ML062220121
| ML062220121 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 11/12/2004 |
| From: | Vito D Division of Nuclear Materials Safety I |
| To: | |
| References | |
| FOIA/PA-2005-0194 | |
| Download: ML062220121 (8) | |
Text
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- Re: Letters due Aýeger Page 1 DavlJ'V ta.
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To:
- DJa, Date:
-- Fri, Nov 12, 2004 7:44 AM
Subject:
Re: Letters due Alleger
- Kymn, The status letter is attached electronically and will be sent hard copy today. I know that you occasionally have trouble reading our Word Perfect files, so in addition, I have included the text of the letter below. I'm sorry if you feel I have been unresponsive. I have made every effort to move things forward as quickly as I can, but I refuse to provide you (or anyone else) with a rushed and/or inferior product. I have provided constant reminders to those who are processing your remaining issues, to the best of my ability. Just as a reminder, with regard to NRC performance, you always have the right to lodge a complaint with the NRC Office of the Inspector General (OIG) 800-233-3497.
Dave V.
November 12, 2004 RI-2003-A-0110
Subject:
Concerns You Raised to the NRC Regarding Continuing Problems with the Safety Conscious Work Environment (SCWE) at the Salem and Hope Creek Stations
Dear Dr. Harvin:
After the low pressure steam line rupture event at Hope Creek on October 10, 2004, you contacted NRC Region I personnel (Mr. A. R. Blough on October 12, 13, and 14, 2004 via e-mail and E. Cobey on October 14 and 19, 2004, via e-mail and on October 19, 2004, via facsimile) with comments/concerns about the actions by Hope Creek management and staff in response to the event. In general, from information you have received, you feel that PSEG has not improved its SCWE. You indicated that workers have told you they no longer feel that the plant is being operated safely. Comments have been made that, while the approach to managing the facility has changed for the better for some managers, many managers are continuing "business as usual."
With regard to the Hope Creek event itself, you noted that you have been informed that management is "minimizing the seriousness" of the event, and trying to restart the plant quickly. You asked that the NRC inte private setting. You also referred the NRC to a Notification written by the
.n the aftermath of the Hope Creek event, which questions PSEG mantigement's response to the event and the knowledge level of the control room operators who responded to the event, indicates that problems reflective of continuing reorganization at the site and ineffective change management persist, and asserts that an unsafe working environment still exists. You also indicated that you were informed that a Notification written weeks earlier which may have provided some insight about the Hope Creek event prior to its occurrence was ignored by management.
With regard to the NRC follow up of the Hope Creek event, as you are aware, an NRC Special Inspection Team (SIT) was established and dispatched to the site. The SIT is focusing on evaluating PSEG's analysis of the cause(s) for the pipe failure, evaluating the equipment and human performance issues that complicated the response to the steam leak and assessing the adequacy of PSEG's root cause evaluation and associated corrective actions. The SIT review includes an assessment of Notifications related to the event, including those you have mentioned, and PSEG's plans for corrective action. The SIT review also includes interviews with pertinent personnel.
Information in this record was deleted in accordance witkthe Freedom of Informolk Act, exemptions FOIA--
I bavid'Vito'- Re: Letters due Alleger CERTIFIED MAIL RETURN RECEIPT REQUESTEDYou are also aware that PSEG does not plan to return Hope Creek to service until after the refueling outage that was originally scheduled to commence at the end of October 2004. PSEG has committed to determine the cause of the pipe rupture, to evaluate the extent-of-condition, to make repairs, to assess operator and equipment performance, and to take any identified corrective actions prior to plant restart. The NRC was notified on October 17, 2004 of PSEG's decision to wait until after the refueling outage to restart the plant.
You also asked Mr. Blough to compare the event at Hope Creek with a similar event that occurred two months ago in Japan. Both events involved steam leaks in the turbine building of the plant. However, while the Japanese event caused several deaths and serious injuries, no one was injured as a result of the Hope Creek event. The Mihama plant in Japan is a pressurized water reactor, similar in design to the Salem plants, although somewhat smaller in size. Hope Creek is a large boiling water reactor. The Mihama pipe rupture occurred on a very large line (approximately 2 feet in diameter) that held rapidly flowing, 380 degree F water, under considerable pressure (> 200 psig). When the Mihama pipe ruptured, a very large amount of water flashed to steam and affected a wide area of the turbine building. The rupture at Hope Creek occurred on a considerably smaller line (8 inches in diameter) that contained predominantly steam at very low pressure. Also, the area where the Hope Creek rupture occurred was unoccupied and is an area that is not typically accessed during plant operation. It is too soon to tell whether the pipe ruptures were caused by the same problem. Such comparisons cannot be made until the Hope Creek event has been thoroughly evaluated.
