ML20138H281

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Third Partial Response to FOIA Request for Documents.App G Records Encl & Available in Pdr.App H Record Identified as Copyright.App I Records Withheld Completely (Ref FOIA Exemption 5)
ML20138H281
Person / Time
Site: Salem  PSEG icon.png
Issue date: 12/24/1996
From:
NRC OFFICE OF ADMINISTRATION (ADM)
To: Holloway W, Oneill J
SHAW, PITTMAN, POTTS & TROWBRIDGE
References
FOIA-96-351 NUDOCS 9701030211
Download: ML20138H281 (6)
v • d • e


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FOlA 351

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} RESPONSE TO FREEDOM OF l FINAL RESPONSE TYPE l yl PAATIAL w INFORMATION ACT (FOIA) REQUEST

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DATE (ee../9g DOCKET NUMBERtS)(if apphcab/c)

J OUESTER Mr. 3. H. O'Neill . 3r. ATTih W. R. Hn11nw v ~

PART l.-AGENCY RECORDS RELEASED OR NOT LOCATED (See checkedboxes)

No tgency records subject to the request have been located.

No cdditional agency records subject to the request have been located.

Requested records are available through another public distribution program. See Comments section, Agency records subject to the request that are identified in Appendix (es) are already available for public inspection and copying at the NRC Public Document Room,2120 L Street, N.W., Washington, DC.

X Agency records subject to the request that are identified in Appendix (es) G are being made av ilable for public inspection and copying at th3 NRC Public Document Room,2120 L Street, N.W., Washington, DC,in a folder under this FotA number.

Thi nonproprietary version of the proposal (s) that you agreed to accept in a telephone conversation with a member of my staff is now being made available for public inspection and copying at the N RC Public Document Room,2120 L Street, N.W., Washington, DC, in a folder under this FOI A number.

Agency records subject to the request that are identified in Appendix (es) may be inspected and copied at the N RC Local Public Document Room identified in the Comments section.

Enclosed is mformation on how you may obtain access to and the charges for copying records located at the NRC Public Document Room,2120 L Street, N.W., Washington, DC.

)( Agency records subject to the request are enclosed. Appendix G Records subject to the request have been referred to another Federal agency (ies) for review and direct response to you.

Fees You will be billed by the N RC for fees totaling $

You will receive a refund from the NRL in the amount of $

in view of N RC's response to this request, no further action is being taken on appeal letter dated , No.

PART 11. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certrin information in the requested r6 cords is being withheld from public disclosure purtuant to the exemptions described in and for the reasons stated X in Pcrt ti, B, C, and D. Any released portions of the documents for which only part of the record is being withheld are being made available for public inspection and copying in the NRC Public Document Room,2120 L Street, N.W., Washington, DC in a folder under this Fol A number.

COMMENTS The review of additional records subject to your request is continuing.

The record listed on Appendix H is copyrighted. Therefore, it is only being made available for inspection in the NRC Public Document Room.

Some of the documents on Appendix I contain drafts which are considered predecisional information. The final versions of the drafts have already been made publicly available or will be addressed in future responses to this request.

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8 FOlA NUMeE Als) DATE RESPONSE TO FREEDOM OF j

, INFORMATION ACT (FOIA) REQUEST FOIA 96-351 OEC 2 4 996 (CONTINUATION)

PART 11.8- APPUCABLE EXEMPTIONS Records subject to the request that are described in the enclosed Appendix (es) I are being withheld in their entirety or in part under the Exemption No.(s) and for the reason (s) given below pursuant to 5 U.S.C. 552(b) and 10 CF R 9.17(a) of NRC regulations.

1. The withheld mformation is property classdied pursuant to Executive Order. (Exemption 1)
2. The withheld information relates solely to the eternal personnel rules and procedures of NRC. (Exemption 2) l l3. The withheld information is specifically exempted from pubhc disclosure by statute indicated. (Exemption 3)

Sections 141 145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C. 21612165).

Section 147 of the Atomic Energy Act,which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

4. The wethheld mformation is a trade secret or commercial or fmancial mformation that es bemg withheld for the reason (s) indicated. (Exemption 4)

The mformation is considered to be confidential busmebs (proprestery) mformation.

.l 5. The withheld mformatio The information is considered to be pronnetary mformation pursuant to 10 CFR 2.79u(dHI)

The mformation was subrmtted and received Y confidence pursuant to 10 CFR 2.790idH2l I l

Dehberative Process: Disclosure of predecesional information would tend to mhibit the open and frank exchange of edeas essentaal to the deliberative process.

X Where records are withheld m 4heer entirety, the f acts are meutncably mtertwined with the predecisional mformation. There also are no reasonably segregable factual portions because the release of the f acts would permit an mdirect inquiry into the predecisional process of the agency.

Attomey work product pnvilege (Documents prepared by an attorney m contemplation of I tigation # '

X Attorney-client privilege, (Confidential communications between an attorney and his/her client.)

