ML092440309
| ML092440309 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/01/2009 |
| From: | Clifford J Division Reactor Projects I |
| To: | Joyce T Public Service Enterprise Group |
| BURRITT, AL | |
| References | |
| Download: ML092440309 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 September 1, 2009 Mr. Thomas P. Joyce President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P. O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -
SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2
Dear Mr. Joyce:
On August 13, 2009, the NRC staff completed its performance review of Salem Nuclear Generating Station (Salem). Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2008, through June 30, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.
Plant performance for the most recent quarter at Salem Units 1 and 2 was within the Licensee Response column of the NRC=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility.
In our annual assessment letter dated March 4, 2009 (ML090620756)1, we advised you of a substantive cross-cutting issue in the area of human performance with a cross-cutting theme in the aspect of documentation and procedure adequacy (H.2(c))2. We were concerned, at that time, that your actions had not proven effective in substantially mitigating this longstanding cross-cutting theme, as indicated by an increase in the number of findings with the same causal factor. In the annual assessment letter, we stated that the substantive cross-cutting issue would be cleared when PSEG demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that resulted in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same causal factor.
1 Designation in parenthesis refers to an ADAMS accession number. Documents referenced in this letter are publicly available using the accession number in ADAMS.
2 This is a descriptor that correlates to this cross-cutting aspect in Inspection Manual Chapter 0305, Operating Reactor Assessment Program.
T. Joyce 2
During this assessment period, we noted that you completed three common cause analyses, two work group evaluations and a root cause analysis on implementing procedure quality which was completed in June 2009. Appropriate corrective actions were identified to address procedure adequacy that included: revising the administrative process for writing and modifying station procedures; reinforcing management expectations regarding procedure quality with station personnel; improving the process for incorporating operating experience into procedures; and forming a procedure working group to ensure procedure quality. However, we concluded that you did not meet the criteria for clearing the substantive cross-cutting issue because you have not demonstrated that you have achieved sustainable performance improvement that is the result of your effective implementation of a corrective action plan. Specifically, we note that many of the corrective actions that resulted from the cause analyses are still in progress. While we note improvement in this area over the last six months with only one new finding, because many corrective actions have not yet been completed, we continue to evaluate the sustainability of your procedure improvement plans. As such, the NRC will maintain this substantive cross cutting issue open.
We will monitor your progress in this area through the baseline inspection program, including completion of a focused problem identification and resolution inspection sample during the fourth quarter of 2009, in accordance with Inspection Procedure 71152, AIdentification and Resolution of Problems.@ Our review will focus on your integration of corrective action plans from the multiple causal analyses that were completed in response to this issue. We will continue to evaluate the comprehensiveness of your plan including how you will address implementing procedure issues and incorporation of operating experience into procedures. Our review will focus on risk significant procedures including those that will be used during the upcoming refueling outage. The criteria for clearing this substantive crosscutting issue remains as stated in the March 4, 2009 annual assessment letter.
The staff also identified four inspection findings for the current assessment period in the area of human performance with a documented cross-cutting aspect of procedural compliance (H.4(b))2. Each finding in this area involved information-use-only (level 3) procedures that were not required to be with the worker at the work location. The staff had previously identified a substantive cross-cutting issue with a procedural compliance (H.4(b))2 aspect in 2007 that was closed in 2008. Corrective actions taken to address the 2007 issues were comprehensive, timely, and effective in reducing non-compliance issues with continuous use (level 1) and reference use (level 2) procedures. However, based on the recent findings documented with aspects in this area, it appears performance gaps still persist related to compliance with information-use-only (level 3) procedures. The staff has determined that a substantive cross-cutting issue does not exist because a reasonable duration of time has not passed since the identification of the new procedural compliance theme. The staff noted that you recognized the problem with procedural compliance and determined that it affected multiple areas before the theme was identified in May 2009. In addition, you already have corrective actions in place that include department functional and cross functional area procedure reviews intended to increase user awareness and compliance with reference-use procedures. We also note that you plan to perform an additional causal evaluation in this area to identify remaining performance gaps and develop corrective actions to close those gaps. We will continue to monitor the effectiveness of the corrective actions in this area through the baseline inspection program.
The enclosed inspection plan details the inspections, less those related to physical protection scheduled through December 31, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of
T. Joyce 3
inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review.
