ML20147B347

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NRC Enforcement Conference on 930406 Re Firewatch Program
ML20147B347
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 04/06/1993
From:
Public Service Enterprise Group
To:
Shared Package
ML20147B009 List:
References
FOIA-96-351 NUDOCS 9701310163
Download: ML20147B347 (29)


Text

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' Public Service j

Electric and Gas Company l

Tl NRC ENFORCEMENT CONFERENCE E

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FIREWATCH l

PROGRAM m

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~ APRIL 6,1993

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SALEM HOPE CREEK l

GENERATING STATION GENBtATM0 STA TION l

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T 9701310163 970124 EI 6-351 PDR

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i FIREWATCH PROGRAM AGENDA

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INTRODUCTION J. J. HAGAN

,1 FIRE WATCH PROGRAM J. F. KERIN i

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INCIDENT AND INVESTIGATION L. A. REITER i.

CORRECTIVE ACTIONS J. F. KERIN 1

l SAFETY SIGNIFICANCE J. F. KERIN j

1990 ALLEGATIONS L. A. REITER i

BROADER ASSESSMENT J. J. HAGAN i

CONTROL OF CONTRACTORS J. J. HAGAN L,_,.

I l

REGULATORY ASSESSMENT F. X. THOMSON 1

i

SUMMARY

S. E. MILTENBERGER 4

1 83EC1-3 l

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FIREWATCH PROGRAM i

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MEETING OBJECTIVES i

[

e REVIEW THE NRC FINDINGS e DESCRIBE THE FIREWATCH PROGRAM AT PSE&G l

  • DISCUSS THE MISSED ROVES AND PSE&G'S INVESTIGATIONS i

e DISCUSS PSE&G'S CONTROL OF CONTRACTORS e DEMONSTRATE MINIMAL SAFETY SIGNIFICANCE

  • DEMONSTRATE THAT ESCALATED ENFORCEMENT IS NOT WARRANTED 93EC131

l l

FIREWATCH PROGRAM

SUMMARY

OF NRC FINDINGS i

i

[

i e POTENTIAL VIOLATION l

j

- FIRE WATCHES FAILED TO COMPLETE THElR ASSIGNED l

ROUNDS l-l

- COMPLETED LOGS TO INDICATE THAT THE ROUNDS l

HAD BEEN SATISFACTORILY PERFORMED, WHEN IN FACT, THEY HAD NOT BEEN PERFORMED

,f i

i' 1'

1 si 93EC12

l Fl.REWATCH PROGRAM FIRE PROTECTION ORGANIZATION VICE PRESEMNT NUCt. EAR OPERATIONS f

GENERAL MANAGER NUCLEAR SGMCES I

StTE PROTECTION I

-,.E I.

,ROTECTiON SUP MSOR B

B Al>MMETRATIVE CUMK PMTECTKW TECHNOLMY OFF-StrE t

I 1

F.E PROTECTION FTl PTl SUPERVISORS PROGRAM MANAGER TECHNICAL SPEC 1AUST (5i (1)

(1)

FIRE PRO TCTION Fft OPERATOR - NUCLEAR SHWT SUPGMSOR (25)

(8) 0 ASST. SUPGMSOR (FELD)

(3)

FWIEWATCH (35)

NOTE: 24 HOUR PER DAY NGFT OPERATION DEDICATED INDUSTRIAL FERE DEPARTMBfT (BlWGADE)

F.W. 3 FIXED SHETS - 2 SUPBMSOfts PER SHFT JULY 1992 STAFF 980 LEVELS 93EC136

~

FIREWATCH PROGRAM FIRE PROTECTION ORGANIZATION e SURVEILLANCE TEST PROGRAM e EMERGENCY SERVICES

- FIRE RESPONSE

- EMERGENCY MEDICAL

- SPILL RESPONSE

- RESCUE e IMPAIRMEP.',,1GNITION SOUF i TRACKING e FIREWATCH PROGRAM (PTI)

