ML062210180

Allegation Review Board Disposition Record

ML062210180
Person / Time
Site:	Salem, Hope Creek
Issue date:	01/29/2004
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2005-0194, RI-2003-A-0110
Download: ML062210180 (9)

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G:\ALLEG\PANEL\200301 1Oarb9.wpdALLEGATION REVIEW BOARD DISPOSITION RECORD Allegation No.: RI-2003-A-0110 Branch Chief (AOC): Meyer Site/Facility: Salem/Hope Creek Acknowledged: Yes ARB Date: 01/29/2004 Confidentiality Granted: No Issue discussed: Current Actions on Tech Issues and SCWE Alleger contacted prior to referral to licensee? Issue will not be referred to licensee until NRC has completed an interim review that adequately assesses the work environment at the station.

AlLI EfATION RE:VIE:W BOARD DECISIONS ALLEGATION REVIEW B ARD DECISIONS Attendees: Chair - Blough Branch Chief (AOC) - Meyer SAC - Vito 01 Rep. - Neff, Wilson RI Counsel - Farrar Others - Barber, Holody. Wingqfield, Crleniak DISPOSITION ACTIONS:

1)

( Responsible Person: Wilson Closure Documentation:

ECD:

Completed:

TBD

ý76

2) DRP to modify drafted violation(s) per ARB discussion and provide to Regional Counsel, 01 and SAC.

Responsible Person: Barber ECD: 216/04 Closure Documentation: Completed:

3) DRP to compare depth of surveys at PSEG with those some other utilities such as Susquehanna. Provide documentation of results to SAC and 01 for file.

Responsible Person: Meyer ECD: 2/18/2004 Closure Documentation: Completed:

4) Perform an interim assessment of the Salem and Hope Creek interviews completed to determine whether additional NRC action is needed to address work environment concerns. Consider Issuance of a letter describing the work environment issues identified to date and request PSEG review and assessment.

Responsible Person: All ECD: 1/29/04 Closure Documentation: Letter to Licensee Completed: 1/28/2004 Information Inthis record was deleted in accordance with the Freedom of Iffforfmti~.D Act, exemptions - ,2_:_

ARB MINUTES ARE REVIEWED AND APPROVED AT THE ARBI* /

2

5) Continue the interviews of the ey Hope Creek operations staff and shift manager-W Upon completion of these interiews determine which additional licensee staff and management interviews are needed to confirm our interim assessment; better develop identified technical issues, identify new issues; investigate potential area of discrimination; and identify potential wrongdoing issues for referral to 01.

Responsible Person: Barber/Neff ECD: TBD Closure Documentation: Completed:

6) Upon completion of the additional interviews reconvene as needed to determine need for additional correspondence (beyond 1/28104 letter) or other actions.

Responsible Person: All ECD: TBD Closure Documentation: Completed:

7) DRPIDRS to continue review of interview transcripts and provide summaries in terms of safety culture/SCWE and technical issues.

Responsible Person: Blouah/Lanning ECD: Ongoina Closure Documentation: Completed:

8) DRP will continue to update the summary of technical issues on weekly basis considering information from additional information from interviews, and information from review of transcripts of completed interviews. DRS has completed review of TARP reports and NRB documentation and will discuss at the next ARB panel.

DRPIDRS to assess.

Responsible Person: Meyer ECD: Oncqoincq Closure Documentation: Completed:

9) After receipt of the licensee assessment plan in response to our 1/28/04 letter, repanel to determine whether or not to provide the licensee additional detailed information on events reflected or SCWE.

Responsible Person: Panel ECD: 3/4/04 Closure Documentation: Completed:

10) Repanel the listing of attributes/behaviors developed by the SAC as being representative of a good safety culture/SCWE, to be used as a point of comparison for outcomes of the SCWE review, and possibly considering how other events/activities/inspection findings at the site feed into that comparison.

