ML20082S494
| ML20082S494 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 09/13/1991 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-91285, NUDOCS 9109170163 | |
| Download: ML20082S494 (9) | |
Text
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P.O. Box 840 Denver CO 80201 0840 A. Clegg Crawford Vice Presiderit Nuclear Operations September 13, 1991 Fort St. Vrain Unit No. 1 P-91285 Director, Office of Enforcement U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Docket No. 50-267
$UBJECT:
REPLY TO A NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-267/91-10)
REFERENCES:
- 1) NRC Letter, Martin to Crawford, dated August 15, 1991 (G-91169)
- 2) PSC Letter, Crawford to Director, Office of Enforcement, dated September 13,1991 (P-91286)
Gentlemen:
The. following is Public Service Company of Colorado's (PSC's) response to the Notice of Violation and proposed imposition of civil penalty for the Fort St, Vrain Nuclear Generating Station as described in Reference No. 1.
V_IOLATION A:
"10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of Part 20 and which are reasonable under the circumstances to evaluate the extent of radiation hazards that may be nresent.
As defined in 10 CFR 20,201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of-radioactive materials or other sources of radiation under a specific set of conditions."
" Contrary to the above, on June 11, 1991, the licensee did not make surveys to assure compliance with that part of 10 CFR 20.101 that limits the radiation exposure to the whole bcdy and hands and forearms. Specifically, a mechanic was allowed to enter a shielded cask in the Hot Service Facility (HSF) without a direct radiation or
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i contamination survey of the cask having been performed."
9109170163 910913
)I POR 4 DOCK.05000267 O
l P-91285 Page 2 September 13, 1991 Admission or Denial of the Alleged Violation.
The violation is admitted.
The Reasons for the Violation.
A survey was not performed internal to the shield cask in the Hot Service Facility because the work plan did not call for an entry into the shield task as part of the decontamination of the cask.
A survey was performed at the top of the cask where the worker was to perform the decontamination in accordance with the original work plan.
The Health Physics technician and the Ma..itenance worker elected to aange the work plan during the course of the work, and the
.cian did not recognize that, as a result of this change, i survey needed to be performed of the cask internals. The reason for this violation is a programmatic weakness in the Radiological Work Control Program. This weakness resulted in an improper work plan in that the work to be performed did not match the scope of work delineated on the Radiation Work Permit (RWP). The program was also deficient in the area of identifying and controlling changes to work scope once initiated.
The Correctiv_e St ep_s That Have Been Taken and the Results Achieved.
A comprehensive Radiation Control Checklist was implemented as an interim corrective action until procedure upgrades could be implemented, lask sequences are now betrg used to plan work and support the development of RWP's.
A new pre-job briefing sheet has also been developed and implemented.
The Radiation Protection function has been reorganized to strengthen the management oversight function. A full time ALARA Coordinator has been appointed, as has a dedicated Health Physics Fuel Deck Coordinator.
Staff training has been provided on the June 11, 1991, Hot Service Facility event on Information Notice 93-47, and on ALARA awareness. This event has been incorporated into initial and continuing General Employee Training. On August 30 1991, procedures for upgrading the ALARA, RWP, and Hot Service Facility (HSF) work programs were reviewed and approved by the Plant Operations Review Committee (PORC) and have been imolemented. These procedures represent a significant upgrade to our programs and accomplish, inter alia, the following:
Proceduralize direct involvement of Health Physics in front-end planning.
Procedurally require ALARA review of RWP's.
Procedurally require ALARA participation in development and presentation of job briefings.
1 P-91285-Page 3-September 13, 1991 Procedurally require post-job reviews, including lessons learned analysis.
Procedurally incorporate applicable Fort St.
Vrain and industry operating experience.
-Procedurally require formal task plans accompany RWP requests.
' Procedurally implement guidelines for defining RWP scope.
Implement procedural method for RWP revisions.
1" Amend existing procedures to clarify survey requirements for continuous Health Physics coverage.
Procedurally link ALARA and RWP programs.
Provide a separate procedure for performing work in the Hot Service Facility.
Although these. controls have been in place only a short period of time, we are confident that the significant upgrades will result in an improved work-control program.
In addition, the Fort St'. Vrain Oversight-Committee has completed their review.of the June, 1991,- event and has provided l
recommendations-to the President and Chief Executive Officer of
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Public Service Company.
The Corrective Steps That Will be Taken to Avoid Further-Violations.
i In addition to the-programmatic changes mentioned above, the Fort St. Vrain do_simetry and irregularity-. report - programs are being L-significantly upgraded to accomplish the following:
Build and use ALARA Job History files.
