ML20098D340

Discusses NRC Decision Not to Impose Penalties on Plant as Result of Turbine Generator Destruction in Nov,1991

ML20098D340
Person / Time
Site:	Salem
Issue date:	04/02/1992
From:	Biden J SENATE
To:	Selin I, The Chairman NRC COMMISSION (OCM)
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ML20098D338	List: ML20098D340
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NUDOCS 9205280213
Download: ML20098D340 (5)

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t t aw a*F Huited starts Etnatt WASHINGTON DC 20510-0802 April 2, 1992 Dr. Ivan Selin Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chairman:

I am stunned by the Nuclear Regulatory Commission's (NRC) decision not to impose penalties on the Salem nuclear plant as a result of the turbine generator destruction in November, 1991.

This decision appears to be based on a very restricted view of the turbine explosion, and can only reinforce the public's perception that the NRC fails to demand the highest level of safety.

It is an understatement to call the turbine explosion a serious event.

Seventy-five million dollars in damage was incurred by the utility as a result of the explosion.

The force of the explosion was strong enough to blast shards of turbine blades through the thick turbine casing and throw them up to three hundred yards away.

In addition, steam generator tubes were shredded and a fire developed.

While the specifics of the blast are serious, perhaps the most disconcerting aspect of the explosion was that it was preventable.

But your agency's decision to impose no penalties on Public Service Electric and Gas (PSE&G) appears to ignore this fact as well as many others.-

A review of actions and inactions, as documented by your own review team, that led to the accident shows many serious shortcomings in the operation of the Salem plant.

First, the Augmented Inspection Team (AIT) sent to Salem after the accident found that "PSE&G missed valuable opportunities to prevent the Salem Unit 2 turbine generator failure.... Insufficient priority and importance was assigned to the verification of operability and replacement of solenoid valve at Salem Unit 2."

In addition, the team found that the utility ignored earlier warnings of problems with the solenoid valves.

An infornation notice sent by the NRC " identified several solenoid valve problems, including applications in turbine trip control systems....The NRC found no indication that the l

licensee had directed any attention or priority to addressing l

the implications of this information... as of the date of this occurrence." (emphasis added) 920S280213 920S13 PDR COMMS NRCC CORRESPONDENCE PDR

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b Perhaps the most shocking aspect of the sequence of 4

ovents is that the utility had found a similar problem at another reactor at the same facility, the Salem i reactor.

The utility initially took on the responsibility to prevent a problem at the Salem 2 reactor by promising the NRC to replace the valves in question during fuel outage scheduled for May, 1991.

However, the inspection team found that " work was deferred... due to management decision that may have been caused by a deficiency in commitment tracking".

No further 4

explanation was provided as to why management decided to put off replacing the valves, what factors went into that decision, or why the NRC failed to detect that the valves i

were not replaced.

Finally,.the inspection team documented that test recults from October 20, 1991 showing that the valves were not working _ properly were ignored by supervisory personnel.

This was not the decision of a single person, but rather l

soveral personnel, including " licensed operators, a shift supervisor, a senior shift supervisor, and a senior operations engineer."

So, in summary, according to the inspection team sent in the aftermath of the accident, PSE&G 1) ignored warnings from the-NRC that the solenoid valves were troublesome in other plants, 2) ignored the lessons of their own experience with the valves, 3) failed to follow through on commitments to replace the valves, and 4) ignored test results which showed that the_ valves in question were not working properly.

P With the findings of the inspection team's report, it is inconceivable that the NRC believes no penalty is justified.

Thecreasons provided for the absence of a penalty are not convincing.

In deciding not to impose any penalties, your agency noted that " corrective actions have been taken or planned to prevent recurrence of such violations." (emphasis added)

To i

be blunt, I r?e no basis for confidence in PSE&G's planned future actions in-light-of their failure te fulfill past

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j commitments related to the valves.

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-In addition, the unstated amount of penalties was reduced to zero through a series of three "mitigations".

The first reduced the unknown penalty by=25 percent because the i

' utility told the NRC, on its own, that.a turbine on the roof of the building had exploded, showering the facility with metal debris.

