structured review of PSEG=s restart activities for the Salem units. Prior to the restart of these units, PSEG
resolved specific technical issues and made substantial programmatic
improvements.
Although
we recognize that the current program implementation issues are in some of the
same general areas as those that resulted in the extended shutdown of the Salem
units, we have concluded that the scope, significance, and impact has been less
than the Stations=
problems exhibited in the mid 1990s.
While we have noted, as has the UCS, that there have been longstanding
weaknesses in PSEG=s
implementation of the corrective actions process, we believe the Stations have
maintained acceptable margins of safety, in that these weaknesses have not
manifested themselves in significant plant events or serious safety violations
at the Stations; and PSEG=s
performance has remained in either the licensee or regulatory response columns
of the NRC Action Matrix for the past several years. Consequently, we have concluded that the actions taken by the NRC
in the mid 1990s (e.g., issuance of a CAL) are not appropriate for the current
conditions at the Stations. We will
continue our ongoing assessment of the Stations= performance and consider the need for additional action, as
necessary.
Thank
you for your analysis and thoughtful commentary on these matters. Your input provides us a valuable and useful
perspective. Should you have any
further questions or concerns related to this issue, please contact Eugene
Cobey of my staff at 610-337-5171.
Sincerely,
/RA/
Samuel J. Collins
Regional Administrator