6. The withheld mformation is exempted from pubhc disclosure because ets disclosure would result in a clearly unwarranted mvasion of personal pnvecy (Exemption 6)
7. Tha wethheld mformation consists of records compiled for law enforcement purposes and es bemg withheld for the reason (s) endicated (Exemption 7)

Disclosure could reasonably be expected to mterfere with an enforcement proceedmg becau'.a it could reveal the scope, direction, and focus of enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrongoing or a violation of NRC requirements Disclosure would constitute an unwarranted mvasion of personal privacy. (Exemption 7(C)) )

The mformation consists of names of mdeduals and other information the disclosure of which could reasonably be exoected to reveal identities of confidential sources. (Exemption 7 (D))

OTHER

] PART 11. C-DENYINb 6 7CIALS Pursuant to 10 CF R 9.25(b) and or 9.25(c) of the U S. Nuclear Regulatory Comm:ssion regulations. it has been determined that the iriformation withheld is exempt from peo-duction or desclosure, and that its production or disclosure is contrary to the pubhc mierest. The persons responsible for the denial are those officials identified below as denying officials and the Director. Divisron of Freedom of information and Publications Services. Office of Admmistration, for any denials that may be appealed to the Executive Director for Operateons (EDOL i 1

DENYING OFFICIAL TITLE / OFFICE RECORDS DENIED APPELLATE OFFICIAL ll ,

Executive Director for EM SECRENY C il 3. M. Taylor Doerations 1/1 - I/14 y Associate General Counsel for llS.

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t Burns Hearings. Enforcement & Admin. 1/15 - I/16 Y 1

1 l PART 81. D- APPEAL RIGHTS The dankl by each denying official identified in Part ll.C may be appealed to the Appellate Official identified there. Any such appeal must be made in writing withM 30 days of receipt of this response. Appeals must be addressed, as appropriate, to the E necutive Director for Operations, to the Secretary of the Commission, af to the inspector General, U.S. Nuclear EspJIatory Commission. Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an initia: FOI A Decision."

NRC FOIM 464 (Part 2) (191) U.S. NUCLEAR REGULATORY COMMISSION s
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l Ret FOIA-96-351 <

s i APPENDIZ G i RECORDS BEING RELEASED IN THEIR ENTIRETY l l

i MQ2 DATB DESCRIPTION /(PAGE COUNT)

. 1. Undated Charts labeled Salem Schedule Adherence and Salem 2 overall Outage Schedule Performance 1 (2 pages) l i*  :

2. Undated Briefing Package for Drop-In Visit by Public l Service Electric & Gas Company (14 pages) l
3. Undated Miscellaneous pages concerning Hope Creek Generating Station (7 pages)

. 4. Undated Handwritten IPAT sheet (1 page)

5. Undated Salem Service Water Problems (2 pages) 1 l

P Ret FOIA-96-351 APPENDIE H COPYRIGHTED RECORDS BEING RELEASED TO THE PDR

& DATE DESCRIPTION /(PAGE CRUNT)

1. No date Various News clippings (28 pgs)  ;

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l l Re: FOIA-96-351 l APPENDIX I RECORD 8 BEING WITHHELD IN THEIR ENTIRETY MQ1 DATE DESCRIPTION /(PAGE COUNT)/ EXEMPTIONS

, 1. Undated Predecisional Information Re: Salem (13 pages) EX. 5

2. Undated Predecisional Information Re: Salem (19 pages) EX. 5

! 3. Undated Salem (2 pages) EX. 5 i

4. Undated Salem (22 pages) EX. 5
5. Undated Salem (10 pages) EX. 5
6. Undated Sensitive Information - Salem (2 pages) EE. 5
7. Undated Handwritten notes, SMM Oral Presentation (4 pages) EX. 5
8. Undated Salem Nuclear Generating Station Units 1 & 2 (21 pages) EX. 5
9. 1/30/90 Handwritten notes (3 pages) EX. 5
10. 06/04/94 Handwritten, Commercial Operations 77/81 (7 pages) EX. 5
11. 01/95 Salem (2 pages) EX. 5
12. 6/95 Salem 1 and 2 w/ attached handwritten sheet and draft letter dated 1/3/95 to L. Eliason,

Subject:

Systematic Performance of Licensee Performance (SALP) Report No. 50-272;50-311/93-99 (24 pages) EX. 5

13. 6/6-7/95 NRC Senior Management (SMM) Summary, Region I (2 pages) EX. 5
14. 1/96 Salem Units 1 & 2 (5 pages) EX. 5
15. 03/23/94 Note from Lisa Clark to Mark Satorius on Proposed Actions against Public Service l Electric and Gas Company and Three

! Individuals with attached draft of letter to

! L. Eliason, draft NOV, and letters to l individuals (19 pages) EX. 5 I 1

a Re: FOIA-96-351 APPENDIX I (continued)

RECORDS BEING WITHHELD IN THEIR ENTIRETY MQA DATE DESCRIPTION /(PAGE COUNT)/EXEMPTIONE

16. 08/25/94 Note from Dick Hoefling to Mark Satorius on EA 95-62; 95-65;95-117; (Salem Corrective Action) with attached draft SECY paper, draft letter to E. Ferland, draft NOV (12 pages)

EX. 5 1

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SHAw, PITTMAN, PoTTs & TROWBRIDGE

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2300 N STREET. N.W.

WASHINGTON. D.C.20037 1128 (202) 663-8000 (202$Ioo7

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Case No.