Proceduralize the use of digital alarming dosimeters.
Proceduralize guidelines for the use of extremity monitoring and multi-badging.
o Clarify-dose calculation procedures.
Incorporate root cause (Human Performance Enhancement System) principles in investigations.
Provide independent review of investigation results.
y P-91285 Page 4 September 13, 1991 i
An action'. plan will'be developed to ensure that the concerns of
-the Oversight Committee are addressed.
The Date'When Full Compliance Will be Achieved.
September 30, 1991.
In addition, training is on going.on the Fort St. Vrain events of
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September, 1990, and June, 1991, and the radiological work
. control upgrades.
i VIOLATION B:
" Technical Specification 7.4.d states, " 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-sexposure.
" Procedure HPP-125;Section4.3, titled,"HotServiceFacility(HSF)
Control," Subsection 4.3.5, states, " Write a Radiation Work Permit (RWP) for the job to be performed in the HSF."-
" Contrary. to the.above, on June 11, 1991, a RWP was not issued to cover workers entering =a shipping cask to conduct decontamination activities.
The-RWP (11663) used for the job addressed only decontamination from outside the cask."
Admission or Denial of the Alleged Violation.
The violation it admitted.
The Reasons for the Violation.
The : violation' occurred because of a programmatic weakness in the Radiation Work Permit (RWP) Program which allowed work to be-performed that did not match the work described on the RWP.
The Corrective Steps That Have Been Taken and the Results Achieved.
As _descr.ibed. above, the Radiation Work Permit (RWP) Program has
-been significantly-upgraded as of August 30, 1991. Although the implementation period has been short, the programmatic upgrades are evident in the quality of the Radiation Wort Permits currently. being generated.
-We have assigned a dedicated individual to write RWP's until such time as we feel confident that we have established a firm foundation that others can utilize.
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.P-91285-
_Page 5 l
September 13,-1991 The Corrective Steps That Will be Taken to Avoid Further Violations.
The Institute of Nuclear Power Operations'(INPO) was requested by Public Service Company management to provide a special assist visit to Fort St.
Vrain for the purpose of' evaluating the Radiological Wo'k Control Prograu, including the Radiation Work r
Permit' Program.
This visit.was performed August 26-28, 1991.
Although the fi1al report has not been received yet, INPO indicated that the-Fort St. Vrain RWP and ALARA Programs were on the way to_ meeting industry standards. The INPO report will be reviewed for. fur _ther programmatic-upgrade opportunities.
The Date'When Full Compliance Will be Achieved.
With? the a'dditional programmatic upgrades planned and scheduled for -completion on September 30, 1991, full compliance will be-
-achieved.
' VIOLATION C:
"10 CFR - 19.12 requires, in part, that all individuals working in a restricted area be instructed'in the precautions and procedures to minimize exposure to radioactive materials "
l "Contr*. / to the above, on June 11, 1991, individuals who were worki%-in-the HSF, a restricted area, had not been instructed in the precautions to-minimize exposure to radioactive materials.
Specifically,_ the individuals involved in the decontamination of the HSF cask were.not informed of the patential for ' encountering activated pieces of control rod nor were they provided instructions to minimize exposure to-such materials "
Admission or Denfal of the Alleged Violation.
L The violation is admitted.
-The Reasons for the Violation.
The violation resulted from a programmatic weakness in our Radiological Work Control Program, specifically with respect to
-pre-job briefings.
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1 P-91285_-
-Page 6-September 13,-1991 The' Corrective Steps-That Have Been Taken-and the Results fchieved.
As_ delineated under the response to Violation A above, we havc upgraded our Radiation Work Permit and ALARA Programs to
_ procedurally require pre-job briefings as part of the work control program as of August 30, 1991.
Although implementation time has been short,-it is evident that the quality of pre-job briefings is improving.
Recent entries into the Fort St. Vrain Hot Service' Facility have indicated that pre-job briefings are effective.
+
l-The Correctiv'e Steps That Will be-Taken to Avoid Further Violations.
i; In1 addition to the'further programmatic upgrades described under the-response to Violation A, an ALARA special project team is
.being +stablished :to provido the resources necessary to fully
. implement-the Fort St. Vrain Radiological-Work Control Program.
This team-will -be charged with developing and evaluating the
' effectiveness'of pre-job briefings, i
l The Date When Full Compliance Will be Achieved.
September 30, 1991.
