January 28, 2004
Mr.
E. J. Ferland
Chairman,
President and Chief Executive Officer
Public
Service Enterprise Group
80
Park Plaza
P.O.
Box 570
Newark,
New Jersey 07101
SUBJECT:
WORK ENVIRONMENT FOR RAISING AND ADDRESSING SAFETY CONCERNS AT THE SALEM
AND HOPE CREEK GENERATING STATIONS
Dear
Mr. Ferland:
In
late 2003, we initiated a special review at the Hope Creek and Salem Generating
Stations to assess the environment for raising and addressing safety issues.
This letter provides interim results of that ongoing review. We
undertook the review in light of information received in various allegations and
inspections over the past few years. Previous inspections
included both baseline and special inspections following up on plant events.
While to this point, we have not identified any serious safety
violations, collectively, information gathered has led to concerns about the
stations’ work environment, particularly as it relates to the handling of
emergent equipment issues and associated operational decision making.
Concerns regarding the stations’ ability to effectively address
potential safety issues have been documented in inspection reports and periodic
assessment letters. For example, a substantive cross cutting
issue was identified in the problem identification and resolution area in both
the last annual and mid-cycle performance review letters dated March 3 and
August 27, 2003, respectively.
The
ongoing special review has included in-depth interviews of numerous current and
former Salem/Hope Creek employees, at various levels of the organization.
Our interviews have sought to understand the extent to which a safety
conscious work environment exists at the stations. Our review
has accumulated information about a number of events which, to varying degrees,
call into question the openness of management to concerns and alternative views,
strength of communications, and effectiveness of the stations’ corrective
action and feedback processes. Several events involved
disagreements or differing perspectives of operators and senior managers on
plant operating decisions, particularly as they might impact on continuing plant
operation and outage schedules. At a minimum, interviews to
date at Hope Creek and Salem have raised questions about whether management has
fully assessed and addressed the negative impact such disagreements have had on
station personnel.
Our
reviews are not yet complete but we consider it important to provide our
perspective at this time on what we have found and to request that you
initiate your own review. If left unresolved, negative
outfall from events relayed to us can create an unacceptable, chilled
environment for raising issues and making appropriate operational decisions.
We recognize that virtually all plants, including those with strong
safety performance, operate with aggressive schedules. Schedule
pressure does not, by itself, lead to safety concerns. However,
we consider it important for you to take action to thoroughly understand what
“messages” the staffs at Salem and Hope Creek have taken from various
events over the past few years and address any situations that significantly
detract from maintenance of a strong safety conscious work environment.
We
understand steps have been taken to realign management responsibilities in an
attempt to better support the separate activities of Hope Creek and Salem and
to improve implementation of your corrective action program, overall.
While some interviewees have indicated that these steps may be leading
to some change under new management, it is vital to assess the climate at the
station, address the current impact of previous unresolved conflict, and take
steps to assure the staffs at Salem and Hope Creek are willing to participate.
In
summary, we request that you conduct your own in-depth assessment.
Previous surveys conducted or directed by PSEG might form part of such
an assessment. We ask that you provide your plan of action
for addressing this matter to the NRC within 30 days of the date of this
letter. Approximately two weeks after we receive your
action plan, we would like to meet with you to discuss this matter in more
detail, so that we may plan for appropriate NRC monitoring and follow up.
In
accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a
copy of this letter and your response will be made available electronically
for public inspection in the NRC Public Document Room or from the NRC’s
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
To the extent possible, your response should not include any personal
privacy, proprietary, or safeguards information so that it can be made
available to the Public without redaction. If personal
privacy information is necessary to provide an acceptable response, then
please provide a bracketed copy of your response that identifies the personal
privacy-related information and a redacted copy of your response that deletes
the personal privacy-related information. Identify the
particular portions of the response in question which, if disclosed, would
create an unwarranted invasion of personal privacy, identify the individual
whose privacy would be invaded in each instance, describe the nature of the
privacy invasion, and indicate why, considering the public interest in the
matter, the invasion of privacy is unwarranted. If you
request withholding on any other grounds, you must specifically
identify the portions of your response that you seek to have withheld and
provide in detail the bases for your claim of withholding (e.g., provide the
information required by 10 CFR 2.790(b) to support a request for withholding
confidential commercial or financial information). If
safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
Sincerely,
Hubert
J. Miller
Regional Administrator