ML20136B243
| ML20136B243 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/15/1995 |
| From: | Zahrt K AFFILIATION NOT ASSIGNED |
| To: | NRC |
| Shared Package | |
| ML20136B139 | List: |
| References | |
| FOIA-96-434 NUDOCS 9703100216 | |
| Download: ML20136B243 (2) | |
Text
. _. . . . - . - - . . - _- . . - . . - . . - - - - . _ - - . _ _ .
. N0l/Ein 6 E A 12 ,) 9 9 5 i
eny to ivonce of vtoierion is<nc ne. 4-N-olo)
I fuRSURAIT To Th'E pro viS low 0 F 10 C FR 2 s 20 la rh'/S /S i
- mV walTreiv RESPCAI.GE TO A/dr/CE O F L//0LA7'/6/V DUAC i i .In/vaSrl&R TION A/0 . 4 - q t} - C f o , )
! l 1
0.)I ///?t/E 13ES/U CHAA6EO hl ITH U / o L A77'A/S T/lE Al^?C Reats t arvoiv sPecieic nLi v' is c Fie so. s "octu.sessre \
11]/S C.Dn/ DUCT " P0f%dnPh' (** ) N
- 1,N'eam.c/x.W..$a 46 do etids) d.Lupufk.qEcowa.-
l ad v.e.Atfans .feuld a9abat me . Dat .2.b(.o
- cs>nasz& J accasataiw scumaf mea.,2 i .aiA memAew s G w acs le ).aa,., 4 . .
- .zalth.nts;oazd' uu/Ia/fc do JcanarAm A?nmd of %
i oc1 arud chad % raa s.c 9M n/ d c orr xio<.,.rz,tres.
I (2d l
THE CoiffEC 7706' STEF5 T//'d7 //f' uE OEEN TAME /U
} AA!D 7H' E /ESOLtS ACH/EVEO:
j s.)
Szc1 ca.eue&se ster asas rny %A &
mrnaval casm 1Ae pr. sr. unai,u p.as,acg, b.) Yle sumdb aedbad aj sa a,.9 iogg,m_. _g(z pag one asil a- }1ay Yest.s a4'biz ,rtji festsur& 4 Q' kP4%*'l E'tG d i ff.5 a l 2 5.o . f * \'
_p (g,g &
- l'AoA h mo st.t arzd.su m .Aary. .e.,, &
i l '7?e ad A A'/"05. Pa&2 .h iriy .ns,,,,A l SEG uAs e 2 tryanm,,,,,,2 made a ypg g g, l 6?L cveri i
I W brouct Ac .ldeAt .s u.prcd tria,, y o-p g,(, p,,o , ,gg
.rn.afsad,, 1 xce p g l b Aud unido2 - d e b l0 e t a f s J rz. d a r / K ,
dwuss and saAuush-s measaus-
, zhmt od 7.se d.zaekes n.m.inaan, y p gsc ,nsnes appm.ain a .2
. a as ste m y t ,,o a ,
a-- zo e'e. . '
ge c > % p ,, ,da>t.,
- to __ .
j 9703100216 970228 m I 5is55
$20a521234 eon / o-, c / 1 . - .
Dd "THE CoRREC T/ UES TEFS T//#7 I4//LL 8 E' 7 W k'E/V 70 AVD/O fur THER l//o/Gr/O/u 5l' a.)i;atww Dab 1Abo-/ cantfullV C/1onancJ A4/Aed> adPY sw i
&catoru k. aimed .zd& b6 ACA' p- -
, .ady &;#Ay'&, ./&~a4+v py u kesurds t . znWer), so
.was to a.
hafAfd, FasIP.bidh7G e%esci$4 of b /2&tlW caw %, .Z~ asn ./.c/t.w.2zA. rio c o2cb bu2.%b N dhs/5y a i oF Awmpisar .9n.2e.e, p.,w,rr.gr{.sizac/w W ' 0 " /' N 2 &
/77ar!V emoiresece.s a<rgM iunetts i !!!on, soin, ivac ) 9 e,,,,gg g y 2midf u ,z Em M .2 W p,g a d rncj y eb .;th .o(c Jrc.tn y me, aA Q a,,)wJ/4
.b{c/u)Acd l etAM ./2Yd<tdA -
- ) "THE DDTE WHE/U fLiLL C,o W7PA IRs B E RCHI E t.r E' O ;
'ld /l/0 UEmBER / 2. , / 9t C5 9
WE/v/l/ETW L . ZANR 7" f
/'awwr4 W. j' aAsD
//- /2 - 9.S~
t-,8
, ,3 h $ 0 'd [(,
- 1. ' 1 NOV 3 Olg 1 I I i
k .c h, 3 i i ..__..
SCIENTIFIC ECOLOGY GROUP, INC.