VIOLATION D:
e j
"10: CFR -20'.202(a)(1) requires that each licensee supply appropriate I
personnel. monitoring equipment to,. and require the use of such-equipment-by, each individual _who enters a restricted area under sJch l
circumstances that he receives, or is likely to receive, a dose in
.any calendar ouarter in excess of 25 percent of the applicable value specified in 10 CFR 20.101(a)."-
j q
" Contrary to the' above, on June 11, 1991, the licensee did not supply appropriate personnel monitoring equipment to the mechanic and health l
p_hysic_s ' technician working-in a restricted area who were subject to
_extremitysradiation levels of up to 14 R/hr, and were therefore likely to receive an -extremity dose in that calendar quarter in
_r'
. excess of;25 percent of the appitcable value specified in: 10 :CFR 20.101(a).
Specifically, no extremity radiation monitoring devices were supplied to the individuals involved in the decontamination of
-l the HSF cask."
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P-91285 1
-Page 7-j
..Septembe_r-13, 1991 l
Admission or Denial of the Alleged Violation.
i The violation is admitted.
- The Reasons for the Violation.
L
- The violation resulted from programmatic weaknesses.in the Fort St.Vrain Work Control Program, specifically with respect to issuance of extremity dosimetry.
-The Corrective Steps That Have -Been Taken and the Results Achieved As_ mentioned under the response to Violation A above, the radiological. work control program at Fort St.
Vrain has been significantly ; upgraded as of August 30, 1991. The development and-implementation of a new Radiation Work Permit (RWP) provides for more visible evaluation of dosimetry requirements. Altho' ugh implementation time-has-been short, a review of completed RWP's has indicated that extremity dosimetry is being appropriately utilized.
l The Corrective Steps That Will be Taken to Avoid' Further ll Violati :n1 As mentioned under the response to Violation A above, a comprehensive upgrade to the dosimetry program is in the process of--being developed that will provide clear procedural guidelines with ' respect 'to_ the ' issuance and evaluation of extremity dosimetry.
The Date When Full Compliance Will be Achieved.
' September 30, 1991.
This is a. Severity Level III problem (Supplement IV).
Cumulative Civil Penalty - 562,500 (assessed eaually among the four
- violations) u
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ll We feel that: the combination of corrective act ions taken and planned represents a-substantial upgrade to.our Radis logical Work Control
-Program.and'will be effective in preventing recurrence of events such
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as the June 11, 1991, Hot Service Facility incident. As dist'ussed at the Enforcement Conference, PSC has identified four broad corrective action elements that we are pursuing in conjunction with the specific actions we are taking related to our radiological work controls. One.
element is that management has been tasked to solicit feedback from employees on issues of safety and quality.
Second, an organi,ational
-analysis has been -completed by outside professionals assessing Nuclear Operations attitudes and issues.
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P-912851 Page 8
' September.13, 1991 j-l Third, INPO provided PSC an assist visit in August, reviewing our
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planned corrective actions in the' Radiation Protection Program.
Last, our Defueling and Decommissioning Oversight Committee has provided technical review and comments of our planned program enhancements.
PSC will sunmarize the findings of these four i
processes and provide the NRC an overall action plan in response to c:
the findings by October ~15, 1991.
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'In_ accordance with the guidance provided by the Nuclear Regulatory Commission and as confirmed in Reference No.
2, Public Service Company-has electronically _ transferred the civil penalty (S62,500) to the Treasurer of the United States.
Please call Mr.
M, H.
Holmes at (303) 480-6960 if you have any questions.
Sincerely, p
A.'Clegg Crawford.
(Vice-President,NuclearOperations
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ACC:FJB/bj.
cc: Regional Administrator, Region IV Mr..-J.. B. Bai rd
-Senior Resident Inspector
. Fort St. Vrain
UN!1ED ;TATES OF AMERICA
' ' CLEAR REGULA10RY COMMISSION In the Matter
)
)
Public Service Company of Colorado
)
Docket No. 50-257 Fort St. Vrain Unit No. 1
)
AFFIDAVIT A.
Clegg Crawford being first duly sworn, deposes and says: That he is Vice President, Nuclear Operations, of Public Service Company of Colorado, the Li:ersee herein, that he has read the information presented in the attached letter and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Vice Presider.t Nuclear Operstions STATE OF d rs; i n! :.t ftlbror/n)
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COUNTY OF 4eJ-4rai'fsid n )
Subscribe end sworn to before n,e, a Notary Public on this
/3 YA day o/ y ] iu llL L 199[-
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. Notary Public My commission expires 9 // 2
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