Responsible Person: SAC ECD: TBD Closure Documentation: Completed: 1/29/04

11) Next periodic ARB Responsible Person: SAC ECD: 2/1812004 0 10:00 Closure Documentation: Completed:

SAFETY SIGNIFICANCE ASSESSMENT: SCWE Review ARB MINUTES ARE REVIEWED AND APPROVED AT THE ARB

3 PRIORITY OF 01 INVESTIGATION: High If potential discrimination or wrongdoing and Of is not opening a case, provide rationale here (e.g., no prima facie, lack of specific indication of wrongdoing):

Rationale used to defer 01 discrimination case (DOL case in progress):

ENFORCEMENT STATUTE OF LIMITATIONS CONSIDERATION (only applies to wrongdoing matters (including discrimination issues) that are under Investigation by 01, DOL, or DOJ):

What is the potential violation and regulatory requirement?

When did the potential violation occur?

(Assign action to determine date, if unknown)

Once date of potential violation is established. SAC will assign AMS action to have another ARB at four (4) years from that date, to discuss enforcement statute of limitations issues.

NOTES: (Include other pertinent comments. Also include considerations related to licensee referral, if appropriate. Identify any potential generic issues)

Next ARB will include a discussion of suggestions for binning inputs related to SCWE (e.g.,

management production vs. safety pressure, non-conservative decision making, union pressures to suppress concerns identification, etc.) And how that will feed into the overall SCWE assessment.

Distribution: Panel Attendees, Regional Counsel, 01, Responsible Individuals (original to SAC)

ARB MINUTES ARE REVIEWED AND APPROVED AT THE ARB

BINNING OF SALE/HOPE CREEK SCWE ISSUES The objective of tis binning Is to establsh the preliminary significance of Issues that have been raised from a Salem/Hope Creek allegation (fall 2003) or that were IdentiFied during interviews conducted to assess this allegation.

The categories are ranked in decreasing order of safety signiflcance.

PERCEIVED LACK OF FREEDOM TO RAISE SAFETY CONCERNS TO PSEG MANAGEMENT

• Environment believed to be intentionally cumbersome to disourage the identification and resolution of issues o 0/22/03, p. 20 0 Manage lntis percýved as responding negatively when issues are raised (types of 'negative' responses:

Inequitab e distribution of work, negative performance appraisals, withholding of pay raises, etc.)

o024/03, p.20, 23 & 47 o 11/7/03, p. 26- 31 PRODUCTION OVER ESAF ISSUES authrzaton from the C Room ... This was contrary to the Operating shift's Intent to take & Main turbine offline to address a 20 foot steam plume from the affected valve ... Could be considered a violation of the Conduct of Operations procedure which prohibits operation of equipment without the operating shift's o v2303, p. 56- S8 o 11/7/03, p. 14 & 15 The 24 tm Generator Feed Regulating Valve (FRV), 248F19, failed to respond ... The NC0s, and at least one Senior Reactor Operator (SRO) , on shift believed the valve was mechanically bound ... Management didn't want to declare the valve mechanically bound and therefore Inoperable because that would require a Urniting Condition for Operation (LOD) 3.0.3. shutdown ... Management elected to pursue a controls failure

.. Shutdowndeiayedforabout36hours 0 A *~jkj 03, p. 7 - 29 o ,11/7/03, p. 16 & 17

• The operations department operates outside of established processes 0.e. cleaning condenser waterboxes) because of a 'just fix It and the unit(s) back up to full power' mentality ... An AOM used a metal bar to pry a Circulating Water Pump breaker Into its cubide In fadlitation of a rapid return of the pump to support return to full power o iM '22/03, p. 25 - 31, 33 - 37 Overheard a memb6r of Operations Management saying that he did not receive a raise at the end of 2003 after numerous Instances of voidng an opinion in contrast to the 'production mentality' ... its built Into their compensation package o A0/22/03, p. 23 & 47 Made an emergent change to the plant startup procedure to remove the resrction that the steam dumps be operated In automatic... Conducted emergent training to extra NOOs and required them tocontrol Reactor temperature and pressure (which affects reactivity) In manual Instead of fixing the system to operate In automatic as designed

~0/23/03, p. 40 - 48 Main Ste6m Isolation Valves (MS[Vs) were opened late during the startup following the 'huricane-salting' shutdown 0 0/23/03, p. 32 - 40

• They have had NEOs operating the components required to synchronize and load the Emergency Diesel SASalem-HC SCWESalem4iC Alleg BInnIng.wpd Page I of 7 January 29, 2004 (9:1 SAM)

BINNING OF SALEMIHOPE CREEK SCWE ISSUES The objective of hiUs binning Is to establish the preliminary significance of Issues that have been raised from a Salem/Hope Creek allegation (fal 2003) or that were Identified during Interviews conducted to assess this allegation.