FOINPA REQUEST

%-35I August 30,1996 Date Rec'd: 9- b % -

Action Off:

Director, Division of Freedom of Related Case:

Informa'. ion & Publications Services

-OfYiceof Administration U.S. Nuclear Regulatory Commission Two White Flint North Building 11545 Rockville Pike Rockville,MD 20852 Re: Freedom ofInformation Act Request Regarding the Salem Generating Station, Docket Nos. 50-272 and 50-311

Dear Sir or Madam:

This is a Freedom ofInformation Act request pursuant to 5 U.S.C. Q 552(a)(3) and 10 C.F.R. Q 9.23. We request that you make available to Shaw, Pittman, Potts & Tmwbridge the documents responsive to the attached Request for Production of Documents. These documents need to be made available as soon as possible to support depositions in an accelerated legal action. In order to expedite production of the documents, we have deliberately' tailored this request to be narrow in scope and straightforward in the type of documents requested. We Itave already obtained copies of relevant documents presently available at the N.R.C. Public Documents Room and they need not be produced again in l J

response to this request. Of course, we agree to bear the cost of this request as per 10 C.F.R.

@ 9.23(b)(4),9.33,9.39, and 9.40, and we authorize you to respond to this request piecemeal as documents become available. Please contact me at (202)663-8148, or William Hollaway at (202)663-8294, at your convenience if you have any questions regarding this request.

Please direct your response, pursuant to 10 C.F.R. Q 9.27, to:

l William R. Hollaway, Ph.D. ,

Shaw, Pittman, Potts & Trowbridge l 2300 N Street, N.W.

Washington, D.C. 20037-1128 (202)663-8294 Fax: (202)663-8007 i

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SHAW' PITTMAN, PoTTs & TROWBRIDGE 1

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- Director, Division of Freedom ofInformation and Publications Services l August 30,1996 Page 2 Thank you for your cooperation in this matter.

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1 John 4. O'Neill, Jr. i l J

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Fv1A Request, Aug. 30,1996 REOUEST FOR PRODUCTION OF DOCUMENTS L DIRECTIONS AND INSTRUCTIONS

1. The term "NRC" means the United States Nuclear Regulatory Commission, all offices
and/or branches thereof specifically including, but not limited to, headquarters in Rockville, Maryland and the Region I office in King of Prussia, Pennsylvania, and also in-cludes all employees, consultants, agents, and representatives to the maximum extent per-mitted by 10 C.F.R. 9.3, unless otherwise indicated by the request.

. 2. The term " Salem" means one or both units of the Salem Generating Station located in d

Hancocks Bridge, New Jersey and operated by the Public Service Electric and Gas j Company. l

' 3. The term " SAP" means the Salem Assessment Panel that was developed in 1995 specifi- )

cally to review Salem Generating Station on an ongoing basis, including all members and j i

supervisors thereof.

4. The term "PSE&G" refers the operator of Salem, Public Service Electric and Gas Company.

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5. The term "PECO Energy" refers to PECO Energy Company, formerly known as Philadel- j phia Electric Company.
  • l l
  • The term "Delmarva" refers to Delmarva Power & Light Company. I 6.

, 7. The term " Atlantic Electric" refers to Atlantic City Electric Company. .

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8. The term "SALP" means the Strategic Assessment of Licensee Performance, a compre-
hensive review of plant performance, performed for each plant on an 18-month cycle. The most recent SALP review for Salem was issued on January 3,1995.
9. The term " Enforcement Action" means a civil penalty levied by the NRC against the licen- 1 sees of Salem pursuant to single or multiple violations at Salem. The most recent En-forcement Action regarding Salem was issued on October 16,1995.
10. The term "AIT" means the Augmented Inspection Teams that performed investigations of

) Salem in 1992,1993, and 1994, including all members and supervisors there'of.

I 1. The term " SIT" means the Special Inspection Team that performed an investigation of Sa-lem in 1995, including all members and supervisors thereof.

1-1 l

l FOIA Request, Aug. 30,1996 l i

)

12. The term "PA" means the comprehensive Performance Assessment evaluation of Salem i performed in July-August,1995 to aid in focusing future NRC inspection resources at Salem.
13. The term " Confirmatory Action Letter" means the letter from the NRC to PSE&G on June 9,1995 confirming PSE&G commitments to take specific actions prior to the restart of j Salem and confirming that failure to take these actions may result in enforcement action.

IL DOCUMENTS REQUESTED

1. All documents concerning the NRC's Salem Assessment Panel (" SAP") established on I August 2,1995, especially including but not limited to:

l

a. All internal NRC discussions concerning the formation and purpose of the SAP; l
b. Transcripts, meeting minutes, summaries, and handouts of all meetings of the SAP; ]
c. Lists of attendees at all meetings of the SAP; 1
d. . All materials presented to the SAP;

)

e. All notes taken during presentations and meetings of the SAP;
f. All reports or memoranda of the SAP;
g. All reports or memoranda written by any members of the SAP concerning Salem. ,
2. All documents concerning the NRC's Systematic Assessment of Licensee Perfonnance

("S ALP") reviews of Salem from 1990 through the present, especially including but not limited to:

a. - Transcripts, meeting minutes, summaries, and handouts of all NRC meetings on the Salem SALP reports;
b. Lists of attendees at all meetings on the Salem SALP reports;
c. Variances, differences or changes between consecutive Salem SALP fe
d. Internal NRC discussions about interim drafts of the Salem SALP reports;
e. Internal NRC discussions about final drafts of the Salem SALP reports;

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FOIA RGquest, Aug. 30,1996

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f. Internal NRC discussions about variances, differences or changes between interim reports and the final Salem SALP repons;  !
g. The basis for each of the findings in the Salem SALP reports;
h. Region I's knowledge ofissues raised in the Salem SALP repons; l l
i. Region I's knowledge of PSE&G's plans to address issues raised in the various Sa-lem SALP repons; l
j. Internal Region I discussions concerning the findings and conclusions expressed in  !