November 29,1995 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
Subject:
REPLY TO A NOTICE OF VIOLATION
Reference:
NRC Notice of Violation EA 95-164, NRC Inspection Report 50-267/94-03, ara Office of Investigations Reports 4-94-010 & 4-95-015 Gentlemen:
Pursuant to the provisions delineated in Section 2.201 of the NRC's " Rules of Practice", Part 2, Title !O, Code of Federal Regulations, Scientific Ecology Group, Inc. (SEG) herein provides formal response to your letter of October 30,1995 transmitting the Notice of Violation to SEG related to Violations of 10 CFR 50.5.
Appendix A provides SEG's response to the specific violation of NRC requirements set out in the Notice of Violation.
I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief. Should you have any questions or require additional information, please telephone me at (423) 376 8237.
Sincerely, Donald R. Ne y Vice President Radiological Engineering and Decommissioning Service l
II:995 D'M'DW9
- P.O. Box 2530 6-0337 1560 Bear Creek Rd. P.O. Box 2138 1234 Columbia Dr. S.E.
Oak Ridge, Tennessee 378312530 Carlsbad, New Mexico 88220 Richland, Washington 99352 (615) 4810222 Fax:(615) 482 7206 (505) 887,-1673 Fax:(505) 885 4219 (509) 736-o626 Fax:(509) 735 3085
.x 7
US NRC Response to Notice of Violation j November 29.1995 1 l Page 2 of 2 I
Attachment:
APPENDIX A 1
4 cc: U.S. Nuclear Regulatory Commission - Region IV L. J. Callan, Regional Administrator 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 bec: H. W. Arrowsmith - Lou Carr, E les Cole Lisa Campagna. E Joe Albenze Tom Howard, E Kevin McGeady A. Clegg Crawford, PSCo
~
l i Harvey Story Mary Fisher, PSCo i
) Allen Wuchenich, E l
s 4
t i
II2995-DS!'D'W9 I
a
. APPENDIX A SCIENTIFIC ECOLOGY GROUP'S RESPONSE TO NOTICE OF VIOLATION NRC EA 95-164 The information in this Appendix is provided in response to the cited non-compliance of 10 CFR 50.5 as described in the Notice of Violation (NOV) and reiterated below:
NOTICE OF VIOLATION 10 CFR 50.5 states, in part, that any employee of a contractor or subcontractor of any licensee may not "[d]eliberately submit to ... a licensee, or a licensee's contractor or subcontractor, i information that the person submitting the information knows to be incomplete or inaccurate in I some respect material to the NRC."
Contrary to the above, in February, March, and September 1993, employees of SEG, a l
contractor to a licensee (Public Service Company of Colorado), submitted 35 records of radiation
{
surveys to the contractor that the employees knew were inaccurate in some respect material to I the NRC. Specifically, during February and March,1993, survey records which were required to support the release of material from the facility and work conducted under various radiation work permits were dated and signed to falsely indicate that they had been created substantially earlier and contained false information regarding survey instniment usage and calibration dates.
In September 1993, a survey record supporting release of the hot service facility plug was created to indicate that the survey had been completed when in fact it had not. These records were material to the NRC because they were required to ensure compliance with the regulations in 10 CFR Pcrt 20. (01013)
I SEG RESPONSE '
l 1.0 ACKNOWLEDGEMENT OF THE VIOLATION SEG does not contest the violations as stated in the NOV and its associated transmittal letter.
It believes, however, that it has fully and appropriately responded to the violations which were self-identified, as indicated by the following information.
2.0 REASONS FOR THE VIOLATION Root cause factors resulting in these violations included SEG Fort St. Vrain Decommissioning Project site management's failure to perform proper management activities. Specifically, there was a lack of oversight and involvement on the part of the Project Radiation Protection (RP) n:mo si "
Page 1 of 7
- i
. NRC - Response to Notice of Violation Appendix A November 29,1995 i
~
i Manager in day-to-day RP field activities and inadequate' implementation of the SEG site RP
- Self-Assessment Program in that required self-assessments were not performed. Thic lack of l 1
oversight resulted in some first line RP Supervisors assuming an inappropriate and unapproved level of authority over RP Technicians and their survey documentation activities without the j knowledge or consent of senior SEG site management. These RP Supervisors and technicians I
were thus able to disregard procedural compliance.
j In addition, the Radiological Occurrence Reponing (ROR) System failed to function as designed.
In particular, the first line Supervisors failed to use the ROR process when missing survey !
documentation was brought to their attention further preventing senior SEG management 1 awareness.
l There was also inadequate implementation of the interface between the SEG and Westinghouse i Team Quality Assurance Program elements. This resulted in insufficiencies in the independent program functions established to provide an additional level of compliance assurance.
l Finally, inadequate implementation of the SEG Open Door Policy by site management and l initially inadequate RP Program Staffimg also contributed as root cause factors.
c i
3.0 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Immediately following self-identification of the violation, SEG management took both immediate and long term comprehensive, effective corrective actions to remedy the violation and prevent recurrence. Some corrective actions involved joint initiatives by SEG, Public Service of j
Colorado (PSCo) (the Licensee] and other members of the Westinghouse Decommission Project l Team. These corrective actions, many of which go far beyond the immediate violation causes, are briefly outlined below. Further detali and discussion of these actions was presented to NRC Region IV staff at the August 29,1995 Predecisional Enforcement Conference and documented in presentation materials provided to NRC attendees. These materials were placed in the PSCo Fort St. Vrain docket (50-267) via NRC Meeting Summary Transmittal dated September 1,1995, i
from R. A. Scarano (NRC) to D. R. Neely (SEG). These previously submitted materials fully and adequately address the required response and will not be repeated here, per instruction in the NOV.