To suggest that a-utility can receive credit i

for reporting an event that would be impossible to hide is a i

ludicrous policy,

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Another mitigation reduced the unstated penalty by ona-half because of apast performance in the operations area specifically, reduction in personnel errors and overall control room performance...."

I cannot fathom the reasoning behind this reduction since personnel errors and operating procedure failures clearly contributed to the explosion.

And those errors were not the result of a single decision; they were a series of decisions spread out over several months.

I would also note that this seems to represent a recurrence of a problem cited by the NRC years ago.

In a Systematic Assessment of Licensee Performanca (SALP) report on Salem's performance in 1988, the report specifically noted further improvement in attention to detail... is needed to reduce the frequency of... missed surveillance tests."

In addition, a 1989 SALP overview of the Salem's operations found that " reduced management and supervisory oversight of maintenance activities resulted in laxness in the implementation of the maintenance program....the long-standing nature of the [ surveillance] problem and the inability to promptly correct the problem indicates a weakness in management attention to this issue."

Based on the AIT report on last November's explosion, it appears this aspect of the plant's operation continued to be problematic.

Yet your agency elected to reduce the penalties based on these shortfalls to nothing.

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A third _ reason the penalty was zero was because "although-you-[ Salem] had prior notice of-potential problems with the mechanical binding of solenoid valves because of a similar problem at Unit 1 in September, 1990, no adjustment to the civil penalty is warranted because the primary issue involved in this case is the performance of the operators, rather than the maintenance of the equipment."

Again, this reasoning is remarkable.

In effect, the NRC has said that because Salem kept the plant from disaster and put out the fire -- crucial goals to be sure -- the utility did its job.

But this completely ignores the point that the explosion and fire could have and should have been prevented by;the utility in the first place.

Under the agency's reasoning, it is acceptable to court disaswer, as long as the disaster does not actually occur.

With regard to nuclear energy in particular, this approach cannot improve weak public confidence in this already-troubled technology.

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But beyot.d the faulty reasoning, as I see it, used to reduce the penalty based on operations performance, I am at a

-loss to understand why your agency decided to ignore maintenance problems completely.

The NRC and PSE&G both knew of problems with the v.alves.

A calculated risk was taken in deferring replacement of the valves until the next scheduled shutdown and a further risk-wau incurred when that r

replacement v oushed back to an even later scheduled shutdown.

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any penalty related to maintenance of the plant's equipms is simply swept off the table.

I question whether PSE&G should be so easily exonerated for their i

maintenance procedures in place leading up to the accident.

As you know, I have advocated an independent safety board for the NRC for years.

One reason I continue to advocate such a board is because of decisions-like the absence of any penalty _after the November accident.

The

. inspection team process, already flawed in its structure, is turned into-a complete sham when its findings are ignored and no changes are made in the_ plant or the utility.

That is what I fear has happened at Salem.

In the af termath of an accident at Salem in 1983, the NRC planned similar inactions, in effect throwing up their hands at-any meaningful penalties.

I managed to convince the Commissioners at that-time that.their approach did not pass public muster.

After reconsidering their decision, the Commission instoad got tough on.the utility, imposing the largest fine at that time -- $850,000, t

One result was a wake-up call to Salem's management that procedures and attitudes had to change, and change they did.

A few years later, top-management had been overhauled, and Salem's operating reccrd had improved. dramatically.

Unfortunately, it appears that problems have returned.-

But the decision of the NRC.to impose no penalty _at all does nothing to-force _ management to take another long, hard look at the operations of the' plant.

The message of tha NRC is that a turbine explosion is no big deal, at least not one big enough to rise to the level of penalties.

The turbine explosion and fire'were the result of a

. breakdown of procedurea, operations,_ training, and-commitments at the_ Salem plant.

The NRC's decision to ignore the. findings of its_ investigatory _ team is bad 1for residents around the Salem plant, and bodes poorly-for meaningful follow-up to other accident investigations around the country.

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One disaster has occurred.

It was proventable.

I am very concerned that other disasters, also preventable, might be allowed to occur.

I urge you to reconsider the 11RC's actions to date with rogard to Salem.

ely,O Sinc Joseph R.

Biden, Jr.

Urrited States Senator

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