ML20058E495

Notice of Violation from Insp on 900928.Violation Noted: Licensee Did Not Perform Radiation & Airborne Surveys Before Allowing Special Svcs Licensed Operator to Enter Hot Svc Facility to Remove Five Unshielded Radioactive Samples

ML20058E495
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/30/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058E476	List: IR 05000267/1990016 ML20058E495
References
50-267-90-16, EA-90-174, NUDOCS 9011070192
Download: ML20058E495 (38)

Text

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ENCLOSURE 1 b\\

NOTICE OF VIOLATION Public~ Service Company-of Colorado Docket No. 50-267

. Fort St. Vrein Nuclear Generating Station License No. DPR-34 EA 90-174 During.an NRC inspection conducted on September 28, 1990, violations of NRC i

requirements were identified.

In accordance with the " General Statement of 4

Policy and Procedure for. NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990),theviolationserelistedbelow:

A.

Surveys.

'10' CFR Part 20.201(b) requires that each licensee shall make or cause to' be made,such surveys as may be necessary'to evaluate the extent of radiation hazards that may be present.

Contrary to'the above, on September 19, 1990, the licensee did not perform I

radiation and airborne surveys before, allowing a Special Services Licensed R

-Operator (SSLO) to enter the Hot Service Facility (HSF) to remove five-unshielded radioactive samples. Subsequent surveys performed on i

September 20,-1990, revealed that the samples had contact radiation levels i

of,about'65 Rads /hr.

This.is a Severity Level IV violation.

(SupplementIV)(267/9016-01)

B.

Procedures.

FortSt.Vrain(FSV) Technical-Specification 7.4.'d.statesthat

" Procedures for personnel radiation protection shall be prepared-consistent with the requirements of.10 CFR Part 20, and shall be approved, maintained, and. adhered to for all operations involving personnel radiation exposure."

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FSV Procedure HPP-125. titled " Establishing and Posting Controlled Areas,"

Section 4.3, " Hot Service Facility Control," Subsection 4.3.5 states:

" Write a Radiation Work Permit (RWP) for the job to be performed in the HSF."

FSV Procedure NPAP-10 titled " Radiation Work Permit Program,"

Section 3.2.2 states that *A special RWP.is normally issued for a specific task for a period of time not to exceed I week."

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Procedure NPAP-10, Section 4.2.3 stated that."During work in an area

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' controlled by.an RWP, health physics personnel shall:

(b) conduct L.

radiation, contamination, and airborne radioactive surveys as necessary to determine changing radiological conditions."

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Contrary to the above, an adequate specific RWP was not issued to cover the collection and removal of five radioactive samples from the HSF on September 19, 1990. The RWP used for the job, RWP No. 11377 titled,

" Manipulator Testing and Modify RCD" did not reference any sample collection or removal activities.

For example, RWP No. 11377 did not 3,

include radiation levels, continuous health physics coverage, extremity monitoring, respiratory protection equipment, or special instructions for handling the radioactive samples, f

This is a Severity Level IV violation.

(SupplementIV)(267/9016-02)

C.

Instructions to Workers 10 CFR Part 19.12 requires that individuals working in a restricted area shall be kept informed of radioactive material ir, the restricted area and 1

shall be instructed in precautions or procedures to minimize exposure.

. Contrary to the above, the SSLO that collected and removed five unshielded radioactive samples from the HSF on September 19, 1990, was not informed that the samples had contact radiation. levels of up to about 65 Rads /hr nor did the SSLO receive special instructions on proper procedures for handling the samples.

- This is a Severity Level IV violation.

(SupplementIV)(267/9016-03) 3-D.

Radioactive Materials Containers 10 CFR Part 20.203(f)(2) requires that each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents. The label shall also provide sufficient information to permit individuals handling or working in the vicinity to take precautions to avoid or minimize exposure.

r FSV Procedure HPP-630, " Radioactive Material Control and Handling,"

1 states:.

Section 4.3.1, " Identify all radioactive material, or their

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containers,withaRadioactiveMaterialsIdentification(RMI) Tag."

h Section 4.3.3, " Perform radiation and contamination surveys-inside and outside of the container or bag, as practicable."