The categories are ranked in decreasing order of safety significance.

-ci '-' Miu'I Is o0 1022/03, p. 32 & 33 "Mem rsof°magement doing union employee work.. " M*nipula

• ... AOM using a metal bar to pry a Circulating Water Pump breake-r in~toits c~ubice ... AOH mra~nipulating a Pressurizer valve,... Ops Supervisor manipulating an instrument nitrogen system pressure controller 0 10/22/03, p. 25 - 31 o 12O3/03, p. 55, 56- 58,59,60- 65 INDUSTRIAL SAFETY ISSUES

• A imbed to an elevated Main Feedwater Pump Steam Isolation Valve without authorization from or notification of the Control Room to dose it toIsolate a 20 foot steam plume 0g 0/23/03, p. 56 - 58 0 sed a metal bar to pry a irculating Water Pump breaker into Its energized cubide 0 .1/22/03, p. 25 - 31, 33 - 37 o" O0/23/03, i p. 59 &60 Had to threaten %Ainvolvement to affect resolution on a fan with exposed fan blades o 110122/03, p. 18 S:ASalem-l-C SCWESalem-tHC Afteg Binnlng.wpd Page 3 of 7 January 29, 20G4 (9:11 SAM)

4 BINNING OF SALEMIHOPE CREEK SCWE ISSUES The objective of this binning is to estabsh the premnay slgnificance of Issues that have been raised from a Salem/-ope Creek allegation (fad 2003) or that were identified during intervews conducted to assess this allegation.

The categories are ranked In decreasing order of safety significance.

W"VVIA PERCEIVED LACK OF FREEDOM TO RAISE SAFETY CONCERNS TO PSEG MANAGEMENT

• Not observed yet AN personnel Interviewed that they would not hesitate to raise a safety concern to management even though managements reaction may be to shoot the messenger.

PRODUCTION OVER SAFETY ISSUES

• An AOM.

0 SCHEDULE PRESSURE ISSUES

• During.

LABOR - MANAGEMENT ISSUES 0 Union.

INDUSTRIAL SAFETY ISSUES

• " During the recent Salern Unit 2 outage, a SW valve was stroked to allow system fill prior to setting the torque and limit switches. This was done to save time on the outage schedule. The valve destroyed itself when stroked remotely. Gould have caused serious personnel Injury If someone had been In the vidnity atthe time of the failure..

o j M 12/23103, p. 37 - 39 Si'atem-HC SCWENSalem-IC Alleg Blnnlng.wpd Page 5 of 7 January 29, 2004 (9:18SAM)

BINNING OF SALEMIHOPE CREEK SCWE ISSUES The objective of Uls binning Is to establish the prerminary significance of issues that have been raised from a SalemI-Hope Creek allegation (fall 2003) or that were Identified during Interviews conducted to assess this allegation.

The categouies are ranked In decreasing order of safety significance.

0 '... I get the Impression that [workers] really dont care anymore. They're fed up with the five-year management teams coming In shaking up the world, changing policies and philosophies, and [the workers]

feel as though they're not listened to ... (across the board]"

0 41 p. 5 0 Threats and Intimidation used against an Individual for responding to a request by a shift manager o ;11/13/03, p. 10 - 14 0 Incdlcatioh of the disorganization within management - An individual had, simultaneously, 2 supervisors, 3 other people who give him direction ... Another person (whom he had never received any direction from) gave him his annual performance review (the written evaluation of which written by the person being evaluated) -

o 1 /13/03, p. 30 &31 INDUSTRIAL SAFETY ISSUES Restart pressure exerted to fix a valve by flashlight vs. correcting the lighting deficiency ... the situation was eventually resolved by using temporary lighting o j0/2l03, p. 53 - 60, 64 - 65 S During therecent Salem Unt 2 outage, a SWvalve wasstroked to allow system fill pdortosetting thetorque and Emit switches. This was done to save time on the outage schedule. The valve destroyed Itself when stroked remotely. Could have caused serious personnel injury if someone had been In the vicinity at the time of the failure.