- COMPENSATION MEASURES FOR FIRE PROTECTION SYSTEM OUT OF SERVICE

- OVERSIGHT BY PSE&G 93EC126

l FIREWATCH PROGRAM i

l FIREWATCH SURVEILLANCE i

1 i

i i

e SCHEDULED SURVEILLANCE -JULY 1992 l

- SALEM 96 AREAS / HOUR t

10 AREAS / HOUR j

- HOPE CREEK e REASONS FOR PERFORMING SURVEILLANCES i

- GOOD PRACTICE rL

-f.4GURANCE

- TECHNICAL SPECIFICATIONS e 9 SUPERVISORS AND 35 FIREWATCHES ON 3 SHIFTS

- 2 SUPERVISORS /12 FIREWATCHES PER SHIFT

- 8 HOURS PER SHIFT /24 HOURS PER DAY e ROVES PER SHIFT

- SALEM 3 ROVE AREAS -

1 A - UNIT 1 RCA 1B - UNIT 2 RCA 1.

II - UNIT 1&2 COMMON AREAS 30 ROVES / SHIFT = 960 AREAS / SHIFT

- HOPE CREEK - 1 ROVE AREA 10 ROVES / SHIFT = 100 AREAS / SHIFT 93EC1-32

,n

l.

I i*

i FIREWATCH PROGRAM PATROL SURVEILLANCE DUTIES I

e IDENTIFY OBVIOUS ACTIVITIES BY PLANT PERSONNEL THAT

[l COULD INCREASE FIRE HAZARDS IN THE AREA i

e IDENTIFY CONDITIONS LIKELY TO CAUSE A FIRE I

e IDENTIFY CONDITIONS LIKELY TO ADVERSELY AFFECT FIRE PROTECTION I

e IMMEDIATELY REPORT EVIDENCE OF SMOKE OR FIRE e REPORT ALL OTHER APPARENT ABNORMALITIES

'l

-1 e DUTIES ARE DOCUMENTED

- POST ORDERS

- PTI PROCEDURES

- TRAINING PROGRAM l

93EC118

Il FIREWATCH PROGRAM i

INCIDENT & IMMEDIATE ACTIONS il I

e INCIDENT

SUMMARY

- 7/1/92

- PTl SUPERVISOR IDENTIFIES MISSED ROVE

- FIREWATCH ADMITS TO MISSING SEVERAL POSTS AND FALSIFICATION OF ASSOCIATED LOGS g

- PSE&G AND PTl MANAGEMENT INFORMED e IMMEDIATE ACTIONS

- PTl INVESTIGATION INITIATED - 7/2/92 I

- PTl ISSUES LETTER TO ALL FIREWATCHES - 7/2/92

- REVIEWED WITH NRC RESIDENTS - 7/6/92

- PSE&G QA INITIATES SPOT CHECKS - 7/6/92

- PSE&G CORPORATE SECURITY INVESTIGATION a

INITIATED - 7/13/92

- PSE&G QA INVESTIGA7lOtl INITIATED - 7/13/92

- LER ISSUED - 7/30/92 0

93EC1-4 L

I

\\-

FIREWATCH PROGRAM i

CONTRACTOR INVESTIGATION l

ePURPOSE I

- DETERMINE EXTENT OF IMPROPER PERFORMANCE OF FIREWATCH ROUNDS l

j l

e SCOPE

- EVALUATE PERFORMANCE OF FIREWATCH EMPLOYEES

.FOR A 7 DAY 100% SAMPLE PERIOD IN JUNE 1992, FOLLOW UP WITH INTERVIEWS OF INVOLVED EMPLOYEES e TEAM

- NINE PTl MANAGEMENT AND SUPERVISORY PERSONNEL 1

e APPROACH

- CARDREADER HISTORY CHECKS

- FIREWATCH INTERVIEWS / STATEMENTS

- FIREWATCH SUPERVISORY INTERVIEWS 93EC1-6 e

e

l, FIREWATCH PROGRAM PSE&G CORPORATE SECURITY INVESTIGATION oPURPOSE

[

- DETERMINE KNOWLEDGE OF PTl AND PSE&G PERSONNEL REGARDING FALSIFICATION OF FIREWATCH LOGS l.