Section 4.3.4

" Record information on the tag as necessary."

l Section 4.3.5, " Record information in Radioactive Material l

Accountability Log."

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Section.4.3.6 " Attach the hard copy of the tag to the material or container to be tagged."

1

. l Contrary to the above, tae five bags containing radioactive samples removed from the HSF on September 19, 1990, were not tagged or identified as containing. radioactive material.

This is a Severity Level IV violation.

(SupplementIV)(267/9016-04)

E.

Personnel Nonitoring 10 CFR Part 20.202 requires that each licensee shall supply appropriate personnel monitoring equipment to each individual who enters a restricted area under such circumstances that he is likely to receive a dose in any calendar quarter.in excess of 25 percent of the applicable value specified inparagraph(a)of10CFRpart20,101.

Contrary to the above, on September 19, 1990, an SSLO collected and hand-carried five unshielded samples-in plastic bags, with contact radiation-levels of up to about 65 Rads /hr, from the HSF into the HSF access area without wearing-extremity monitoring devices.

This is a Severity Level IV violation.

(SupplementIV)(267/9016-05) pursuant to the provisions of 10 CFR 2.201, Public Service Company of Colorado is hereby required to' submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555'with a copy to the. Regional Administrator, Region IV, and if applicable, a copy to the NRC Resident Inspector,(within 30 days of the date of the letter transmitting this Notice of Violation Notice). This reply should

. be. clearly marked as a= " Reply to a Notice of ','iolation" and should include for each violation: -(1) the reason for the violation, or, if contested, the basis for disputing'the violation. (2) the corrective steps that have been taken and

- the results' achieved. (3) the corrective steps that will be taken to avoid further violations. and (4) the date when full compliance will be achieved.

If an adequate' reply is not received within the time specified in this Notice, an

' order may be, issued to show cause why the license-should not be modified, suspended,_ or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the

, response time.

DatedstArlingt)o/n,Texasthis g 4 cay ci g g 1990 y

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4 ENCLOSURE 2

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1 PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION ENFORCEMENT CONFERENCE OCTOBER 18, 1990 ARLINGTON, TEXAS f

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AGENDA

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INTRODUCTION AND OPENING REMARKS A. C. CRAWFORD l

REVIEW AND ANALYSIS OF RADIOLOGICAL F. J. BORST PROTECTION CONCERNS L

REVIEW OF ROOT CAUSE AND C. H. FULLER CORRECTIVE ACTIONS CONCLUSIONS A. C. CRAWFORD 1

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i INTRODUCTION AND OPENING REMARKS ~

PSC ACKNOWLEDGES THAT A PROBLEM EXISTb PSC RECOGNIZES THAT THE POTENTIAL FOR AN OVEREXPOSURE EXISTED PSC IS CONFIDENT THAT THE ROOT CAUSE HAS BEEN IDENTIFIED ACTIONS HAVE BEEN 'TAKEN, AND FURTHER ACTIONS ARE IN PROGRESS, TO CORRECT THE SITUATION AND PREVENT RECURRENCE PSC RECOGNIZES THE IMPORTANCE OF RADIOLOGICAL.

PROTECTION AS WE PROCEED WITH DEFUELING AND DECOMMISSIONING O

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1 INTRODUCTION AND OPENING REMARKS GENERAL TIMELINE OF THE EVENT 9/11/90 WORK BEGINS ON COLLECTING SAMPLES lN THE HOT SERVICE FACILITY 9/19/90 POTENTIAL OVEREXPOSURE EVENT OCCURS 9/20/90 HPES INVESTIGATION INITIATED PRELIMINARY DOSE ASSESSMENT COMPLETED 9/26/90 C'JNFERENCE CALL WITH SRI AND HEGION IV 9/28/90 ONSITE INSPECTION 10/3/90 PSC INFORMED OF ENFORCEMENT CONFERENCE 10/12/90 NRC INSPECTION-REPORT RECEIVED 10/18/90 ENFORCEMENT CONFERENCE t

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i SEQUENCE OF EVENTS REVIEWL OF SPECIFIC FINDINGS REVIEW 'OF PREVIOUS NRC CONCERNS