. the Salem SALP repons; i

k. Whether NRC or Region I ever expressed any concerns about poor or declining performance or the like to PSE&G related to the Salem SALP reports;
1. Communications between NRC and Region I personnel concerning consistencies  !

or inconsistencies between the various Salem SALP repons; l l

m. A11 documents setting fonh or discussing the deliberations and consideratiora of l ihe SALP boards reviewing Salem performance from 1990 to the present;

]

n. To the extent not covered by previous requests, all other documents regarding the Salem SALP reports.
3. Al.1 documents concerning potential and actual NRC enforcement actions regarding Salem -

from 1990 to the present, including but not limited to:

a. Transcripts, meeting minutes, summaries, and handouts from all Enforcement Con-ferences concerning Salem between NRC and PSE&G, including but not limited to tnectings on February 2,1992; April 9,1992; April 6,1993; Febniary 1,1994; July 28,1994; February 10,1995; Jdne 1,1995; June 23,1995; July 13,1995; and July 28,1995;
b. Lists of attendees at all Enforcement Conferences concerning Salem between NRC and PSE&G; i
c. Transcripts, meeting minutes, summaries, and handouts from all interpal NRC meetings concerning enforcement actions regarding Salem;

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d. Lists of attendees at all internal NRC meetings concerning enforcement actions re-l garding Salem"
e. Communications with PSE&G concerning potential and actual NRC enforcement actions regarding Salem; j

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. . - - - - . - - . . - . - . . - - . . _ - - - - . - . - - . ~ - - - - . -

FuA Requsst, Aug. 30,1996 i

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f. Communications with others concerning potential and actual NRC enforcement l

actions regarding Salem, especially including but not limited to PECO Energy, L Delmarva, and Atlantic Electric;

g. _ Internal NRC discussions concerning potential NRC enforcement actions regarding l Salem;
h. Intemal NRC discussions concerning actual NRC enforcement actions regarding Salem, including but not limited to the $50,000 civil penalty issued March 9,1994; the $500,000 civil penalty issued October 5,1994; $80,000 civil penalty issued April 11,1995; and the $600,000 civil penalty issued October 16,1995;-
i. The basis and rationale for taking each of the enforcement actions regarding Salem;
j. Internal NRC discussions about drafts of the enforcement actions regarding Salem; l
k. - Internal NRC discussions concerning the findings and conclusions expressed in the I~ . enforcement actions regarding Salem;
1. Internal NRC discussions concerning PSE&G's responses to each of the enforce-ment actions regarding Salem;
4. All documents concerning meetings between the NRC and PSE&G management or Board i of Directors conceming the performance of Salem from 1990 to the present, including but l

. not limited to: l

a. Transcripts, meeting minutes, summaries, and handouts from all meetings, includ-

.ing but not limited to meetings on June 25,1992; July 1,1992; October 10,1992; July 16,1993; July 18,1993; August 6,1993; May 7,1994; March 20,1995; March 21,1995; April 3,1995; June 5,1995; and May 24,1996;

b. Lists of attendees at all such meetings;
c. Communications with PSE&G concerning such meetings; I
d. Communications with others concerning such meetings, especially including but not limited to PECO Energy, Delmarva, and Atlantic Electric; j
e. Internal NRC discussions concerning such meetings. I l
5. All documents concerning the NRC Augmented Inspection Team ("AIT") investigations ofincidents at Salem from November 11-December 3,1991; December 14-23,1992; June 5-28,1993; and around April 1994, including but not limited to:

I 1

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! - FOIA Request, Aug. 30,19% t l a. Transcripts, meeting minutes, smmnaries, and handouts from all AIT meetings re-garding Salem; 2

b. Lists of attendees at all AIT meetings regarding Salem;  ;
c. Communications with PSE&G concerning the AIT investigations at Salem and f AIT meetings regarding Salem;
d. Communications with others concerning the AIT investigations at Salem and AIT

, meetings regarding Salem, especially including but not limited to PECO Energy, Delmarva, and Atlantic Electric;

e. Internal NRC discussions conceming the AIT meetings regarding Salem;
f. The reasons why the NRC decided to do the AIT investigations at Salem.

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g. ' The basis for each of the findings in the AIT reports ofinvestigations at Salem;
h. Notes taken by inspectors during and after the AIT investigations at Salem; i
i. Internal NRC discussions about interim drafts of the AIT reports ofinvesdgations at Salem;
j. Internal NRC discussions about final drafts of the AIT reports ofinvestigations at Salem;
k. Internal NRC discussions concerning the findings and conclusions expressed in the

. AIT reports ofinvestigations at Salem. .

