ML052630222

NRC Oversight Status of Salem & Hope Creek Work Environment and Corrective Action Effectiveness Presentation

ML052630222
Person / Time
Site:	Salem, Hope Creek
Issue date:	06/29/2004
From:	NRC Region 1
To:
References
FOIA/PA-2004-0314
Download: ML052630222 (14)

Text

C

(

C NRC Oversight Status of Salem & Hope Creek Work Environment and Corrective Action Effectiveness June 29, 2004 N

If;-

- I-D 1

HISTORY Extended SID and Watch List i Late 1990's Recovery Satisfactory but Performance Improvements Stalled in Early 2000's

• Poorly-conceived realignment to "3-Unit Site"

• stretched mgt thin and created confusion, especially in engineering

• Equipment Reliability/Outages/Events stressed the organization

• Corrective Action issues and Work Management ineffectiveness evident

• ORG Changes and Management Turnover

(

(

c PSEG PERFORMANCE AND NRC OVERSIGHT 2000-2003

• All three units have stayed in Licensee Response or Regulatory Response columns --a number of White indicators or findings, numerous other findings

• Strong crosscutting theme, PIR, highlighted in three Assessment letters; continues today

• Numerous findings involving PIR

> Involved S/HC EDGs, S/HC SW, S/HC grid UV protection, Salem water hammers, air systems, HC CRDMs, leaks, MOV's

• Also lots of issues in BOP 3

PSEG PERFORMANCE AND NRC OVERSIGHT 2000-2003 (cont.)

Increased NRC management attention and site visits RAvisits: 4/01, 10/01, 7/02, 4/03, 7/03, 12/03, 3/04, 5/04

> Maintained separate inspection programs for Salem and Hope Creek (2 SRls)

Special inspections (e.g., partial LOOP, fuel pool leak with Tritium migration, EDG turbo charger failure)

• Late 2003: Initiated Special Review based on crosscutting themes, events, and allegations

> Disciplined, structured approach through allegation process - panels led by Region I DRP Director 4

(

(

(l NRC OVERSIGHT 2004 January 28: Interim Results of Special Review

• NRC concerns related to work environment and station capacity for:

• Handling emergent issues and associated operational decision-making

• Addressing potential safety issues

• These concerns included:

• Openness of management to concerns and alternate views

• Strength of communication

• Effectiveness of corrective actions and feedback processes

• Concerns did not involve any serious safety violations

• Recognized some change under new management but need to understand and address lingering issues

• NRC Requested PSEG to do their own Assessment 5

(

NRC OVERSIGHT 2004 (cont.)

(

W-M 7~~

=,

I-~

• NRC Letter to PSEG 1/28/04

• PSEG Letter to NRC

• Provided interim assessment plant 2/27/04

• Public Meeting

• Discussed assessment plans 3/18/04

• PSEG Letter to NRC

• Submitted assessment results 5/21/04 w NRC Public Meeting

• Discussed PSEG assessment results and action plan 6/16/04

• PSEG Commitment letter

• Documented action plans in summary form 6/25/04 6

C(

C PSEG ASSESSMENTS SUBMITTED 5/21/04

• Synergy Cultural Assessment (Dec. 2003)

• USA Group Safety Culture Assessment (Mar. 2003)--DBLL SOER Review

• Independent Review by IAT (Feb.- May 2004)--interviews and overall review, included corporate

> Results consistent with NRC inspections, assessments and special review

> Very detailed results (- 200 pages docketed)

> Includes stark, unvarnished verbiage

> None found major safety issues but overall implications are negative about "organizational effectiveness" and SCWE 7

(

(

(

EXTERNAL STAKEHOLDER PERSPECTIVES

• Key Alleger -- revealed alleger status publicly in March; has ongoing civil suit against PSEG. Very frequent contact with NRC Region 1. Alleger contends that extensive "records" and views of numerous station staff provide "irrefutable evidence" that corporate-driven production pressure has overshadowed safety; and plant should be shut down to fix equipment and other plant problems.

• UCS -- Increasing involvement over past several months -

advocates plant S/D, Order, or CAL. Considers problems to be the same as during extended shut down and watch list during 1990's.

• Unplug Salem -- small group consistently advocates S/D

• New Jersey -- very interested; supportive of NRC

• Congressional -- interest, but little direct involvement so far

• Financial -- recent strong interest including mtg attendance

• Media -- mostly local 8

PSEG ACTION PLANS

• PSEG letter recently submitted, summarizes plans. Licensee initiatives involve, in large measure, better execution of standard industry processes that PSEG has been trying to implement for several years.

• PSEG focus areas: SCWE, CAP, Work Management, Leadership Effectiveness, Facilities (detailed plans ECD July 31, 2004)

• PSEG intends to pursue action plans thru Business Plan

• Recent emphasis: conservative decisions and communications. Expanded outage scope to fix more equipment.

• Commitments:

• Submit Key metrics (SCWE and SCWE drivers)

• SCWE and Safety Culture Survey after the HC outage, submit and meet with NRC early 2005

• Survey for five years

• Assessment of effectiveness to be part of normal line management processes

(

(

c REGULATORY OVERSIGHT --

PRINCIPLES

• Provide appropriate safety perspective and attention

• Understand that these issues will take some time to address.

Recognize that things could get worse before improving

• Need to assure PSEG has long term focus

• Look for effectiveness of efforts vs. merely completing action items

• Capture commitments and performance measures while avoiding "over-constraining" licensee processes.

• Recognize that metrics can be helpful but cannot become the sole measure of effectiveness 10

REGULATORY OVERSIGHT --

PRINCIPLES (cont.)

• Recognize that "organization effectiveness" and equipment reliability problems are principal drivers of "soft" communications/SCWE issues

• Avoid open-ended process - have a clear exit strategy

• Needn't satisfy all stakeholders, but NRC action should be logical and be clearly explained within context of ROP and other processes (SCWE policy and allegation process) 11

(

(C'.(

REGULATORY OPTIONS ADDITIONAL PSEG COMMITMENT Considering the need for additional PSEG commitments in several areas:

• Metrics submittal -- better coverage of equipment issues.

• Management meetings -- one this Fall, semiannually thereafter

• Additional effectiveness review -- without undercutting licensee management line processes, obtain agreement to repeat third-party assessment (e.g., USA review) covering more than work environment 12

C C,

cl REGULATORY OPTIONS --

MONITORING AND FOLLOW UP

• Continued overall strong inspection effort

• Maintain resident staffing Thorough special/supplemental inspections as needed Management site visits

• Complete the allegations and investigations in progress

• Some combination of some of the following:

• Site Visits (some with HQ assist)

> Review PSEG assessment in more detail (probably not needed)

• Review PSEG approach and method for future assessments (with HQ assist or lead)

• Focused Inspection follow up of selected actions (with HQ assist)

> Periodic management meetings (how often?)

SCWE x-cut in mid-cycle assessment (probably)

. Deviation Memo (likely)

Oversight panel - to coordinate HQ and RI activities

• Remove site from ROP due to corrective action weaknesses? (Not needed) 14

C C

C )

4 REGULATORY OPTIONS -

REGULATORY "FOOTPRINT" I " M
T-
-M--"' -M,

77-7!1 m Order

• CAL

• Letter Accepting Commitments

• Possibly to include Oversight Panel and Deviation Memo 15