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SCOPE OF WORK OBJECTIVE SURVEY THE RCD AND THE MCRBs OBTAIN TWO SAMPLES (METAL-SHAVINGS) EACH FROM ONE REGION CONSTRAINT DEVICE. (RCD)

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TO BE USED FOR 10CFR61 ANALYSES H

CONTROL OF WORK PERFORM A " DRY. RUN" OF THE DRILLING-PRIOR TO ACTUAL SAMPLING i

SURVEYS ' AND. SAMPLING WOULD BE

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IN-THE HSF

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WHILE ELEMENTS WERE IN THE HSF USE EXISTING EQUIPMENT

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TAKE RADIATION READINGS AT 6" AND 36" FROM THE RCD /MCRB L

DRILL RCD /MCRB TO 'OBTAIN AN APPROXIMATE l

' 2 GRAM SAMPLE

- - REMOVE THE RCD /MCRB FROM THE HSF REMOVE THE SAMPLES FROM THE HSF PACKAGE AND SHIP THE SAMPLES

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o SEQUENCE OF EVENTS 1/11/90 LOWERED RCD INTO HSF FROM THE FHM

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MAX RADIATION READING ON RCD - 3.3 R/hr GAMMA AT 6" 4

DRILLED SAMPLE #1 FROM RCD RETRACTED RCD FROM HSF TO FHM ASSESSMENT OF HP PRACTICES l

APPROPRIATE HP PRACTICES. WERE UTILIZED

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1 9/12/90 HP TECH ENTERED HSF TO PERFORM SURVEY j

FULL ANTI-Cs AND RESPIRATOR AIRBORNE SURVEY RESULTS 1.32E-10 MICROCURIES/CC. Co-60 l

MPC FOR Co-60 IS *E-9 MICROCURIES/CC

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MAX SAMPLE READING IN TRAY - 2.0 mR/hr GAMMA @ 6" REMOVED SAMPLE #1 FROM HSF.FOR ANALYSIS

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- ALL PERSONNEL EXITED THE HSF LOWERED RCD INTO HSF-AND DRILLED' a

SAMPLE #2

- SAMPLE #2 LEFT IN TRAY IN HSF AND HSF WAS LOCKED ASSESSMENT OF HP PRACTICES U

APPROPRIATE HP PRACTICES WERE UTILIZED RWP WAS GENERAL RATHER THAN SPECIFIC

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SEQUENCE OF EVENTS 9/13/90 TO 9/17/90 REPAIRS TO THE FUEL HANDLING MACHINE 9/18/90 LOWERED FIRST MCRB INTO HSF RECEIVED ALARMS IN HSF (EXPECTED) AND IN HSF ACCESS AREA (>2.5 mR/hr-UNEXPECTED)

.I HP TECH DIRECTED-THAT THE MCRB-BE i

RETRACTED FROM THE HSF i

HP TECH DISCUSSED SITUATION WITH THE HP SUPERVISOR PRIOR TO PROCEEDING-HP TECH OBTAINED. ASSISTANCE FROM OTHER TECHS FOR AREA SURVEYS AGAIN LOWERED FIRST MCRB INTO HSF SURVEY OF ACCESS AREA SHOWED 15 mR/hr HP TECH ROPED OFF ACCESS AREA AS RADIATION CONTROL AREA REMOTE SURVEY OF MCRB WITH RO-7 SHOWED >200 R/hr AT 6"

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PROCEEDED WITH DRILLING OF FIRST SAMPLE FROM FIRST MCRB (SAMPLE #3)

RETRACTED MCRB TO FHM l

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9/18/90 (CONT)

HP TECH PERFORMED ENTRY OF HSF r

FULL ANTI-Cs AND RESPIRATOR SURVEY RESULTS

. GENERAL AREA SURVEY - 2.0 mR/hr GENERAL. AREA WIPE - 5000 DPM/100 cm2 LOCALIZED WIPE - 730,000 DPM/100 cm2 AIRBORNE - 3.67E-10 MICROCURIES/CC SAMPLE #2 IN TRAY (RCD) - < 0.2 mR/hr SAMPLE #3 IN TRAY (1st MCRB) - 30 mR/hr HP TECH THEN REPLACED RO-7 PROBE WITH HIGHER RANGE PROBE.

