ML20066D158
| ML20066D158 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/29/1990 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-90344, NUDOCS 9101140175 | |
| Download: ML20066D158 (10) | |
Text
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- th P.O. Box 640 m-- W'~~E:_~ ~
Denver CO sc2o1. e60 A. Clegg Crawforo
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'IAN - 21991 N@6ef Operetens I
Novameer 29, 1990 Fort St. Vrain Unit No. 1 L'gg,iHt 19, c
P-90344
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U. 5. Nuclear Regulatory Commissicn u ="s~ "
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ATTN: Oucument Control Desk
'gg Washington, D.C.
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Occtet No. 50 267 Ey f5".d" RESPONSE TO NOTICE OF VI0t.ATION (NUCLEAR S. 2sIm..m;-
SUBJECT:
REGULATORY CCm !5510N INSPECTION REPORT 90-16).-~:
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REFERENCE:
NRC Letter, Martin to Crawford.
W.:= '
dated October 30, 1990 (G-9025A) l Osar $1rs:
7n September 28, 1990, Mr. Blaine Murray concueted NRC Insoection Fort St. Vrain.
On 90-16 to evaluate a potential overstoosure at October 18, 1990, an enforcement conference was conducted to provide l
Public Service Company of Colorado the opportunity to respond to tn11 The followin9 is our response to the itess contained in l
inspection.
the Notices of Violation and addresses actions we have taken to address the areas of systematic weaknesses and canagement involvement in the Radiation Protection Program.
A.
$URVE11 "10 CFR Part 20.201(b) requires that sach licenses shall make or cause to be made such surveys as may es necessary to evaluate the extent of radiation hazares that may be l
present.
Contrary to the above, on September 19, 1990, the licenses perform radiation and airborne surveys before did not a Special Senior Licensed Operator ($$LO) to enter 4110 wit:0 the Hot Service Facility (H$F) to remove five unshielded radioactive samples.
Subsequent, surveys performed on September 20. 1990, retseled that the samples had contact radiation levels of about 65 Rads /hr."
This is a Severity Level IV violation.
(Supplement IV)
(267/9016-01)
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JAN 2 '91 10:50 FSV TSC PAGE.03 P 90344 Page 2 Novemoer 29; 1990 The Reason for the Violation if Admitted The violation is admitted.
A Health Physics Tecnnician covering the. cork in the Hot Service Facility did not i
perform a survey pr1Gr to allowing an $$L0 to enter the Hot Service Facility to obtain some irradiated samples.
A survey should have been obtained because conditions could reasonably have been expected to have changed in the H5F
-l due to additional irradiated samples being obtained in the HSF since the previous survey.
No overexposure was received as a result $f this work but the potential for an overexposure did exist. The Health Physics Techrt.:ian was i
mistakenly relying on previous day survey information.
the Corrective Steps Which Have Been Taken and the Results Achievec A thorougn investigation of the event was performed to determine the root causes.
The following corrective actions have been taken based on the conclusions and recommendations of the evaluation.
a) Counselling / Disciplinary action has been taken with sne Health Physics Tecnnician involvec in the job.
b) All Radiation Work Permits now require a review by Radiation Protection management to provide a better overall review of the work to be performed anc the raciation protection requirements for the jobs.
c) The event has been reviewed with all the Health Physies Technicians and SSL0s.
The need to utiliza c.rrent survey information and not rely on previous data was stressac.
No further incidence of failure to perform surveys or inadequate surveys has been noted.
Corrective Steps Which Wili be taken to Avoid Further Violations Corrective steps which will be taken to avoid further violations include the following:
a) The Radiation Work Permit review requirements will be reviewed and Administrative Procedure changes made, as necessary, to assure adequate surveys are performed.
I
JAN 2 '91 10101 FSV T5C PAGE.04 l
l P-90344 Page 3 Novemeer 29, 1990 b)A review will be performed of Health Physics Precedures specifying survey recuirements, and changes will be maos as necessary to assure compliance with 10 CFR 20 Part 20,201(b).
The Date When Full compliance Will Be Achievec Interim administrative controls for review of RWPs nave caen implemented.