Regarding your comments about continuing problems with the SCWE at Salem and Hope Creek, in our previous letter to you dated July 30, 2004, we informed you of NRC's conclusions regarding our assessment of the SCWE at Salem and Hope Creek. At the June 16, 2004, public meeting with PSEG, which you attended, as well as in a letter to the NRC dated June 25, 2004, PSEG described its plans for improving the SCWE at the site. While PSEG's action plans appeared to be sufficient to address the key findings of the various SCWE assessments (NRC, Synergy, USA, IAT), we acknowledged that much work needed to be done to implement the action plan in a manner that will affect sustainable improvements to the SCWE at Salem and Hope Creek. We informed you that it was our expectation that PSEG closely monitor the implementation of the action plans, frequently evaluate progress toward achieving intended actions, and adjust its plans and efforts accordingly.
We acknowledge that the aftermath of the Hope Creek event provides PSEG with an opportunity to demonstrate whether progress has been made in the SCWE area. The NRC is closely watching their corrective actions. Salem and Hope Creek are in a period of transition. As you understand, problems in the SCWE area are not often resolved quickly, and progress can be difficult to discern, particularly in the initial stages of recovery. From the NRC's previous experience with other facilities with similar problems, in the early recovery period, it is not uncommon for there to be continuing issues in the SCWE area, and some continued skepticism from staff about progress. We acknowledge your comments and will consider them as we monitor PSEG's performance and their efforts to improve the SCWE at Salem and Hope Creek.
You informed the NRC that some employees may feel harassed and intimidated as a result of PSEG management's actions in response to the Hope Creek event. Since it is our preference that an assertion of discrimination for raising safety issues be provided to the NRC directly bythe affected individual (i.e., not second hand), we ask that you inform these individuals that they may contact the NRC Allegation staff at the toll free telephone number noted below, if it is their preference to submit a discrimination concern.
Additionally, you asked Mr. Cobey several questions about previous activities related to the Hope Creek high pressure coolant injection (HPCI) system, and whether the recent Hope Creek event may have been caused by ineffective corrective actions. Specifically, you asked:
Was thorough post-maintenance testing done on HPCI after the orifice change, and the setpoint data change in the procedure?
Was a 10 CFR 50.59 evaluation completed?
,I D6vid'Vito, - Re: Letters due Alleger Page 3 1 If all this (work) was done while the plant was in the Technical Specification Limiting Condition for Operation action statement which was exited on July 29, 2004, why would HPCI not operate as designed (during the Hope Creek event)?
If all this (work) was not done, has HPCI been operational since July 29, 2004?
In response to your questions, we note that PSEG modified the HPCI injection line to achieve the required design flow at design pressure. The design change process which implemented this modification included a 10 CFR 50.59 screening and evaluation. After the modification was completed, PSEG performed testing and engineering analysis to demonstrate HPCI operability. The NRC Safety System Design Inspection (SSDI), that was onsite at that time, reviewed the actions completed by PSEG and found them to be acceptable.
Thank you for providing this additional information to the NRC. Our review of your concerns regarding potential discriminatory action against you for raising safety issues, and possible wrongdoing by PSEG management continue.
If I can be of further assistance at this time, please call me via the NRC Safety Hotline at 1-800-695-7403.
Sincerely,
[Original Signed by]
David J. Vito Senior Allegation Coordinator 11/1104 04:36PM >>>
- Dave, Tomorrow will be one more week that has gone by that I have not received the letter that was promised three weeks ago regarding HPCI problems at Hope Creek. I know you gave Gene a draft last Friday and he gave you comments. Can't it be finalized?
Please send it tomorrow at the latest.
I am disappointed and quite concerned about how long everything is taking.
This time lapse in no way honors allegers and the courage that it takes to come forward. Frankly, this is quite demoralizing.