SSLO ENTERED AND REPLACED DRILL BIT SSLO AND HP TECH EXITED THE HSF FIRST MCRB AGAIN LOWERED INTO HSF 930 R/hr GAMMA AT 6" DRILLED SAMPLE #4 FROM MCRB RETRACTED FIRST MCRB TO FHM

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9 SEQUENCE OF EVENTS ASSESSMENT OF HP PRACTICES APPROPRIATE HP PRACTICES OBSERVED 1

l HP TECH STOPPED THE WORK WHEN a

UNEXPECTED SURVEY READINGS OCCURRED HP TECH OBTAINED ASSISTANCE WHEN WARRANTED HP TECH PERFORMED THE ENTRY PROPERLY RWP WAS GENERAL RATHER THAN SPECIFIC' i

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9/19/90 LOWERED SECOND MCRB INTO HSF 63 R/hr GAMMA AT 6" DRILLED SAMPLES #5 AND #6 FROM.MCRB l

RETRACTED SECOND MCRB FROM HSF l

SSLO AND HP TECH DISCUSSED HSF ENTRY AND SSLO PERFORMED ENTRY (BASED ON ALARA) 4 FULL. ANTI-Cs l

NO RESPIRATOR BASED ON PREVIOUS 1

- AIRBORNE RESULTS.

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' ' SSLO PERFORMED SURVEY OF SAMPLES IN-1 TRAYS UNDER OBSERVATION OF HP TECH AT VIEW - WINDOW 1

I SAMPLE #2 APP. 20 mR/hr i

r SAMPLE #3 APP. 50 mR/hr.

J SAMPLE #4 APP. 2500 mR/hr SAMPLE #5-APP. 50 mR/hr-SAMPLE #6 APP. 50 mR/hr EACH SAMPLE POURED FROM TRAY.INTO INDIVIDUAL ZIPLOC BAG

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9/19/90 (CONT)

SAMPLE #4 READ > 5 R/hr AFTER BEING BAGGED HP TECH INSTRUCTED SSLO TO TOSS BAG IN CORNER: APPROXIMATELY-6 FEET AWAY g

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. SSLO COMPLETED BAGGING SAMPLES, THEN PLACED-ALL SAMPLE BAGS IN ONE LARGER BAG

". ilSLOL THEN CARRIED BAG OF SAMPLES (AT ARM LENGTH)-TO HSF ACCESS AREA AREA MONITOR ALARMED AT HSF ACCESS AREA a

(>2.51mR/hr) i'

-. 'HP'-TECH ' INSTRUCTED SSLO=TO PLACd DAG ON

-FLOOR AND COVER WITH STEEL PLATES ~ FOR i

SHIELDING

.~ SSLO: MOVED 'TO STEP-OFF ' AREA AND NOTEd DOSIMETER READING OF 3 mR HP TECH POSTED SSLO AS " GUARD" AND DEPARTED TO OBTAIN ADDITIONAL ' SHIELDING

.- HP TECH NOTED 0.8 mR/hr ON LEVEL' BELOW-THE HSF ACCESS ' AREA WHILE TRANSITING THE AREA

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-l SEQUENCE OF EVENTS 3

l 9/19/90 l

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.' - ADDITIONAL SHIELDING PLACED ON THE SAMPLES j

RADIATION-LEVELS OUTSIDE THE HSF ACCESS AREA' DOOR REDUCED TO 1.0 mR/hr THE POSTED-HSF ACCESS AREA DOOR WAS LOCKED ~

HP TECH DISCUSSED CONDITIONS WITH HP.