  • SCOPE

]

- PTl FIREWATCH PERSONNEL, SUPERVISION, AND MANAGEMENT

- PSE&G SITE PROTECTION SUPERVISORS AND OPERATIONS SUPERVISORS 1

e TEAM

- THREE INVESTIGATORS WITH PREVIOUS LAW.

ENFORCEMENT EXPERIENCE

  1. APPROACH

- INVESTIGATIVE PLAN AND FORMAL QUESTIONS

'l DEVELOPED WITH QA INPUT

- 53 CONFIDENTIAL INTERVIEWS 93EC17 t

l a

FIREWATCH PROGRAM I

PSE&G QA REVIEW

  • PURPOSE r

t

- VALIDATE PTl'S INVESTIGATION RESULTS

- EVALUATE PERFORMANCE OF FIREWATCH PERSONNEL FOR 2 SAMPLE PERIODS IN ORDER TO SUBSTANTIATE RESULTS OF PTI'S INVESTIGATION AND ASCERTAIN IF THIS IS A RECENT PROBLEM l.

  • SCOPE

- PTl INVESTIGATION EFFORT

- SAMPLE PERIODS, FEBRUARY 16-23,1992 AND APRIL 12-19,1992 l;

  • TEAM

- TWO EXPERIENCED QA LEAD' AUDITORS WITH ONE ASSISTANT o APPROACH a

- WITNESS PTl VERIFICATION OF ROVE LOGS

- WALKDOWN SAMPLE OF 2 ROVE ROUTES FOR FAMILIARIZATION

- COMPARE ROVE LOGS WITH SECURITY ACCESS

[

RECORDS

- COMPARE PSE&G RESULTS WITH PTI'S RESULTS 03EC18 L

ll hREWATCH PROGRAM

SUMMARY

OF INVESTIGATION FINDINGS

[i FINDINGS FOR THREE INVESTIGATIONS WERE CONSISTENT 1

l e REPORT ISSUED TO NRC - 10/28/92 g-

)

i l

e 19 OF 35 FIREWATCH PERSONNEL DID NOT C.OMPLETE

]

THEIR ASSIGNED ROUNDS AND COMPLETED LOGS TO l

INDICATE THAT THE ROUNDS HAD BEEN COMPLETED

[

]

SATISFACTORILY, WHEN IN FACT THEY HAD NOT a

i

, \\

I 1

4 4

93EC127

.I 6

I

~

FIREWATCH PROGRAM

SUMMARY

OF INVESTIGATION FINDINGS I

ADDITIONAL FINDINGS OF INVESTIGATIONS e CORPORATE INVESTIGATION

- CONTRIBUTING FACTORS (WEATHER, LOCATION, BOREDOM, SELF-ESTEEM)