6. All documents concerning the NRC Special Inspection Team (" SIT") review of Salem per-formance from March 26-May 12,1995,. including but not limited to:

! .l

a. Transcripts, meeting minutes, summaries, and handouts from all SIT meetings re-garding Salem;
b. Lists of attendees at all SIT meetings regarding Salem;
c. Communications with PSE&G concerning the SIT investigation at Salem and SIT meetings regarding Salem;
d. Communications with others concerning the SIT investigation at Salem and SIT meetings regarding Salem, especially including but not limited to PECO Energy, Delmarva,' and Atlantic Electric;
e. Internal NRC discussions concerning the SIT meetings regarding Salem; 5-

l - FOIA Rrquest, Aug. 30,1996 i

f. The reasons why the NRC decided to perform the SIT investigation at Salem;  ;
g. The basis for each of the findings in the SIT report regarding Salem;
h. Notes taken by inspectors during the SIT investigation at Salem;  !

l

i. Internal NRC discussions about interim drafts of the SIT report regarding Salem-l l j, Internal NRC discussions about final drafts of the SIT report regarding Salem; j
k. Internal NRC discussions concerning the findings and conclusions expressed in the  !

l SIT report regarding Salem. ] 1

7. All documents concerning the NRC's Performance Assessment ("PA") review of Salem from July Il-August 25,1994, including but not limited to:

3

a. Transcripts, meeting minutes, summaries, and handouts from all meetings concern- l ing the PA review regarding Salem, Lists of attendees at all meetings concerning the PA review regarding Salem; l b.

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c. Communications with PSE&G concerning the PA review and PA review meetings l regarding Salem; l
d. Communications with others conceming the PA review and PA review meetings regarding Salem, especially including but not limited to PECO Energy, Deinurva, )

and Atlantic Electric,

e. Internal NRC discussions concerning the PA review meeting regarding Salem; ,

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f. The reasons why the NRC decided to do a PA review regarding Salem;
g. The basis for each of the findings in the report regarding the PA review regarding Salem;
h. Notes taken during the PA review regarding Salem;
i. Intemal NRC discussions about interim drafts of the PA review report regarding Salem;
j. Internal NRC discussions about final drafts of the PA review report regarding Salem;
k. Internal NRC discussions concerning the findings and conclusions expressed in the :

PA review report regarding Salem.

FOIA Request, Aug. 30,1996 i  ?

j 8. All documents concerning the Confirmatory Action Letter ofJune 9,1995 (CAL No. l l-95-009), including but not limited to: i

\

a. Communications with PSE&G concerning the Confirmatory Action Letter; ,
b. Communications with others concerning the Confirmatory Action Letter, espe-a cially including but not limited to PECO Energy, Delmarva, and Atlar ric Electric;
c. Internal NRC discussions concerning the Confirmatory Action Letter;  ;
d. Discussions with Region I concerning non-final drafts of the Confirmatory Action  !

Letter; '

e. Discussions with Region I concerning final drafts of the Confirmatory Action i Letter-i I

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j f. Region I's knowledge of the issues raised in the Confirmatory Action Letter;

g. Region I's knowledge of PSE&G's plans to address issues raised in the Confirma-  ;

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_ WEEK E NO ING 114ul 16-Jah 25-Jul 1-Aug ' Sang 14 Aug 21-Aug 28 Aug 4-sep 11.se p i t a-ser 25-sep 154an CO M P LEToo N GO AL 23.042 24,487 25,655 27,080 28,505 28,930 31,355 32.78C 34,505 45,000 CU M M CO M P LE TE 20,424 21<2CS 22 244 23.042 23,749 24,520 W / E E K LY CO M P LE TE 730 845 975 788 747 731

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BRIEFING PACKAGE FOR DROP-IN VISIT BY PUBLIC SERVICE ELECTRIC & GAS COMPAN 1

Visiting Officials: E. James Ferland Chairman of the Board, President and Chief Executive Officer i

I Leon R. Eliason President - Nuclear Business Unit 1 and Chief Nuclear Officer Date of Visit: August 26, 1996 .

Plants: Hope Creek Generating Station  !

Salem Nuclear Generating Station, Units 1 and 2 l

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Anticipated Licensee Focus of Visit 4

1 Salem Restart Issues (unknown for Hope Creek)  !

Potential NRC Topic.of Discussion Salem Status of restart activities

  • Design basis efforts Maintenance Department problems Hope Creek
  • Management changes
  • Configuration control i

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ORGANIZATION CHARTS 3

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SALEM OPERATIONS Chart 2.2 General Manager Salem C peretions (R/C 069)

David Garchow Executive Secretary Barbara Powell l I I I I Meneger Chemistry Meneger Radiation Protection Manager Assistant General Manager Setem Projects (RC-147) Meneger Salem Operations (RC-069) (RC-065) (RC-061)

(Operations MartT))

Nick Conicella Greg Suey Eric Katzman Chris Bakken John Holden 1

l l Outege Manager Meneger (RC-092) Salem Maintenanos (RC-2OO)

(Maintenance Mgr (T))

Rob Antonow Mike Kerwin See Chart 2.2.3 Senior Secretary Carol Tabor I I Sr. Outage Program Contractors Specialiste T. Cote Ricky Barlow J. Bledsoe Herb Cruickshank* i Steve Chapmann Bill Tench Jody Denton (1-Openi

/T/ Designated title in accordance with Tech. Spec.: Chapter 6. Admin Controls rwr/069 8/1/96

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NUCLEAR ENGINEERING Senior VP Nuclear Engineering

' Bert Simpson Senior Executive Secretary Betty Kidd l I I I Manager Director Director Director Manager Salem Design System Steam Nuclear Restart Engineering Engineering Generator Fuels Engineering & Projects Project '

Mark Gary Mark Elliott Jerry Ranalli McGough Overbeck Reddemann Rosenfeld e

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IIOPE CREEK OPERATIONS GM llope Creek Operations Mark Bezilla Executive Secretary Jenny Turner ,

Station Project Specialist Bob Cephas '

l I I I I Operations Maintenance Manager Manager Outage Planning Manager Manager Chern/ Rad Manager Hope Carck Ilope Creek (acting) Pro / Station Rad Waste Projects liarlan llanson Mike Massaro Charlie Smith Tom Kirwin s

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NUCLEAR OPERATIONS Senior Vice President Nuclear Operations Louis Sterz Senior Executive Secretary Dana Bussey Technical Advisor '

Mike llendrick l l l l GM GM GM Director .

