LR-N06-0419, PSEG Letter Dtd 10/31/2006 to Mr. Collins Reference Status of Safety Conscious Work Environment Commitments at Salem and Hope Creek Stations

PSEG Letter Dtd 10/31/2006 to Mr. Collins Reference Status of Safety Conscious Work Environment Commitments at Salem and Hope Creek Stations

ML063350400
Person / Time
Site:	Salem, Hope Creek
Issue date:	10/31/2006
From:	Levis W Public Service Enterprise Group
To:	Collins S Region 1 Administrator
References
LR-N06-0419
Download: ML063350400 (6)

Text

William Levis PSEG Nuclear LLC Senior Vice President and CNO EO. Box 236, Hancocks Bridge. N J 08038 tel: 856.339.1100 fax: 856 339.1104 ocr 3 I. zoo6 LR-N06-0419 Mr. Samuel J. Collins Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Hope Creek Generating Station Facility Operating License No. NPF-57 Docket No. 50-354 Salem Nuclear Generating Station, Unit luas.1 nc, 2 Facility Operating Licenses DPR-70 And DPR-75 NRC Docket Nos. 50-272 and 50-31 1

Subject:

Status Of Safety Conscious Work Environment Commitments References : 1. Letter from A. C. Bakken (PSEG Nuclear LLC ) to H. J. Miller (U.S. NRC), PSEG Plan for Improving the Work Environment, dated June 25,2004

2. Letter from H. J. Miller (U.S. NRC) to E. J. Ferland (Public Service Enterprise Group), Work Environment at the Salem and Hope Creek Generating Stations, dated July 30, 2004

3. Letter from S. J. Collins (U.S. NRC) to W. Levis (PSEG Nuclear LLC), Mid-cycle Performance Review and Inspection Plan -

Salem Nuclear Generating Station, dated August 31, 2006

4. Letter from S. J. Collins (U.S. NRC) to W. Levis (PSEG Nuclear LLC), Mid-cycle Performance Review and Inspection Plan -

Hope Creek Nuclear Generating Station, dated August 31, 2006

OCT 3 1 2006 Page 2

Dear Mr. Collins:

This letter provides the status of commitments made by PSEG Nuclear LLC (PSEG) to the NRC regarding the safety conscious work environment (SCWE) at Salem and Hope Creek Generating Stations.

Backqround In 2004, the NRC identified concerns with the environment for raising and addressing safety issues at the Salem and Hope Creek Generating Stations. In-depth assessments were conducted into these matters and actions were established to address the identified concerns. Commitments were also made to the NRC (references 1 and 2) that supported continued NRC oversight of our improvement efforts. Subsequently, a substantive cross-cutting issue in SCWE was identified at both stations during the 2004 NRC mid-cycle performance reviews.

A comprehensive set of work environment improvement actions were subsequently implemented. As a result, plant and personnel performance improved. These changes were evident through improved safety system performance, more effective execution of the Corrective Action and Work Management programs, and a realignment of the organization with an operational focus. Collectively, the improvement efforts resulted in substantial and sustainable changes in the work environment at the stations. A peer assessment team as well as an NRC inspection team independently examined the work environment at Salem and Hope Creek Generating Stations and confirmed that substantial and sustainable changes had been achieved. During the 2006 NRC mid-cycle performance reviews, the substantive SCWE cross-cutting issue for each station was closed (reference 3 and 4).

Commitment Status PSEG made several commitments to the NRC related to SCWE. The text of the commitment is provided, along with its current status.

1. We will conduct the next cultural survey after the Hope Creek refueling outage, which is scheduled for fall of 2004. (reference 1 )

This commitment is met. Following the 2004 Hope Creek refueling outage, a cultural survey was administered at PSEG between January 24, 2005 and February 4,2005. PSEG letter LR-N05-0239, dated April 29, 2005, provided metrics data from the cultural survey to the NRC.

2. We will periodically resurvey our organization during the next four years thereafter.

(reference 1)

This commitment will remain open until February 28, 2009. PSEG completed cultural surveys in February 2005 and February 2006. PSEG is considering this an open commitment to the NRC, which will extend four years from the cultural survey

OCT 3 1 2006 Page 3 that ended in February 2005. PSEG will continue to meet this commitment by performing a cultural survey on a periodic basis to monitor the work environment at the Salem and Hope Creek Generating Stations until February 28, 2009.

3. After we and the NRC have analyzed the results of the 2004 survey, we plan to meet with you at a public meeting. We anticipate this meeting would occur during the second quarter of 2005. (reference 1)

This commitment is met. A cultural survey was administered between January 24, 2005 and February 4,2005. PSEG letter LR-N05-0239, dated April 29,2005, provided metrics data from the cultural survey to the NRC. The results were discussed in a public meeting between PSEG and the NRC that was held on June 8, 2005.

4. The following metrics will be implemented, monitored, and published quarterly to objectively measure the effectiveness of the above-described Safety Conscious Work Environment improvements at Salem and Hope Creek. We may need to modify these metrics in order to meet a future need for performance monitoring. If that need arises we will notify the NRC of the change and the basis for the change.