[

- SUPERVISORS HAD NO KNOWLEDGE OF THE MISSED CHECKS

- POOR COMMUNICATIONS BETWEEN PTl MANAGEMENT AND SUPERVISION O PSE&G CORPORATE SECURITY INVESTIGATION

- EMERGENT WORK LED TO LAPSES IN SUPERVISION

- EXPECTATIONS NOT CLEARLY COMMUNICATED AND MINIMAL REINFORCEMENT e PSE&G QA REVIEW

- INSUFFICIENT DIRECT SUPERVISION

- INADEQUATE PERIODIC AUDITS AND SPOT CHECKS

- 16 OF 35 FIREWATCH PERSONNEL HAD UNBLEMISHED RECORDS 1

93EC1-38 j

i l

I 1-4l' FIREWATCH PROGRAM l

ROOT CAUSE CATEGORIES i

i e LESS THAN ADEQUATE SUPERVISION OF PERSONNEL BY PTl

- POOR ROVE ROUTE DESIGN l

- LESS THAN ADEQUATE FIELD SUPERVISION

- EMERGENT WORK COVERED BY FIELD SUPERVISION i

- PROGRAM MANAGER PERFORMANCE ISSUES i

l.,

i l

e LESS THAN ADEQUATE PERFORMANCE OF FIREWATCH PERSONNEL 4

- POOR TRAINING PRACTICES i

t

- EXPECTATIONS NOT REINFORCED

- LOW SELF-ESTEEM e LESS THAN ADEQUATE OVERSIGHT BY PES &G

^l

- FIREWATCH OVERSIGHT WAS LOW PRIORITY OF PSE&G j

SUPERVISOR RELATIVE TO OTHER DUTIES

- QA OVERSIGHT NOT STRUCTURED TO IDENTIFY THE PROBLEM

- ASSIGNMENT OF EMERGENT WORK TO PTl 93EC128

l FIREWATCH PROGRAM I

CORRECTIVE ACTIONS f

IMPROVED SUPERVISION OF FIREWATCH PERSONNEL BY PTl e POLICY LETTER ISSUED ENCOURAGING FIREWATCH TO SUGGEST HUMAN FACTORS BASED ROVE ROUTE DESIGN ENHANCEMENTS

{

e QUARTERLY AFTER-HOUR INSPECTIONS e WEEKLY RANDOM CARD HISTORIES OF A MINIMUM OF ONE FIREWATCH PERSONNEL, PER SHIFT e QUARTERLY RANDOM CARD HISTORIES OF A MINIMUM OF

[

THREE FIREWATCH PERSONNEL e ROVE CHALLENGE PROGRAM USED A MINIMUM OF ONCE A WEEK FOR ALL SHIFTS e TELEPHONE CALL-INS FROM ISOLATED ROVE AREAS 1.

e ADDITIONAL FIREWATCH PERSONNEL ADDED DURING PERIODS OF EMERGENT WORK e REPLACEMENT OF PT1 PROGRAM MANAGER

- STRONG LEADERSHIP BACKGROUND

- EX.PECTATIONS CLEARLY DEFINED

- OPEN LINE OF COMMUNICATION WITH PSE&G MANAGEMENT 93EC1-20 s.


4

I i.

h

FIREWATCH PROGRAM i

l CORRECTIVE ACTIONS i

i I

i l

lMPROVED PERFORMANCE BY FIREWATCH PERSONNEL

)

l e STANDARD 12ED FIREWATCH INDOCTRINATION TRAINING PROGRAM WITH FOCUS ON PERFORMANCE EXPECTATION

- ANNUAL REFRESHER TRAINING i

i e PTl CORPORATE STAFF-CONDUCTED SUPERVISORY l

TRAINING FOCUSED ON SUPERVISOR / EMPLOYEE RELATIONS SKILLS, QUALITY POST INSPECTIONS, COMMUNICATIONS, AND QUALITY CIRCLES l

- ANNUAL SUPERVISORY SKILL,S TRAINING l

1 e GENERAL EMPLOYEE TRAINING REVISED TO STRESS THE l

lMPORTANCE OF THE FIREWATCH PROGRAM i

i i

i.

i s3EC1 19 i

i 4

l FIREWATCH PROGRAM CORRECTIVE ACTIONS r

IMPROVED OVERSIGHT BY PSE&G r

e RENFORCED PSE&G'S FIRE PROTECTION SU'PERVISION AND i

MANAGEMENT RESPONSIBILITIES FOR ULTIMATE PERFORMANCE OF PROGRAM e ENHANCED FACE-TO-FACE COMMUNICATION - PSE&G AND PTl SUPERVISION RELOCATED TO SAME BUILDING

[.

e RENFORCED PTI'S ACCOUNTABILITY FOR PROGRAM IMPLEMENTATION e ON-GOING EVALUATION OF FIRE PROTECTION PROGRAM TO IDENTIFY IMPROVEMENTS e ENHANCED QA MONITORING OF FIREWATCH ROVE PERFORMANCE 1.

