321 Barr Ave., Linwood NJ 08221




Date: 10/20/03


To: Nils J. Diaz, Chairman, Nuclear Regulatory Commission


Dear Chairman Diaz,


   On behalf of the 109 organizations that comprise the UNPLUG Salem Campaign, I am sending you this letter. This letter is a request to the Nuclear Regulatory Commission to suspend issuance of any license amendment requests at PSEG’s three nuclear plants at Artificial Island: Salem Units One and Two, and Hope Creek. This halt should stay in place until an NRC inspection verifies adequate correction of chronic human performance problems at the Island. This request is due to PSEG’s apparent inability to change the safety culture at its three plants. This deficiency in safety culture is indicated by the NRC’s repeated findings of human performance, problem identification and resolution cross - cutting  issues.

     A short list of documents in ADAMS that demonstrate these continuing human performance/safety culture cross- cutting issues include, but are not limited to: ML022140463, 2002-08-02; ML032240699, 2003-08-12; ML031320802, 2003-05-12; ML030620693, 2003-03-03; ML032390511, 2003-08-27; ML031330793 2003-05-13; ML022140114 2002-08-01; and ML032130232 2003-08-01,

     In reality these human error/safety culture issues have been a challenge unsuccessfully met by PSEG for many years.  In July of 2001, Dave Lochbaum, nuclear safety engineer for the Union of Concerned Scientists documented an unusually high number of human error/safety culture errors at the Hope Creek and Salem Nuclear Plants.  (Lochbaum’s letter is attached to this document.)

   At the last four inspection exit meetings, PSEG has continued to pledge to fix their human error problems. Even at the re-start hearings for Salem Units One and Two in 1997 and 1998, PSEG acknowledged problems with their safety culture and vowed to fix them.  Clearly, PSEG has not fixed these problems. PSEG’s promises may be sincere, but their efforts to date have not yielded tangible improvements in human performance. By refraining from approving license amendments until PSEG has replaced promises with progress, the NRC will (a) provide PSEG with the incentives it apparently lacks on its own to fix this chronic safety problem and (b) remind the public and plant workers that the NRC cares about their safety.

   We feel that this action is necessary and prudent. Many of the license amendment requests sought by PSEG reduce the testing and inspection intervals for important safety equipment at the Island. Obviously, the justification for such reductions is lacking when there are chronic human performance problems.

    This request is being made in light of the debacles at Davis Besse, in which poor safety culture was a major contributor to a near-miss Loss Of Cooling Accident, and at Indian Point, where the NRC allowed Indian Point to continue to operate with defective steam generators. To avoid another major problem from occurring, it seems to the UNPLUG Salem Campaign that the NRC must take the extra steps necessary at all nuclear plants, including the three at Artificial Island, to make sure that safety culture at these plants is working. Therefore our suggestion is a quite reasonable one, and one that the NRC should have already adopted.

   The NRC is free to characterize this letter as a 2.206 petition, if applicable.






                                                                                                            Norm Cohen


                                                                                                            UNPLUG Salem Campaign   

Attachment 2: salem usc (application/pdf)