While I appreciate your, Randy's and Gene's willingness to take my phone calls and emails, "official responses" are still owed in a timely manner.
Speaking of that, is there any word on my discrimination allegation? Has O0 delivered its report yet to region management? When Eileen Neff resigned early this year, Ernie Wilson told Dave Lochbaum my case was being given to the top investigator and had TOP priority.
How could it now be November and I have been told virtually nothing?
As you know, I have firmly supported the NRC in its investigations at Salem/Hope Creek. And at great personal cost, I have-for well over a year now--continued to supply timely information to the NRC about safety and work environment issues at the site, especially when current employees are still fear retaliation. I have even defended the NRC when others have attacked it.
Re:
a ito*-.Re: Letters.due Afleger.
Page 4 I find the lack of timeliness of official responses to nuclear safety and discrimination allegations to be not only exasperating but favoring the utility over the alleger. This is unfair and inconsistent with the NRC's mission and policies. My faith in the NRC is eroding.
Please bring the gap.
Nancy Kymn Harvin, Ph.D.
LEA 0RTH FOLLOWING CC:
A. Randolph Blough; Eugene Cobey
. [ David Vito'- 206ý01 1 0ST3a.WPD Page 1
[d...
20 3 1 S~......PD.
Page 1i November 12, 2004 RI-2003-A-0110
Subject:
Concerns You Raised to the NRC Regarding Continuing Problems with the Safety Conscious Work Environment (SCWE) at the Salem and Hope Creek Stations
Dear Dr. Harvin:
After the low pressure steam line rupture event at Hope Creek on October 10, 2004, you contacted NRC Region I personnel (Mr. A. R. Blough on October 12, 13, and 14, 2004 via e-mail and E. Cobey on October 14 and 19, 2004, via e-mail and on October 19, 2004, via facsimile) with comments/concerns about the actions by Hope Creek management and staff in response to the event. In general, from information you have received, you feel that PSEG has not improved its SCWE. You indicated that workers have told you they no longer feel that the plant is being operated safely. Comments have been made that, while the approach to managing the facility has changed for the better for some managers, many managers are continuing "business as usual."
With regard to the Hope Creek event itself, you noted that you have been informed that management is "minimizing the seriousness" of the event, and trying to restart the plant quickly.
You asked that the NRC interview all "relevant p*ou also referred the NRC to a Notification written by they~he aftermath of the Hope Creek event, which questions PSE( management's response toe event and the knowledge level of the control room operators who responded to the event, indicates that problems reflective of continuing reorganization at the site and ineffective change management persist, and asserts that an unsafe working environment still exists. You also indicated that you were informed that a Notification written weeks earlier which may have provided some insight about the Hope Creek event prior to its occurrence was ignored by management.
With regard to the NRC follow up of the Hope Creek event, as you are aware, an NRC Special Inspection Team (SIT) was established and dispatched to the site. The SIT is focusing on evaluating PSEG's analysis of the cause(s) for the pipe failure, evaluating the equipment and human performance issues that complicated the response to the steam leak and assessing the adequacy of PSEG's root cause evaluation and associated corrective actions. The SIT review includes an assessment of Notifications related to the event, including those you have mentioned, and PSEG's plans for corrective action. The SIT review also includes interviews with pertinent personnel.
CERTIFIED MAIL RETURN RECEIPT REQUESTED
. I David Vitýr-200301 IOST3a.WPD Page 2 1 David Vito~- 200301 1OST3a.WPD Page 2 I
N. Kymn Harvin, Ph.D.
2 RI-2003-A-0110 You are also aware that PSEG does noit plan to return Hope Creek to service until after the refueling outage that was originally scheduled to commence at the end of October 2004. PSEG has committed to determine the cause of the pipe rupture, to evaluate the extent-of-condition, to make repairs, to assess operator and equipment performance, and to take any identified corrective actions prior to plant restart. The NRC was notified on October 17, 2004 of PSEG's decision to wait until after the refueling outage to restart the plant.