  • REVISED QA AUDIT PLAN FOR FIRE PROTECTION TO INCLUDE FIELD VERIFICATION OF ROVES AND SAMPLE COMPARISON OF ROVE LOGS WITH SECURITY DOOR TRANSAC'i10N RECORDS 1

e ADDITIONAL FIREWATCH PERSONNEL ADDED DURING PERIODS OF EMERGENT WORK 93EC121

j I

i FIREWATCH PROGRAM i

i OTHER PROACTIVE ENHANCEMENTS I

i i

1 l

II

  • CONTINUING SUPERVISORY (LEADERSHIP / MANAGEMENT) j SKILL TRAINING j

4 l

l e QUARTERLY " SAFETY / HEALTH / ACCOMMODATION

[. I l

MEETING". PTl SITE MANAGEMENT, FIREWATCH j

PERSONNEL, PSE&G SAFETY COORDINATOR AND SENIOR i

FIRE PROTECTION SUPERVISOR 4

l

[

o PLACEMENT OF SIGN-IN SHEETS FOR ROVE AREAS WHERE l

PHONES ARE NOT AVAILABLE i

e THE EFFECTIVENESS OF THE CORRECTIVE ACTIONS WILL BE

.1 MONITORED AND ADJUSTED AS NECESSARY J

d 93EC122 1

i

I i

l FIREWATCH PROGRAM i

i CURRENT PERFORMANCE i

i t

i e OVERALL INCREASE IN MORALE

  • NO DISCREPANCIES IDENTIFIED DURING RANDOM WEEKLY CARD READER VERIFICATIONS
  • SATISFACTORY QA SURVEILLANCE REPORTS e BASED ON A SAMPLING OF CARD READOUTS, FIREWATCH PERSONNEL FULFILLED RESPONSIBILITIES DURING MARCH SNOW STORM l