Formal administrative procedural revisions t
will be acnieved by December 31, 1990.
B.
PROCEDURES
" Fort St. Vrain (FSV) Technical hecification 7.4.o states that " Procedures for personnel radiavan 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."
FSV Procedure HPP 125 titleci " Establishing and Posting Controlled Areas," Section 4.3,
" Hot Service Facility Control," Subsection 4.3.5 states: " Write a Radiation Work l
Permit (RWP) for the job to be performed in the HSF."
l FSV Procedure NPAP-10 titled " Radiation Work Permit Program," Section 3.2.2 states that "A
special RWP is I
normally issued for a specific task for a perico of time not to exceed 1 week."
Procedure NPAP-10, Section 4.2.3 stated that "During work Jn an area controlled by an RWP, health-physics personnel shall:
conduct raciation, contamination, and airborne radioactive surveys as necessary to determine changing radiological conditions."
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 RC0" did not reference any sample collection or removal activities.
For example, RWP No.
11377 did not. include radiation levels, continuous health physics
- coverage, extremity monitoring, respiratory protection equipment, or special instructions for hanoling the radioactive samples, this is a Severity L,evel IV violation.
(Supplement IV)
(267/9016-02)"
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sa acacc rev i:L
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P-90344 Page 4 November 29, 1990 The Reason for the Violation if Admitted The violation is admitted. The Radiation Work Permit did notadeouatelyacdressthejob scope for the work being performed in the Hot Service Facility.
It was written to allow general access to the area for set-up and testing work in preparction for obtaining the
- samples, instese of addressing the specific job.
_T_he Corrective Steps Which Have Been Taken and the Results Acnieveo All Radiation Work Permits are now recuired to be reviewed by Radiation Protection management prior to being issued.
This has resulted in raore consistency in RWPs and provides cetter overall control of the RWP program.
Counselling /0iteio11 nary action nas coen taken with tne Health Physics Technician involved in the job.
All Health Physics Technicians have been instructed in the proper use and requirements of Raciation Work Permits.
No further incidence of failure to follow procecures witn respect to RWP use has taken place.
Corrective Steps Which Will be Taken to' Avoid Further l
Violations i
The Radiation Work Pe rmit review requirements will be revicwed and Administrative Procedure changes mace, as nece ssary, to assure adequate RWPs are prepared and used, and to assure that til radiological concerns are addressed.
- Also, procedures addressing RWP recuirements will be reviewed to assure they address the need for preparation and use of ad*quate RWPs.
The Date When Full Compliance Will be Achieved Interim administrative control for review of RWPs have oesn implemented.
Formal administrative procedural revisions will be achieved by December 31, 1990, i
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'34 icamJ rev inc PAGE.06 P-90344 Page 5 1
Novemcer 2g, 1990 2
~i l
C.
INSTRUCTIONS TO WORKER $
l "10 CFR Part 19.12 requires that individuals working in a restricted area shall be kept infoneed of radioactive material in the restricted arwa and shall be intructed in i
precautions or precedures to minimize asposure.
Contrary 1,o the above, the 55LO that collected and removed
~
i five unshielded radioactive samples from the.
HSF on l
Septemoer 19, 1990, was not informed that the samples had contact radiation levels of up to about 65 Racs/hr nor did the $$LO receive special instructions on proper procedures
{
for handling the samples, q
This is a Severity Level IV violation.
(Supplement IV)
(267/901603)"
The Reason for the Violation if Admitted 4
The violation is admitted.
The $$LO entering the Hot
{
5ervice Facility was not fully aware of the radiological conditions because tne Health Physics Technician cic not perform a survey prior to his entry, no specific job briefing was provided, and the procedure for obtaining the samples did not include specific steps for retriev' s the l
radioactive samples.
The Health Physics Technician mistakenly concluded that ALARA considerations justified the entry by the $$LO alone.
The Corrective Steps Which Have Been TAken and the Results Acnievec l
This incident, and its potential consequences, has been-reviewed with all the Health Physics Technician, and SSL0s.