SUPERVISOR' HP SUPERVISOR APPROVED LEAVING-SAMPLES

>lN -THE AREA OVERNIGHT i

BASED ON REPORTED RADIATION LEVELS

. dASED 'ON LOCKED / POSTED HSF ACCESS AREA i

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ASSESSMENT OF HP PRACTICES INAPPROPRIATE ACTIONS e

SAME-GENERAL RWP USED FOR THE WORK HP TECH-DID NOT PERFORM AIRBORNE ANALYSIS AFTER CONDITIONS HAD CHANGED yp L

L HP TECH ERRONEOUSLY PERMITTED SSLO TO PERFORM ENTRY OF HSF:

LACK OF EXTREMITY MONITORING ERRONEOUS SAMPLE '#4 SURVEY RECORD

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(500~ mR/hr'VERSUS 2500 mR/hr)'

.' HP TECH. PERFORMED INADEQUATE SURVEY OF ACCESSIBLti-AREA (0.8: mR/hr)

APPROPRIATE < ACTIONS t

. DISTANCE FROM SAMPLE #4 WAS MAXIMIZED-DURING WORK PERFORMANCE BY SSLO TIME EXPOSURE'WAS MINIMlZED-BY SSLO o

SHIELDING:WAS'IMMEDIATELY PLACED. AFTER RECEIPT-OF ALARM SSLO WAS POSTED AS A " GUARD" HP TECH CONSULTED WITH HP SUPERVISOR I

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1 9/20/90 3

' NIGHT' SHIFT HP TECH -lDENTIFIED-10 mR/hr RADIATION-AREA UNDER THE HSF ACCESS AREAL AT 0100 HOURS.(VERSUS THE' PREVIOUSLY. REPORTED 0.8 mR/hr FIELD)

NIGHT' SHIFT HP TECH POSTED!THE AREA HP SUPERV;SOR NOTlFIED OF CONDITION AT l

. ABOUT ' 0700 - HOURS HP SUPERVISOR DETERMINED THAT NO OVEREXPOSURE OR ADMINISTRATIVE LIMITS

'COULD-.HA)/ELBEEN EXCEEDED'

.' HP SUPERVISOR NOTIFIED RPM AND 4

DEPARTMENT. MANAGER PRELIMINARY EXTREMITIES EXPOSURE:

CALCULATED.TO BE 679.mR TO THE HANDS.

4 (VERSUS.18.75 R LIMIT).

'-- HP SUPERVISOR = DIRECTED SURVEY OF SAMPLES.

i y-WITH' SHIELDING REMOVED -- 17.5 R/hr CONTACT i

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SAMPLES MOVED TO VENT HOOD IN DECON LAUNDRY AREA USING A LEAD PIG l

INDIVIDUAL SAMPLE GAMMA SURVEY s

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10. mR/hr f'

.' SAMPLE #3 120 mR/hr SAMPLE #4 15.8: R/hr SAMPLE #5 300 mR/hr-l

- 90 mR/hr i

. SAMPLE #6

~ SAM'Pl.E '#4 REDUCED' IN VOLUME FOR SHIPMENT-D SAMPLES #1 THROUGH #6 PACKAGED FOR SHIPMENT -

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APPROPRIATE HP PRACTICES WERE OBSERVED-

. SPECIFIC RWP WAS APPROPRIATE 1

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'I 9/27/90

. SAMPLES SHIPPED TO WESTINGHOUSE LABS i

ADDITIONAL EVALUATIONS i

SSLO FILM. BADGE PROCESSED - PROCESSOR i

. REPORTS VALUE AS MINIMAL (< 10 mR)'

i SSLO WHOLE BQDY COUNT - NEGATIVE f-

- BASED--ON SECURITY ACCESS RECORDS THE MAXIMUMLEXPOSURE IS CALCULATED L

-TO~ BE 40 mR h,

' BASED ON WIPES OF SAMPLE TRAYS THE

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REVIEW OF INSPECTION 90-16 j

September 28,:1990

' FIVE NRC IDENTIFIED APPARENT VIOLATIONS i

FAILURE TO PERFORM SURVEYS

• r FAILURE TO FOLLOW PROCEDURE

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i FAILURE TO PROVIDE INSTRUCT;ONS*

-. FAILURE TO LABEL RADIOACTIVE CONTAINERS FAILURE TO: PROVIDE PERSONNEL MONITORING

• i ONE.' LICENSEE' IDENTIFIED' APPARENT VIOLATION l

FAILURE TO POST RADIATION AREA

• lE ONE OPEN ITEM' HP-. SUPERVISOR OVERSIGHT OF WORK ACTIVITIES IN' PROGRESS

- ALSO lDENTIFIED AS DEFICIENCY BY LICENSEE PRIOR TO l'