e PTl UTILIZING CONFIDENTIAL EMPLOYEE OFINION SURVEYS TO MAINTAIN AWARENESS OF EMPLOYEE MORALE 93EC123

1l i

4 j

i FIREWATCH PROGRAM i

l CURRENT PERFORMANCE 1

1 i

i l

e OVERALL INCREASE IN MORALE i

l l

e NO DISCREPANCIES IDENTIFIED DURING RANDOM WEEKLY CARD READER VERIFICATIONS

-l l

l 1

e SATISFACTORY OA SURVEILLANCE REPORTS l

e BASED ON A SAMPLIP;G OF CARD READOUTS, FIREWATCH i

PERSONNEL FULFILLED RESPONSIBILITIES DURING MARCH l

SNOW STORM a

i

  • PTl UTILIZING CONFIDENTIAL EMPLOYEE OPINION SURVEYS 4

i TO MAINTAIN AWARENESS OF EMPLOYEE MORALE l

I I

l 93EC123 l

i 4

l FIREWATCH PROGRAM FACTORS MINIMlZING SAFETY SIGNIFICANCE i

AREAS REQUIRED BY TECHNICAL SPECIFICATIONS / FIRE PROTECTION PROGRAM e COMPENSATING FACTORS

- SALEM SWITCHGEAR ROOMS A EARLY WARNING DETECTION A FIRE SUPPRESSION SYSTEM

- HOPE CRE5K REFUELING FLOOR A NO SAFE SHUTDOWN EQUIPMENT A OPERATOR ROUNDS

- SALEM BAILING & STORAGE AREA A EARLY WARNING DETECTION IN AREA ON OPPOSITE SIDE OF OPEN PENETRATION

- MISCELLANEOUS AREAS L

A EARLY WARNING DETECTION e NO FIRES HAVE GONE UNDETECTED AS THE RESULT OF THE MISSED FIREWATCH ROVES e CONCLUSION

- BASED ON THE ABOVE FACTORS, FIREWATCH ROVE DEFICIENCIES HAVE MINIMAL SAFETY SIGNIFICANCE 93EC137

I l

FIREWATCH PROGRAM

'1 1

AUGUST 10,1990 ALLEGATIONS I

l l

l ALLEGATIONS FORWARDED TO PSE&G BY NRC I-l e 7/18/90 i

j

- HOURLY PATROL OF ZONE 1B MISSED BY 17 MINUTES l

- SUPERVISOR KNEW AND INFORMED WATCH NOT TO l

WORRY

[

l

- ROVING LOG REDONE TO INDICATE ALL TOURS WERE i

. PERFORMED ON HOUR i

l e 6/1/90 t

- FIREWATCH FOUND ASLEEP ON POST AND TERMINATED

{

- ONE PATROL EXCEEDED ONE HOUR BY 20 MINUTES l.

- ROVING LOG REDONE TO INDICATE ALL TOURS WERE PERFORMED ON THE HOUR l

e AREA REQUIRING FIREWATCH WAS NOT ON ROUNDS SHEET (CLOSED BY NRC LETTER 7/2/92) l i

- BAILING STORAGE AREA NOT ON ROUNDS UNTIL INCIDENT REPORT IN 1989

- NOT PROPERLY REPORTED TO NRC

)

e THREE PTl EMPl.OYEES MAY HAVE KNOWLEDGE OF i

PROBLEMS 93EC1-18 i

1

ll l

i i

FIREWATCH PROGRAM i

l INVESTIGATION OF AUGUST 10,1990 ALLEGATIONS l

i I

i i

f e INITIALLY INVESTIGATED BY QUALITY ASSURANCE. NONE OF THE ALLEGATIONS WERE SUBSTANTIATED

- SUBMITTED TO NRC - 9/28/90

- REVIEWED SECURITY DOOR RECORDS AGAINST ROVE LOGS I

- PERFORMED DETAILED DOCUMENT REVIEWS

- INTERVIEW INVOLVED PTl AND PSE&G PERSONNEL

- ALL FIREWATCH ROVE REQUIREMENTS WERE MET l

e REINVESTIGATED BY CORPORATE SECURITY INVESTIGATOR IN SUMMER,1991. NONE OF THE ALLEGATIONS WERE SUBSTANTIATED

- SUBMITTED TO NRC 9/27/91 a

93EC1 15

g FIREWATCH PROGRAM INVESTIGATION OF AUGUST 10,1990 ALLEGATIONS

,e CORPORATE SECURITY INVESTIGATION - SUMMER 1991

  • 20 PEOPLE INTERVIEWED: ALL ASKED FOLLOWING

['

QUESTIONS l

- DO YOU HAVE KNOWLEDGE OF ANYONE FALSIFYING OR ALTERING OF THE ROVE FIREWATCH LOGS?

- DO YOU HAVE KNOWLEDGE OF ANYONE SLEEPING WHICH WAS COVERED UP?

- DO YOU HAVE KNOWLEDGE OF ANY NRC VIOLATIONS?

- DO YOU HAVE KNOWLEDGE OF ANY WRONG DOING BY ANY PSE&G OR OTHER CONTRACT EMPLOYEES?

- ARE THE SIGNATURES AND INITIALS ON THE FIREWATCH LOGS YOURS7 93EC138

l.

FIREWATCH PROGRAM INVESTIGATION OF AUGUST 10,1990 ALLEGATIONS e INCIDENTS IN ALLEGATIONS WERE APPROPRIATELY I

DOCUMENTED BY CONTRACTOR. CARD READER LOG REVIEWS CONFlRMED PEOPLE COVERING ROVE WERE IN AREAS NOTED ON LOGS ll e NONE OF THE ALLEGATIONS WERE ASSOCIATED WITH FIREWATCH PERSONNEL SYSTEMATICALLY SKIPPING POSTS AND SUBSEQUENTLY. FALSIFYING LOGS TO INDICATE COMPLETING POSTS