0 A1/13/03, p.42 S:*Salem-4C SCWMESalem-HC Alleg Blnnlng.wpd Page 7 of 7 January 29, 2004 (9:1 SAM)

I Salem/Hope Creek Allegatiori Background/Chronology A* /jj Issue/Event Date Description Jan. 28!, 2004 Issued a asignificant letter" to PSEG providing them with Interim results of our ongoing SCWE review (they have until February 27h to respond with an action plan).

Jan. 28', 2004 Interviews conducted Jan. r" and Jan. 28 Dec. 31I, 2003 Interviews conducted Dec. 2" and Dec. 3 1 14 Ii k I I

I Nov. 13, 2003 5"' ARB Nov. 12", 2003 Interviews conducted Nov. 12" and Nov. 131' N Nov. 7r, 2003 4W1 ARB Nov. 4', 2003 Interviews conducted Nov. 4' throuQh Nov. 7" I

I Oct. 28', 2003 3W' ARB Oct. 24', 2003 Interviews conducted Oct. 24 throuqh Oct.29" Oct. 23ý,2003 Interviews conducted on Oct. 23"'

Rev. Date: 1V29a04 Page I of 4

Salem/Hope Creek Allegation BackgroundlChronology 1 I Issue/Event Date Descridption March 17", 2003 1. Hope Creek Reactivity Event - Manipulation of Electro Hydraulic Control (EHC) system caused an unanticipated rise In reactor power 6 % % to 13 % ... not discovered until Wednesday (3119/03).

2. Entering a planned shutdown to repalr 3 technlcaVmechanical failures (late Sunday/early Monday morning).

3. Monday morning (0800) rb* ass Valve u)c%). TBV closed fully during subsequent testing. rgued with Pjout whether or not a shut down was required. e concerm here was betwe d his partment heads. He apparently "harassed" (from Interviews witht"an them for 4hours on why a shutdown to repair the TBV was ,when all of theepartment heads believed that shutting down was a "no brainern. Although non-conservative decision making Is a possible root cause, there was no TS violation.

4. Heated discussions about the duration of the forced outage.

Mar. 28h, 2003 Alleger's last day on site (employment officially terminated this date).

Allq r told . . ... .* * . _. .. eo -

Mar. 26', 2003 111Oitanted the alleger "out by Fa-y" (March 28i, 3).

Mar. 25". 2003 Alleger submitted letter to CEO reiterating work environment concerns and describing the alleged retaliatory actions.

Feb. 261, 2003 Alleger met wl o purportedly discuss [the] bonus. But, after discussing concerns about the work environment it Artificial Island, the alleger was infor.,Mdof future termination (originally planned for April 16). Itwas also alleged that n directed that the termination be 'accelerated."

Nov. 2002 Higher Tritium sample concentration In Spring 2003 -; us issue that had to be handled with kid gloves to keep us [PSEGI out of troublem'qUNW Fall 2002 Mana gr a..I an o NA a startup checklist step.

t.o havefired but was unsupcssfuL Inormation received Indicates this alleged activity may have actaaly occurred whedee= = A "NA" a surveillance step for the Reactor Vessel Ven vlves pn a single valve indicated dual Indication during this routine stroking evolution. 1Njm was allegedly told by the Operation Crew that they would not "NA" the step. Ea*ier Information from Interviews suggested that the concern involved NA-Ing" a second verification containment walkdown to be done by a VP-OPS level person step. This step was a o the SU procedure as a lessons learned from the Davis-Besse Issue. According tItis walkdown was actually done by himself and nd startup was delad by a ay because of leaks that they found from some SG wet layup level Indication valves. So, the step was actually completed contrary to the alleger's assertion.

Sept 241, 2002 Based on the size and location of a significant steam eakrto u Le nnet of a Feed Water Pump steam admission valve), the to affect re jairs agreed with the shift operators that the plant shoul be shut down left to speak with "upper management and, upon his return su ent,_

tngi*Jwhich Isolated the steam leak avoiding a shut down. CLP confidential report substantiates allegation, Third Step Grieva without regard to his own personal safety, without a Nuclear ulpment Operator (NEO),

and without the permlsslorkflnowledge of control room personnel).

Rev. Date: 1129/04 Page 3 of 4