. SEPTEMBER 28, 1990,. DURING ~lNTERNAL. INVESTIGATION i

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INSPECTION 90-08 g

May_ 8-10, 1990 THREE. OPEN ITEMS INVOLVING l

t TRAINING PROGRAM FOR CONTRACT HP TECHS 3

o RADIOLOGICAL CONTROLLED-~ AREA AND i

PERSONNEL CONTAMINATION-SURVEYS f

CONTROLS FOR THE HOT SERVICE FACILITY g

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STATUS

. A COMPLETE REVIEW OF CONTRACT HP TECH TRAINING HAS BEEN COMPLETED-l h

TRAININGilS IN PROGRESS.

PORTABLE VENTILATION SYSTEM MAINTENANCE H

PROGRAM HAS BEEN IMPROVED L'

4 PCM-1: MONITORS HAVE' BEEN OBTAINED-7 1

HSF KEY CONTROLS HAVE BEEN IMPLEMENTED AND PROCEDURALIZED u

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1 ROOT CAUSE i-AND

. CORRECTIVE ACTIONS 4

C..H. FULLER

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HP TECHNICIAN ACTIONS EXERCISED POOR JUDGMENT AND BECAME COMPLACENT RWP WAS NOT APPROPRIATE FOR THE WORK DID NOT RE-SURVEY THE HSF AFTER CONDITIONS HAD REASONABLY CHANGED

.- PERMITTED SSLO TO MAKE HSF ENTRY VIOLATED PROCEDURAL REQUIREMENTS

.DID NOT POST RADIATION CONTROL AREA -

INADEQU ATE SURVEY TECHNIQUES RECORDED 500 mR/hr FOR SAMPLE'#4 VERSUS 2500 mR/hr ACTUAL RECORDED 0.8 mR/hr UNDER HSF ACCESS AREA'VERSUS L10 mR/hr ACTUAL CONTRIBUTING FACTORS

' APPLICATION' OF PRECURSOR EVENT -

CONCENTRATION OF SAMPLE SUPERVISORY ' INVOLVEMENT IN PLANNING OF ACTIVITIES:

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CORRECTIVE ACTIONS TAKEN-o RADIATION ' AREA POSTED UPON DISCOVERY l

DETERMINED EXPOSURE TO-SSLO:

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-i. COUNSELLING / DISCIPLINARY ACTIONS TAKEN

. THOROUGH EVENT INVESTIGATION COMPLETED p

RE-FOCUSSED. HP SUPERVISOR DUTIES REASSIGNED SOME DUTIES TO HEALTH PHYSICIST SECOND' HEALTH PHYSICIST SELECTED

- - - -. COUNSELLED HP STAFF ON RWP CONTROLS-INSTITUTED : MANAGEMENT REVIEW / APPROVAL:

OF RWPs IMPROVES HP. TECH / SUPERVISORY: JOB BRIEFINGS RESULTS lN GREATER CONSISTENCY OF RWPs t

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1 CORRECTIVE ACTIONS TAKEN

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REVIEWED EVENT WITH HP TECHNICIANS /SSLOs d

AND SENIOR MANAGEMENT

. :lNCREASED HP PARTICIPATION IN DAILY MEETINGS REVIEWED EVENT REPORTING PHILOSOPHY WITH HP STAFF AND HP MANAGEMENT p.

HSF KEY ' CONTROL-PROCEDURALIZED i

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INITIATED " HOT SPOT" MARKING PROGRAM i

CONTINUED NEW MANAGEMENT FOCUS 4

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NEW DEPARTMENT. MANAGER--9/1/90

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QUALIFIED RADIATION PROTECTION-MANAGER-l:

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CERTIFIED HEALTH PHYSICIST-i T

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CORRECTIVE ACTIONS IN PROGRESS-3 e SERVICE EXCELLENCE " REGROUPING" SESSIONS BEING. CONDUCTED WITH HP TECHS REVISING ALARA COMMITTEE. REVIEW CRITERIA

. : REVIEWING ' ADMINISTRATIVE CONTROLS OF HP PRACTICES ENHANC'ING HP OVERSIGHT' IN PREPARATION-FOR DECOMMISSIONING' 1

SHIPPINGPORT ~ DECOMMISSIONING PROJECT l.