{

e CORPORATE SECURITY INVESTIGATION INTO JULY 1,1992 INCIDENT FOUND NO TIES TO 1990 ALLEGATIONS

.i e PSE&G MAINTAINS THAT THE ALLEGATIONS WERE NOT SUBSTANTIATED AND WOULD NOT HAVE REASONABLY PROVIDED AN OPPORTUNITY TO IDENTIFY THIS CONCERN e3EC140 n

v

-vr--

T r

l FIREWATCH PROGRAM l

ASSESSMENT OF BROADER IMPLICATIONS I

[

l l

e QA SURVElLLANCE OF EQUIPMENT OPERATOR ROUNDS

- MARCH - APRIL,1992 PERFORMED RANDOM HISTORICAL CHECKS

[

- NO EVIDENCE OF MISSED ROUNDS OR FALSIFIED LOGS l

e QA SURVElLLANCE AND SPOT CHECKS - CURRENTLY BEING PERFORMED QUARTERLY

['

- FIREWATCHES

- EQUIPMENT OPERATORS

- SECURITY WATCHES

- NO EVIDENCE OF MISSED ROUNDS OR FALSIFIED LOGS

[:.

e NO EVIDENCE OF BROADER IMPLICATIONS 93EC129 L

1

Il FIREWATCH PROGRAM CONTROL OF CONTRACTORS i

I

[

e ALL CONTRACTORS ARE ACCOUNTABLE TO A DESIGNATED PSE&G EMPLOYEE e NEW NUCLEAR DEPT. ADMINISTRATIVE PROCEDURE

- NAP-68, " CONTROL OF ON-SITE CONTRACTOR

[

PERSONNEL"

- SPECIFIES REQUIRED CONTRACTOR TRAINING FOR EACH CONTRACT

- lSSUED JUNE 1,1992 I

e CONTRACTOR CONTROL TRA!NING

- EMPHASIS ON PERFORMANCE EXPECTATIONS AND ACCOUNTABILITY

- COMPLETED AUGUST 3 - SEPTEMBER 12,1992 2

e CONTRACTS CONTAIN WORK STANDARD REQUIREMENTS e IMPROVING TREND IN PERFORMANCE t

93EC135

I f

FIREWATCH PROGRAM REGULATORY ASSESSMENT I

[

  • PSE&G DOES NOT DISPUTE THE VIOLATION e MINIMAL SAFETY SIGNIFICANCE f.
  • SEVERAL MITIGATION FACTORS APPLY

- SELF IDENTIFIED

- THREE PROMPT, INDEPENDENT, PROACTIVE AND

{

i COMPREHENSIVE INVESTIGATIONS

- COMPREHENSIVE AND PROMPT CORRECTIVE ACTIONS

- PROMPT NOTIFICATION OF NRC

- FALSIFICATION OF LOGS ISSUE ISOLATED TO d-FIREWATCHES

- 1990 ALLEGATIONS WOULD NOT HAVE PROVIDED AN OPPORTUNITY TO IDENTIFY

\\

l l

e PSE&G BELIEVES THAT ESCALATED ENFORCEMENT SHOULD NOT BE APPLIED TO THIS ISSUE 93EC1 13 t

1

I'

.c

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FIREWATCH PROGRAM

SUMMARY

  • THREE PROMPT, INDEPENDENT, PROACTIVE AND COMPREHENSIVE INVESTIGATIONS
  • 1990 ALLEGATIONS WOULD NOT HAVE PROVIDED AN OPPORTUNITY TO IDENTIFY e COMPREHENSIVE CORRECTIVE ACTIONS e DEMONSTRATED COMMITMENT TO STRONG FIRE

. PROTECTION PROGRAM - VIEWED AS AN INDUSTRY LEADER e MINIMAL SAFETY SIGNIFICANCE

  • RECOGNIZED SAFETY CULTURE e ESCALATED ENFORCEMENT NOT WARRAP3TED S3EC1 14

.