All Radiation Work Permits are being reviewed by Radiation Protection management to assure that adequate instructions are provided for the work to be performed, i
f Counselling /01sciplinary. action has been taken with the
+
Health Physics Technician involved in the job.
i The Health Physics Supervisor or his designee is required to attend the daily planning meeting to be better informed of the work. schedules affecting Health Physics.
4 No further : incidence of. inadequate instructions to workers i
has ' taken place.
i
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l JAN 2 '91 10:34 FSV TSC
=GE.07 P-90344 Page 6 Novemoer 29, 1990 l
Corrective Steps Which Will be fiken to Avoid Further Violations The Radiation Work Permit procacural recuirements will be reviewed and Administrative Procedure changes will be mace.
as necessary, to assure adequate RWP reviews are performee ard to assure thts all radiological concerns are aedressac in personnel briefings.
- Also, the procedures accressing worv, performed in the Het Service Facility will be reviewed to assure that proper wort instructions are provicec for all work in that area.
The Date When Full Comoliance Will be ' Achieved Interim acministrative controls for review.* RWPs have osan imolemented.
Formal acministrative procacural revisions will be ac.ieved by Decemoer 31, 1990.
1 0.
RA010 ACTIVE MATERIAL CONTAINERL i
"10 CFR Part 20,203(f)(2) reautres tnat eacn container of licensed material shall bear a dursole, clearly visiele 16bei identifying the radioactive contents. The label snail l
also provide sufficient information to permit individuals handling or working in the vicinity to take precautions to avoid or minimize exposure.
l FSV Procedure HPP 630
" Radioactive Material Control ano l
Handling," states:
3ection 4.3.1, " Identify all radioactive material, or their containers, with a Radioactive Materials identification (RMI) Tag."
Section 4.3.3, " Perform radiation and contamination surveys inside and outside of the container er bag, as S.**cticable."
Section 4.3.4, " Record information on the tag as necessary."
Section 4.3.5, "RecoM information in Radioactive Natorial Accountability Log."
Section 4.3.6,
" Attach the hard copy of the tag to the material or container to be tagged."
Contrary to the above, the five bags containing radioactive samples removed from the H$F on September 19, 1990. were not tagged or identified as containing radioactive material.
l I
loN 2 'S1 10155 F 5 t) T3C cag, gg P-90344 Psge 7 Novemoer 29, 1990 This is a Severity level
!V violation.
(Suppl'ementIV)
(267/9016-04)"
TheReasonfortheViolajienifAceitted The violation is acmitted.
The samples,_although locatec in a locked control area, did not have eacn indivicual tag marked as containieu radioactive materials.
7 The Correctivt_ Aeos Which Have_Been Taken and t e assults h
Acntevec The reovirements for marking radioactive materials have osan reviewed with all the Health Physics Technicians.
Hot $0ot fcentification is being utilized to identify those areas /touipment which present a radiological concern inside control areas so that workers are mace aware of the hazarcs.
No further incidence of inadeauate racioactive materia' icentification has taken place.
Cor*ective Steps Whien Will be Taken to Avoic ~urtner Violations i
A comprehensive review of the Radioactive Materials Control program is being performed to assure full compliance with 10 CFR 20,203(f)(2).
The Date When Fuli Compliance W111 be Achieved Procedural
- changes, if required, will be achievec by December 31, 1990.
E.
PERSONNEL MONITORING "10 CFR Part 20.202 requires that each licensee shall supply appropriate personnel monitoriag equipment to each fladividual 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 in pare;-aph (a) of 10 CFR Part 20.101.
Contrary to the above, on September 19, 1990, an SSLO collected and hanc-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.
JAN 2 '91 10:56 FSV TEC PQGE.09 P-90344 Page 8 Novemoer 29, 1990 This is a Severity Level IV violation. (Supplement IV)
(267/9016-05)".
The ilenGn for the Violation if Admitted The violation is acmitted.
The SSLO was not providea with the proper dosimetry for the radiation levels encounterea because no survey was performed prior to him accessing the Hot Service Facility and consecuently the Radiation Wo rt.
Permit did not acequately address the ractological conditions in the area.