MANAGER OBTAINED FOR OVERSIGHT. COMMITTEE.

- WORLD RESPECTED HEALTH PHYSICIST ON L

. OVERSIGHT COMMITTEE RADIATION PROTECTION' PLAN SPECIFICALLY

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INCORPORATED INTO PROPOSED-

-DECOMMISSIONING PLAN' EVENT WILL BE DISCUSSED WITH THE' DECOMMISSIONING CONTRACTOR MANAGEMENT.

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L CONCLUSIONS A.C.CRAWFORD

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CONCLUSIONS PSC ACKNOWLEDGES THAT A PROBLEM. EXISTS PSC RECOGNIZES THAT A POTENTIAL OVEREXPOSURE EXISTED PSC IS CONFIDENT THAT THE ROOT CAUSE l

HAS' BEEN IDENTIFIED ACTIONS HAVE BEEN TAKEN, AND FURTHER ACTIONS

- ARE IN PROGRESS, TO CORRECT THE-SITUATION AND PREVENT RECURRENCE PSC RECOGNIZES' THE IMPORTANCE' OF RADIOLOGICAL PROTECTION AS ~WEl PROCEED WITH DEFUELING AND DECOMMISSIONING:

PSC IS COMMITTED TO AN EXCELLENTzRADIOLOGICAL PROTECTION PROGRAM L

PSC WILL CONTINUE TO COMPLY WITH LICENSE L

-CONDITIONS AND REGULATORY REQUIREMENTS I

SAFETY AND QUALITY WILL NOT BE COMPROMISED PSC CONTINUES TO PURSUE' OUR CORE VALUES OF SAFETY,' EXCELLENCE, AND FINDING A BETTER WAY m

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L SERVICE EXCELLENCE UPDATE.

L OVERALL MORALE'IS GOOD

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L COMMUNICATIONS IS. THE KEY L

' PEOPLE ARE INTERESTED IN THE WORK THEY ARE DOING i

SITUATION IN OPERATIONS AND MAINTENANCE IS -.SIGNIFICANTLY IMPROVED UNION RELATIONSHIP IS SIGNIFICANTLY IMPROVED 1

OVERALL QUALITY 'OF-WORK IS GOOD i

AREAS'OF EMPHASIS ARE HEALTH PHYSICS AND CLERICAL-S 1

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• 7

.I ENCLOSURE 3 2

1 L

' List of, attendees, October 18, 1990, enforcement conference-between the Public-iService' Company of Colorado and1the Nuclear Regulatory Commission in NRC's Regio ~n IV of f. ice, Arlington, Texas Public Service Company of Colorado

' A. Clegg' Crawford, Vice President, Nuclear Operations j

43C.H.; Fuller,' Manager, Nuclear Production, FSV

, as F.J.. Borst, Manager,L Nuclear Training and Support, _ FSV

{ Bill Woodard, Health Physics Supervisor, FSV H;L. Brey, Manager, Nuclear _ Licensing and Resources, FSV

. Nuclear Regulatory' Commission t.

L T.P.fGwynn ; Acting Director,' Division of Reactor Projects, NRC Region IV

'V'

L.A.fYandell, Deputy. Director, Division' of Radiation Safety & Safeguards,- NRC Regioni!V.

" Blaine;Murray, Chief, Radiological Protection &. Emergency Preparedness LSection, Division of-~ Radiation. Safety, & -Safeguards, NRC Region IV

,E.F. ;Hawkins, Deputy Director, Uranium Recovery. Field Office, NRC-Region IV JJ.B. Baird,: Technical ~Asristant, Division of Reactor Projects, NRC Region.IV

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D.L.fGarrison,ReactorInspector,NRCRegionIV

-" Gary -Sanborn',. Enforcement Officer, NRC Region IV-Geoffrey. Cant.cEnforcement' Specialist, NRC Office of Enforcement:

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