The metrics are as follow: (reference 1)

I . Survey Results of Employees Perception of Management Commitment

2. Executive Review Board Action Approvals Without Comment

3. Survey Results of Employees Perception of Supervisor Communication Effectiveness

4. ECP Concerns ConfidentialitylAnonymity Request

5. Survey Results of Trust Between Management and Employees

6. Total Notifications Generated

7. Nuclear Condition Reports (NUCRs) Operations Overdue

8. Open NUCR Evaluations with Due Date Extensions

9. Repeat Nuclear Safety Related Notifications

10. Safety System Unavailability

11. Unplanned Limiting Condition of Operation (LCO) Entries

12. Unplanned Operational Challenges

13. SCWE Management Training Completion

14. Knowledge of Alternate Avenues

15. Corrective Maintenance Backlog

16. Elective Maintenance Backlog

17. Corrective Action Problem Resolution This commitment is met. On a quarterly basis, PSEG provided SCWE metrics to the NRC and any modifications and the bases for the changes until closure of the substantive cross-cutting SCWE issue at each stations NRC mid-cycle performance review (reference 3 and 4). The SCWE metrics submittals were made as follows:

Third Quarter 2004 PSEG letter LR-N04-0481, dated October 29,2004 Fourth Quarter 2004 PSEG letter LR-N05-0045, dated January 31,2005 First Quarter 2005 PSEG letter LR-N05-0239, dated April 29,2005 Second Quarter 2005 PSEG letter LR-N05-0379, dated July 29,2005

OCT 3 1 2006 Page 4 Third Quarter 2005 PSEG letter LR-NO5-0536, dated October 31, 2005 Fourth Quarter 2005 PSEG letter LR-N06-0046, dated January 31,2006 First Quarter 2006 PSEG letter LR-N06-0179, dated April 28, 2006 Second Quarter 2006 PSEG letter LR-N06-0301, dated July 27,2006 These metrics provided the NRC with a method to periodically monitor improvements in the work environment. The NRC closed the SCWE substantive cross-cutting issue for both stations and returned the stations to a normal level of NRC oversight (references 3 and 4). With the return to normal NRC oversight, PSEG considers this commitment completed and does not plan to continue submitting quarterly metrics to the NRC. PSEG will continue to monitor its performance in the areas of Work Management, Corrective Action Program, and Safety Conscious Work Environment to ensure that continued improvement occurs in the work environment at the Salem and Hope Creek Generating Stations.

5. Meet with the NRC in late 2004 to discuss your overall progress in improving the work environment. In addition, you will also cover the following topics: (a) role and function of QA; (b) procedure adherence and other elements of human performance; and (c) quality of engineering products particularly as they relate to evaluation of degraded equipment and associated operational decision making. (reference 2)

This commitment is met. On December 2,2004, a public meeting was held between PSEG and the NRC with an agenda that included a Quality Assurance update, a Human Performance update, and a discussion of engineering support of operational decision-making.

6. Subsequent meetings, including the meeting in early 2005 to which you had already committed, will continue periodically until PSEG has made substantial, sustainable progress in improving the work environment. (reference 2)

This commitment is met. PSEGs progress in improving the work environment was discussed in public meetings with the NRC on the following dates: June 8, 2005; November 17, 2005; and May 17,2006. During the 2006 NRC mid-cycle performance reviews, the NRC confirmed that there has been substantial and sustained progress in improving the SCWE (references 3 and 4). Therefore, no further meetings are required.

7. Include in your quarterly submittals a brief description of any significant changes to your action plan. (reference 2)

This commitment is met. Any significant changes to the action plan were included in the quarterly SCWE metrics submittals, such as the replacement of the People Team with the Executive Protocol Group (reference PSEG letter LR-N05-0379, dated July 29, 2005). The action plan was subsequently completed and the NRC informed of this status by letter LR-N06-0046, dated January 31, 2006. Closure of the action plan completed this commitment. PSEG continues to improve its procedures, processes and programs. Future changes to the programs established to improve the work environment will not be reported to the NRC.

OCT 3 1 2006 Page 5

8. At a point when you believe you have made substantial progress in addressing work environment, corrective action, and work management issues at the Stations, obtain a peer assessment to evaluate the effectiveness of your efforts and provide the results to NRC. (reference 2)

This commitment is met. By letter LR-NO6-0179, dated April 28, 2006, PSEG informed the NRC that substantial and sustainable progress had been made in addressing work environment, corrective action, and work management issues at the stations. This letter stated that PSEG commissioned an independent assessment of the work environment with the final report to be provided under a separate letter. On May 4,2006, PSEG submitted the Peer Assessment report under letter LR-N06-0216.

Conclusion In response to NRC concerns with the work environment at Salem and Hope Creek Generating Stations, PSEG established a comprehensive set of actions to improve its performance. The NRC established additional oversight to monitor our progress. The commitments cited above were established to facilitate this additional oversight.

PSEG implemented numerous actions to substantially improve plant and personnel performance, processes, and programs in order to achieve a healthy work environment.

The resultant changes are evident in the improved morale, teamwork, communications, and alignment of our staff. Though the stations have returned to normal NRC oversight, our efforts will remain on continuously improving our performance.

If you have any questions regarding this submittal, please contact me at (856) 339-1100.

Sincerely, /?

OCT 3 1 2006 Page 6 C USNRC Document Control Desk Washington, DC 20555 Mr. S. Bailey, Project Manager Salem & Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B2 11555 Rockville Pike Rockville, MD 20852 USNRC Senior Resident Inspector - Hope Creek (X24)

USNRC Senior Resident Inspector - Salem (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 086