Ilope Creek Salem Nuc Nuclear Operations Operations Operation Trng Cntr Services Dave Jean .

Mark Bezilla Garchow Marty Trum McMahon ,

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NUCLEAR TRAINING CENTER Director Nuclear Traimng t l

Jerry .

McMahon

  • Executive Secretary Ann Lloyd l l l l l l Manager Operations Manager Tech. Trng Instructional Radiological Trng Maint. Trmg Manager Tech Safety Manager (acting) Manager J. Polyak J.Zerbo Mark Shedlock Mark Shedlock Stormi Carlson

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SYSTEM ENGINEERING Director Nuclear.

System Engineering Gary

  • Overbeck Executive Secretary Carol Buyarski I I l Manager Manager Manager S/IIC System System Speciality Engineering Engineering  ;

Engineering Salem ~ llope Creek Mike Craig  ;

Ali Fakhar Rencheck Clapper

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NUCLEAR BUSINESS UNIT

. Chief Nuclear Officer &

President -

NBU Leon Eliason Executive .

Assistant Ann Shimp I I l l Senior Vice Senior Vice Director Director Manager President President Nuclear QA/NSR Nuclear Nuclear Nuclear Business iluman Operations Engineering Support Resources Bert Jeff Chuck Louis Storz Simpson Eric Salowitz Benjamin Johnson 4

QUALITY ASSURANCE / NUCLEAR SAFETY Dirrctor QA/NSR Jeff Benjamin  !

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Executive Secretary Delores lladden ,

I I I I I I l l Manager Manager Manager Manager Manager Manager Principal Staff Nuclear Conective Quality Quality Employee Licensing & Administrator ,

Safety Actions & Assessment Assessment Concerns Regulatiore 1 Review Qaulity llope Creek Salem Services Dennis Ray Ng Mark Joe Pollock Tauber Jack Carey Dave Powell Peter Moeller ,

Marano '

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s t DESIGN ENGINEERING & PROJECTS

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Director ,

Design Engineering Projects Mark McGoughl ,

Executive Secretary Edna Schermerhorn I I I I I I I Technical Mgr Salem Mech Plant Salem Salem Hope Crrek Assistant Nu- Engineering Engineering Civil / Structural Electrical Design Engineering Mgr Mgr & Programs Engineering Engineering Projects Mgr Mgr Mgr R. Scott Michigan Craig Lambert Greg Cranston Chuck Nentwig George Englert G. Boerschig D. LaMastra

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NUCLEAR BUSINESS SUPPORT Director Nuclear Business Support Eric Salowitz Executive Secretary Nancy Dixey i I I I I I Manager Manager Manager Manager Manager Administrative Business Business /Co-Owner Procurement Site Planning Information Coordinator Support Affairs & Systems Nuc Materials Engineering Managmnt Ed Walters Todd Phyllis Page Bill llenrick Ed Benson Anderson C. McClain Clerical Assistant Melody DiMarzio l

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BIOGRAPHICAL DATA I

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- HOPE CREEK GENERATING STATION '

A. CURRENT PLANT STATUS I l Hope Creek restarted from Refueling Outage 6 in Spring '96 and has operated uneventfully. Their current power duration is a record for ,

post-refueling-startup operation for Hope Creek. Refueling Outage 6 had been extended to almost 6 months to address a number of adverse plant conditions. '

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B. ORGANIZATION AND NANAGENENT CHANGES The Hope Creek Management structure has been characterized by frequent

' changes. The licensee has had difficulty in staffing the positions of General Manager and Operations Manager; while these two positions are  !

now filled, the positions of Maintenance Manager and Chemistry / Radiation Protection / Rad Waste Manager are not permanently staffed.

i l C. SALP/ PLANT PERFORMANCE Overall performance declined from the last SALP period for operations, maintenance, and engineering activities. Earlier initiatives to reduce scram frequency had previously shown some success. However, the number of automatic and manual scrams (seven in the previous SALP period, five of which occurred in 1994) as a result of personnel, component, and l design installation problems, indicates that performance in this area 1 4

was inconsistent. Weak or poorly implemented root cause analysis was a i

. dominant. factor in the general performance weaknesses noted during the previous SALP period. During the SALP period which ended April 22, i 4

1995, the licensee received a Category 2 rating for Operations, l Maintenance, and Engineering, and a Category I rating for Plant Support.

The licensee received an adverse " trends" letter on January 29, 1996.

A recent Plant Performance Review validated the SALP observations and noted the need for more stability in the staffing of plant management positions. It was also noted that the promotional chain, from plant equipment operator to senior reactor operator-(SRO), lacked a sufficient number of candidates to assure a good supply of SR0s and managers.

D.