You also asked Mr. Blough to compare the event at Hope Creek with a similar event that occurred two months ago in Japan. Both events involved steam leaks in the turbine building of the plant. However, while the Japanese event caused several deaths and serious injuries, no one was injured as a result of the Hope Creek event. The Mihama plant in Japan is a pressurized water reactor, similar in design to the Salem plants, although somewhat smaller in size. Hope Creek is a large boiling water reactor. The Mihama pipe rupture occurred on a very large line (approximately 2 feet in diameter) that held rapidly flowing, 380 degree F water, under considerable pressure (> 200 psig). When the Mihama pipe ruptured, a very large amount of water flashed to steam and affected a wide area of the turbine building. The rupture at Hope Creek occurred on a considerably smaller line (8 inches in diameter) that contained predominantly steam at very low pressure. Also, the area where the Hope Creek rupture occurred was unoccupied and is an area that is not typically accessed during plant operation. It is too soon to tell whether the pipe ruptures were caused by the same problem. Such comparisons cannot be made until the Hope Creek event has been thoroughly evaluated.
Regarding your comments about continuing problems with the SCWE at Salem and Hope Creek, in our previous letter to you dated July 30, 2004, we informed you of NRC's conclusions regarding our assessment of the SCWE at Salem and Hope Creek. At the June 16, 2004, public meeting with PSEG, which you attended, as well as in a letter to the NRC dated June 25, 2004, PSEG described its plans for improving the SCWE at the site. While PSEG's action plans appeared to be sufficient to address the key findings of the various SCWE assessments (NRC, Synergy, USA, IAT), we acknowledged that much work needed to be done to implement the action plan in a manner that will affect sustainable improvements to the SCWE at Salem and Hope Creek. We informed you that it was our expectation that PSEG closely monitor the implementation of the action plans, frequently evaluate progress toward achieving intended actions, and adjust its plans and efforts accordingly.
We acknowledge that the aftermath of the Hope Creek event provides PSEG with an opportunity to demonstrate whether progress has been made in the SCWE area. The NRC is closely watching their corrective actions. Salem and Hope Creek are in a period of transition.
As you understand, problems in the SCWE area are not often resolved quickly, and progress can be difficult to discern, particularly in the initial stages of recovery. From the NRC's previous experience with other facilities with similar problems, in the early recovery period, it is not uncommon for there to be continuing issues in the SCWE area, and some continued skepticism from staff about progress. We acknowledge your comments and will consider them as we monitor PSEG's performance and their efforts to improve the SCWE at Salem and Hope Creek.
You informed the NRC that some employees may feel harassed and intimidated as a result of PSEG management's actions in response to the Hope Creek event. Since it is our preference that an assertion of discrimination for raising safety issues be provided to the NRC directly by
yDaid Vi!o-2003011 OST3a. WPD..
Page3 N. Kymn Harvin, Ph.D.
3 RI-2003-A-0110 the affected individual (i.e., not second hand), we ask that you inform these individuals that they may contact the NRC Allegation staff at the toll free telephone number noted below, if it is their preference to submit a discrimination concern.
Additionally, you asked Mr. Cobey several questions about previous activities related to the Hope Creek high pressure coolant injection (HPCI) system, and whether the recent Hope Creek event may have been caused by ineffective corrective actions. Specifically, you asked:
Was thorough post-maintenance testing done on HPCI after the orifice change, and the setpoint data change in the procedure?
Was a 10 CFR 50.59 evaluation completed?
If all this (work) was done while the plant was in the Technical Specification Limiting Condition for Operation action statement which was exited on July 29, 2004, why would HPCI not operate as designed (during the Hope Creek event)?
If all this (work) was not done, has HPCI been operational since July 29, 2004?
In response to your questions, we note that PSEG modified the HPCI injection line to achieve the required design flow at design pressure. The design change process which implemented this modification included a 10 CFR 50.59 screening and evaluation. After the modification was completed, PSEG performed testing and engineering analysis to demonstrate HPCI operability.
The NRC Safety System Design Inspection (SSDI), that was onsite at that time, reviewed the actions completed by PSEG and found them to be acceptable.
Thank you for providing this additional information to the NRC. Our review of your concerns regarding potential discriminatory action against you for raising safety issues, and possible wrongdoing by PSEG management continue.
If I can be of further assistance at this time, please call me via the NRC Safety Hotline at 1-800-695-7403.
Sincerely,
[Original Signed by]
David J. Vito Senior Allegation Coordinator
Da'id Vfto'- 2003011 OST3a.wpD Page 4 N. Kymn Harvin, Ph.D.
4 RI-2003-A-0110