The Corrective Stoos Which Have Been* Taken and the Results Aentevec The requirements for dosimetry have been reviewed by all the Health Physics staff. All Radiation Work Permits are being reviewed by Radiation Protection management to. assure that adequate dosimetry is provided for the work to be cerformed.
A followuo evaluation determined the SSLO received 0 millirem whole bocy exoosure ano a whole bocy count indicated no uptake of radioactive material.
Counselling /01sciolinary action has been taken with the Health Physics Technician involved in the job.
No further incidence of inadequate cosimetry being issuec to workers has taken place.
l Corrective Stoos Which Will be Taken to Avoid Further Violations The Radiation Work Penett procedural recuirements will be reviewed and Administrative Procedure changes will be made to assure adequate dosimetry is provided for the work to os performed.
l The Date When Full Cosoliance Will be Achieved l
Interin administrative controls for review of RWPs have been l
I implemented.
Formal administrative procedural revisions will be achieved by December 31, 1991.
~
f JAN 2 '91 10 55 FSV isc pag,3g l
4 J
P 90344 Page 9 Novemoer 29, 1990 Systematic Weaknesses and inaceouste Management involvement 4
Public Service Company of Colorado is improving the ability of the Radiation Protectiot, staff to provide for the health and safety of the workers and the public.
In addition to-the items addressed in the prior - sections, which specifically address the violations, the following actions have been taken
- 1) A second Health Physicist has been selectea to reduce the work lead on the Health Physics Supervisor ano allow nim to refocus his efforts on inplant work a,ctivities.
- 2) The Health Physics Supervisor nas increaseo ni s participation in cally planning meetings.
The Radiation Protection Manager, Health Physics Supervisor or Health Physicist is recuitec to attend.
- 3) Service Excellence "regresping" meetings are ceing conducted with the Health physics staff to improve communications cetween management and staff,
- 4) ALUtA Committee review requirements are ceing evaluatec and changes are being implemented-to increase its effectiveness.
- 5) The access controls to the Hot Service Facility have oeen upgraded to provide more effective control over this area including proceduraliaod key control and requiring an RWP to enter the H5F.
- 6) A Certified Health Physicist who is cualified in accordance with Regulatory Guide 1.8 as a Radiation Protection Manager - has assumed responsibility for the Radiation Protection Program.
7)Public Service Company of Colorado has obtained the services of several individuals with exceptional' decommissioning and Health Physics experience to assist on the Oversight Coeunittee for spent fuel shipping' ano 4
decommissioning activities,
- 8) This event was reviewed with senior management and the Oversight Committee. A followup report will be made-to the Oversight Committee in February,1991.
- 9) The event reporting philosophy has been reviewed with the Radiation Protection staff and management.
JAN 2 '91 10:57 SU TSO
- agg, 3 ;
I P-90344 Page 10 November 29, 1990 10)
Public $ervice Company of Colorado is working closely with the contractor for decommissioning to ensure that a comprehensive Radiation Protection Program is developec for coconsissioning. This particular event has been discussed with the contractor and will be incorporated into their l
program.
Public Service Company of Colorado acknowledges that a problem existed and that there was a cotential for an overexposure.
We are t
confident that the root cause has been identified and the actions taken ano future actions will prevent recurrence.
Public Service Company of Colorado is committed to an excellent Radiological Protection Program and recognizes its importance*as we proceed with defueling and decommissior.ing. Public Service Company will continue to co s y with license and regul4 tory requirements and continue to j
pursue our core values of safety, excellence, and finding the better way.
Thase actions are responsive to your concerns and provide reasonable assurance that similar events will not occur in the future.
ilease call Mr.
M.
H.
Holmes at (303)480-6960 if you have any questions.
Very truly yours, 0l A.?leggCrawfor{
l Vice President, Nuclear Operations l
ACC;WOUbh cc: Regional Administrator, Region IV ATTH: Mr. G. L. Constable, Chief Technical Support Section Division of Reactor Projects b
Mr. J. 8. Baird Licensing Review By:
Senior Resident Inspector
/
UNo Fort St. Vrain Date: _.
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