RECENT ENFORCEMENT ACTIONS (SEVERITY LEVEL III OR HIGHER)

The July 8,1995 shutdown cooling bypass event resulted in escalated enforcement. A pre-decisional enforcement conference was held on i November 6, 1995 and a Notice of Violation (Level III with a Civil  ;

Penalty of $100,000) was issued on December 12, 1995. The licensee's response dated January 11, 1996, did not dispute the violation and forwarded payment of the penalty.

On April 8,1996, a Notice of Violation (Level III witi, no Civil Penalty), was issued due to repetitive failures of seismic sway arresters (snubbers) on the Hope Creek Safety Auxiliaries Cooling System. The major issue in this violation was failure of ?.he licensee 4 J

to take proper corrective actions.

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_ LIMITED OFFICIAL USE ONLY E. CURRENT ISSUES The NRC staff is currently considering three issues as Level III Violations: (1) A proposed modification to the service water system would have implemented a change to.the facility, involving an Unreviewed Safety Question-(per 10 CFR 50.59) without prior Commission approval, (2) A number of safety-related air dampers were installed backwards.

The licensee knew about this condition and failed to take corrective' action.~(3) The licensee would have deferred the " scram time testing" of control rods, following control rod maintenance, in- violation of the Technical Specifications.

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. LIMITED OFFICIAL USE ONLY Current Performance - Hope Creek Systematic Assessment of Licensee Performance (SALP) Ratings (Based on period ending April 22, 1995)

Operations - Category 2 Maintenance - Category 2 Engineering - Category 2 Plant Support - Category 1 Current assessment period: April 23, 1995 to November 9, 1996.

The NRC held the SALP management meeting on August 3, 1995. The licensee's response to the SALP, as well as recent performance trands, are dominated by corrective actions taken or planned resulting from: (1) the April 5,1995 radiological release event; (2) the two events involving a loss of shutdown cooling in March and July 1995; (3) the recent problems identified in the surveillance test program; (4) the continuing concerns regarding operator errors that have recently resulted in numerous plant events; and, (5) the licensee's self identified Impact PTan (improvement program).

The licensee has initiated numerous organizational and management changes, and additional changes are still planned, especially regarding Hope Creek operations leadership. Also, significant changes have been made to the corrective actions program. While an immediate impact relative to problem identification was noted, overall effectiveness of the new corrective action program has not been determined. Streamlining of the engineering support function has been noted; however, again, it is too early to determine the effectiveness of this change.

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LIMITED 0FFICIAL USE ONLY SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 i

A. CURRENT PLANT STATUS Salem Unit 1 On May 16, 1995, Unit I entered Technical Specification'3.0.3 and began {

a shutdown due to inoperable switchgear supply fans.. The unit reached i Mode 5 on May 17. ~ Plant staff began core off-load on July 25, completed it August 5. Unit 1 is currently defueled, Mode undefined.  !

Salem Unit 2 On June 7, 1995, Unit 2 entered Technical Specification 3.0.3 and began  !

a shutdown due to inoperable trains of RHR. During the shutdown, a 500 i KV breaker failure and subsequent loss of 2 of 4 operating reactor coolant pumps caused a reactor trip from 10% power. The unit reached Mode 5 on June 8, and remained in Mode 5 as of mid-October.

Both' Salem units must satisfy the conditions specified in a Confirmatory Action Letter (CAL), dated June 9, 1995, prior to restart. A letter

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dated February 13, 1995, approved the satisfactory completion of two of the CAL conditions, including the Salem Restart Plan.

B. ORGANIZATION AND MANAGEMENT CHANGES Effective July,1996, David Garchow became-the General Manager, Salem  !

Operations.

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, , C. SALP/ PLANT PERFORMANCE During the SALP period which ended November 5, 1994, the licensee received a Category 3 rating for Operations and Maintenance, Category 2 rating for Engineering, and a Category I rating for Plant Support.

D. RECENT ENFORCEMENT ACTIONS (SEVERITY LEVEL III OR HIGHER)

On October 16, 1995, a Notice of Violation and Proposed Imposition of Civil Penalties for $600,000 was issued. The violations involved:

a thirteen examples of inadequate corrective actions including failure to promptly resolve a known safety issue associated with the pressurizer overp-essure protection system, failure to correct inoperable RHR recirculation valves for both trains of RHR at Salem Unit 2, and failure to correct inoperable switchgear supply fans at Salem Unit 1; failure to con' trol a modification to ensure that it was correctly )

implemented (installing the loop drains for the pressurizer code  !

safety without insuring that the drain valves were properly aligned,  !

or insuring that post modification testing verified that the drain I performed its intended function); and a repeat failure to comply with the Technical Specification action statement requirement for an inoperable PORV.

E. CURRENT ISSUES Maintenance Department Overhaul - Management has concluded that the Maintenance Department has serious flaws,:' including knowledge deficiencies, poor leadership, reliance on contractors, and flawed planning. As a result, new maintenance superintendents will be hired.

In addition, the entire department will be tested and sent offsite for training. During this time, maintenance activities will be performed by contractors.

Shift Schedules - On August 7,1996, the licensee notified the NRC that it was not meeting a Unit 2 license condition that required the establishment of regularly scheduled eight-hour snifts without reliance on the routine use of overtime. In 1992, the licensee transitioned from eight-hour shifts to twelve-hour shifts without requesting a license amendment. It is expected that the licensee will request the necessary license amendment to allow twelve-hour shifts.