In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
As you may know, the NRC is currently evaluating the scope and frequency of all the baseline inspection procedures as part of our biennial review of the reactor oversight process. If the results of the evaluation, or any other circumstances, cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Art Burritt at 610-337-5069 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
James W. Clifford, Acting Director Division of Reactor Projects Region I Docket Nos. 50-272, 50-311 License Nos. DPR-70, DPR-75
Enclosure:
Salem Nuclear Generating Station Inspection/ Activity Plan cc w/encl:
W. Levis, President and Chief Operating Officer, PSEG Power R. Braun, Site Vice President P. Davison, Director of Nuclear Oversight E. Johnson, Director of Finance E. Eilola, Salem Plant Manager J. Keenan, Manager Licensing, PSEG D. Sowers, Director of Public Safety P. Baldauf, Assistant Director, NJ Radiation Protection Programs P. Mulligan, Chief, NJ Bureau of Nuclear Engineering, DEP H. Otto, Ph.D., Administrator, DE Interagency Programs, DNREC Div of Water Resources Consumer Advocate, Office of Consumer Advocate, Commonwealth of Pennsylvania N. Cohen, Coordinator - Unplug Salem Campaign E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance A. Muller, Executive Director, Green Delaware V. Zabielski, General Solicitor, PSEG
Inspection / Activity Plan Page 1 of 2 08/31/2009 16:36:59 Report 22 07/01/2009 - 12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Salem 7111111B
- BIENNIAL REQUAL INSP WITH P/F RESULTS 3
1, 2 IP Licensed Operator Requalification Program 7111111B 07/27/2009 07/31/2009 71152B
- PI&R BIENNIAL TEAM 4
1, 2 IP Identification and Resolution of Problems 71152B 07/06/2009 07/10/2009 7112203
- PUB RAD SAFETY - REMP 1
1, 2 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 7112203 09/14/2009 09/18/2009 71121
- OCC RAD SAFETY 1
2 IP Access Control to Radiologically Significant Areas 7112101 10/19/2009 10/23/2009 2
IP ALARA Planning and Controls 7112102 10/19/2009 10/23/2009 2
IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 10/19/2009 10/23/2009 1, 2 IP Performance Indicator Verification 71151 10/19/2009 10/23/2009 TI-172
- U2 TI-172 RCS DISSIMILAR METAL WELDS 1
2 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 10/19/2009 10/30/2009 7111108P
- U2 INSERVICE INSPECTION 1
2 IP Inservice Inspection Activities - PWR 7111108P 10/19/2009 10/30/2009 7112202
- PUB RAD SAFETY - RADWASTE 1
1, 2 IP Radioactive Material Processing and Transportation 7112202 12/07/2009 12/18/2009 7112201
- PUB RAD SAFETY - RETS 1
1, 2 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 01/04/2010 01/08/2010 5/10EXAM
- OPERATOR LICENSING INITIAL EXAM 6
1 FY10 - SALEM UNITS 1&2 INITIAL OPERATOR LICENSING EXAM U01764 04/12/2010 04/16/2010 1
FY10 - SALEM UNITS 1&2 INITIAL OPERATOR LICENSING EXAM U01764 05/10/2010 05/14/2010 MODS
- PERMANENT PLANT MODIFICATIONS 5
1, 2 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 02/08/2010 02/12/2010 1, 2 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 02/22/2010 02/26/2010 71121
- OCC RAD SAFETY 1
1 IP Access Control to Radiologically Significant Areas 7112101 04/12/2010 04/16/2010 1
IP ALARA - Required 7112102-7112102R 04/12/2010 04/16/2010 1
IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 04/12/2010 04/16/2010 7111108P
- U1 INSERVICE INSPECTION 1
1 IP Inservice Inspection Activities - PWR 7111108P 04/12/2010 04/23/2010 TI-172
- U1 TI 2515/172 DISSIMILAR METAL WELDS 1
1 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 04/12/2010 04/23/2010 EP EX
- EP EXERCISE EVALUATION 4
1, 2 IP Exercise Evaluation 7111401 05/17/2010 05/21/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 2 of 2 08/31/2009 16:36:59 Report 22 07/01/2009 - 12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Salem EP EX
- EP EXERCISE EVALUATION 4
1, 2 IP Emergency Action Level and Emergency Plan Changes 7111404 05/17/2010 05/21/2010 1, 2 IP Drill/Exercise Performance 71151-EP01 05/17/2010 05/21/2010 1, 2 IP ERO Drill Participation 71151-EP02 05/17/2010 05/21/2010 1, 2 IP Alert & Notification System 71151-EP03 05/17/2010 05/21/2010 ISFSI
- ANNUAL SAMPLE - ISFSI INSPECTION 1
1 IP Operation Of An ISFSI 60855 07/01/2010 09/30/2010 71121
- OCC RAD SAFETY 1
1, 2 IP Access Control to Radiologically Significant Areas 7112101 07/19/2010 07/23/2010 1, 2 IP ALARA - Required 7112102-7112102R 07/19/2010 07/23/2010 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 07/19/2010 07/23/2010 TI-177
- MANAGING GAS ACCUMULATION IN ECCS 5
1, 2 IP Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System 2515/177 08/02/2010 08/06/2010 ISFSI
- ISFSI - DRY RUN AND INITIAL LOADING 1
1, 2 IP Preoperational Testing Of An ISFSI 60854 08/09/2010 08/20/2010 1, 2 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 60854.1 08/09/2010 08/20/2010 1, 2 IP Operation Of An ISFSI 60855 08/09/2010 08/20/2010 1, 2 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 08/09/2010 08/20/2010 71121
- OCC RAD SAFETY 1
1, 2 IP Access Control to Radiologically Significant Areas 7112101 09/27/2010 10/01/2010 1, 2 IP ALARA - Required 7112102-7112102R 09/27/2010 10/01/2010 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 09/27/2010 10/01/2010 1, 2 IP Occupational Exposure Control Effectiveness 71151-OR01 09/27/2010 10/01/2010 1, 2 IP RETS/ODCM Radiological Effluent 71151-PR01 09/27/2010 10/01/2010 7111107T
- TRIENNIAL HEAT SINK 1
1, 2 IP Heat Sink Performance 7111107T 12/06/2010 12/10/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.