Unit 1 Steam Generator Replacement - Eddy current testing of all tubes in the replacement (Seabrook) neam generators (SGs) have been completed. The first SG is scheduled to leave Seabrook by.the end of September, 1996. All four.SGs are scheduled to be installed in Unit 1 by the end of January,1997, and startup of Unit 1 is scheduled for the end of the second quarter of 1997.

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Licensing Basis Conformance Project - The entire project, as originally scoped, was completed August 9,1996. The final report is due by the end of September,1996. So far, more than 100 items that require corrective actions have been identified. Most of these are inconsistencies in design basis documentation that the licensee believes do not have to be corrected prior +,o restart of Unit 2. Contingent on .

l completion of the limited number of corrective actions designated as required for restart, the licensee believes that there is reasonable assurance that Salem Unit I and 2 will be operated within their i licensing / design basis. '

Operator Exemption - The licensee requested an exemption from 10 CFR 55.31(a)(5) for ten operator license applicants.

(10 CFR 55.31(a)(5) requires that operator license applicants perform at least five significant control manipulations on the facility for which the license is sought.) An exemption for six of the ten applicants was signed by William Russell, Director of NRR, and sent to the ED0 on July 26, 1996.

NRC Inspection Activities .- Six of the 43 technical items have been closed and fully documented in inspection reports. Six more technical items have been updated in inspection reports with some additional licensee actions necessary for closure. Three programmatic items have i been closed. There is a~significant NRC inspection effort onsite: two l full-time contractors are reviewing restart items and are closing  !

allegations, and several NRR personnel have been providing direct inspection support.

Merger - PSE&G is considering a merger with.one.of.the other.. owners of Salem, PECO Energy Company, to form a new company that would control all j of the nuclear resources of PSE&G and PECO. Meanwhile, an August 12,  ;

1996, press release reported the merger of the other two owners, i Atlantic Energy, Inc. and Delmarva Power and Light Company. '

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Current Performance - Salem ,

Systematic Assessment of Licensee Performance (SALP) Ratings (Based on period ending November 4, 1994)

Operations - Category 3 Maintenance - Category 3 Engineering - Category 2 ,

l Plant Support - Category 1 Current assessment period: November 5, 1994 to March 8, 1996. (End date will change based on Salem Units restart)  !

The new management team has implemented a number of measures designed to {

improve the standards of performance for Salem and Nuclear Business Unit '

employees. Some of the results include a large increase in the numbers of documented degraded plant conditions, a graded approach to performing l root cause determinations, management accountability for the quality and l timeliness of root cause deterM nations, and implementation of a departmental self-assessment program. The new management team has LIMITED OFFICIAL USE ONLY I

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demonstrated a significantly improved grasp of safety perspective during ,

daily meetings and SORC meetings. The process to address equipment  !

deficiencies and determine which must be addressed prior to restart has '

largely been completed. The action plans to address people and process i

problems have been reviewed, and plant management has just begun implementation of these resulting actions.

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i SALEM SERVICE WATER PROBLEMS BACKGROUND:

Salem service water (SW) problems surfaced circa 1980 l 1

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  • Aggressive carbon steel pipe attack by corrosion / erosion due to the Delaware River source; i.e., brackish water, sitt entrainment, stagnant lines, aggresive river water chemistry and microbiologically influenced corrosion (MIC).
  • Licensee replaced some affected piping with stainless steel type 316. Ucensee then experienced severe pitting corrosion with the stainless steel type 316 piping.
  • In 1987, licensee developed and presented to NRC a 7 year plan ($83 Million) to  ;

deal with SW problems. gg7 l

  • Identified problem areas
  • Initiated a system inspection and monitoring program
  • Establish priorities and a material test program l
  • Selected 6% Moly Stainless Steel as replacement material ALO ,
  • Licensee has replaced more than 40% of the affected piping and intends to complete the replacements by 1995.

SPECIFIC LICENSEE ACCOMPLISHMENTS:

  • 1987-1989, the licensee replaced the followino.
    • 10 containment Fan Coil Units
    • Selected areas of inlet and outlet piping on 3 component cooling heat exchangers (11, 21&23)
    • All motor operated valves (Butterfly type) in the service water structure intake structure with Hi-performance valves

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    • Eliminated 14 rubber expansion joints and replaced with hard piping in the service water intake structure Contaiment Fan Coil Units header (21&22) located in valve room
    • Chiller condensers piping (11,12&13)

LICENSEE SCHEDULE FOR 1990 SERVICE WATER SYSTEM UPGRADES:

  • Piping replacement on the remaining containment Fan Coil Units (24 25)
  • Piping replacement in selected areas of Bay #1 of the SW intake structure
  • Piping replacement in selected areas of #21 Component Cooling Heat Exchanger, both inlet and outlet (unit #2)

LICENSEE MONITORING PROGRAM:

On going "in-line" material test program.

  • Continue system inspections and testing
    • Visual- examinations during planted system outages.

LICENSEE EVENT REPORTS and RESPONSE:

  • This results from a conservative response to NRR interpretation that any less than minimum wall thickness condition is outside the plant design basis for ASME Code systems. No other Ucensee's are known to be this conservative in reporting at this time.

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E5555555555555555555555555555555555E Copyrighted Document Addressed Under FOIA l

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. FOIA Name & Numbers Pages: kescasc #3 hafxd. la -A 4 -Slo k fhxw S.]X. N {( (59fy\ .

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