1 1
1 a
mmouom Page 2 of 7 l
l
NRC - Response to Notice of Violation Appendix -A November 29,1995 l
SEQ Immediate Corrective Actions j Two RP Supervisors were placed on administrative leave immediately following discovery;
'All physical work was voluntarily suspended; An immediate independent investigation by SEG senior management and technical personnel was initiated and was followed by a Westinghouse Team Safety Assessment; SEG RP staff were augmented with an additional 17 experienced personnel; A full scale MORT (Management Oversight Risk Tree) Team Assessment was
. performed on the entire RP Program; An all hands Management Meeting, conducted by senior executives from the licensee and the contractors, was held on March 31, 1994 to discuss corporate core values and project expectations; All RP Technicians were given special " Restart" training which addressed appropriate methods for documenting records errors and omissions; Pertinent RP Procedures, including those for unconditional release of materials and survey documentation, were revised and RP Technician training was conducted prior to restart; Team Building training sessions were conducted April through September,1994; SEG and PSCo jointly established restrictions and independent monitoring of unconditional releases of material, including PSCo verification of 100% of the material release documentation; All Westinghouse Team site personnel were given " Restart" Training:
PSCo validated this " Restart" Training by interviewing a sampling of site personnel:
mmo u o m Page 3 of 7
t W NRC - Response to Notice of Violation Appendix A November 29,1995 1 :
- All RWPs were deactivated, re-evaluated and then reactivated prior to restart; 3
Additional controls were established to ensure that required RWP surveys are performed; and, f
- The SEG RP Management office was moved inside the restricted area to provide
! better management / worker accessibility and interface.
SEG Lone Term / Lasting Corrective Actions
- The RP Department was re-organized to enhance management involvement in daily work activities and to better allocate staff resources - this included replacing certain RP management personnel including the RP Supervisors directly involved
. with the violations and the Project RP Manager; I
- As more fully described at the August 29, 1995 Predecisional Enforcement j Conference, remaining involved staff were re-trained and counselled; 4
4'
- An all hands meeting was held August 10, 1994, to discuss results of the SEG -
MORT Assessment and PSCo Third Party Investigation and to re-emphasize
, management's expectations; j
- To ensure all site personnel and new hires understand procedural documentation 4
responsibilities including appropriate response to record errors and omissions and non-compliance identification and communication, these issues are emphasized in FSV General Employee Training and Annual Re-training;
- The Westinghouse Team has completed a review of all 1992 and 1993 RP records to ensure that project activities are supported by a complete and accurate records system; A " Radiological Improvement Plan" implemented 339 improvement items in response to MORT Findings;
- Implementation of the SEG site Open Door Policy was enhanced and strengthened and the Corporate Open Door Policy was re-emphasized to all SEG site personnel; ums.o" " Page 4 of 7
NRC - Response to Notice of Violation Appendix A November 29,1995 The ROR System was improved;
- SEG and PSCo management oversight was enhanced; and, The Westinghouse Team QA Program was enhanced.
SEG Corporate Actions SEG President and Vice President, Radiological Engineering and Decommissioning Services, were immediately involved following discovery and personally directed initial response and corrective actions; Mangiaent oversight group formed at corporate level; SEG Open Door Policy is emphasized at the corporate level and by senior managers visiting offsite projects; FSV issues have been 6sossed on corporate senior m:nagement meetings and at many staff meetings; SEG Executive Self-Assessment Procedure for all offsite projects was development and has been effectively implemented numerotc umes; and, As appropriate, FSV, Radiological Improvement Program corrective actions were integrated into corporate and other project procedures.
All of these corrective actions were complete as of October 10, 1995.
i These corrective actions have fully addressed the causal factors of the violations and have been I
effective in preventing recurrence. SEG believes there is now a full understanding and awareness on the part of RP staff at Fort St. Vrain of their responsibility for procedural compliance, especially in the area of documentation requirements. Enhancements in the self-assessment j functions of the onsite organization as wdl as independent oversight from the onsite j Westingt,nuse Team and PSCo QA departments and senior QA and management staff from the l
SEG Mrae office, which were integral elements of the overall corrective action effort, have i strengthened SEG's ability to prevn at, or to quicidy identify and correct progrr.m deficiencies. I mmowo" Page 5 af 7 i
. l l
j..- -
4 i NRC - Response to Notice of Violation l* Appendix A November 29,1995 l-As described to you at the Predecisional Enforcement Conference and confirmed by the NRC in its NOV transmittal letter (P.ef. NRC Case Number EA 95-184), evidence exists that SEG's implemented corrective actions are effective in that they recently enabled SEG management at
! FSV to identify and take prompt corrective action in connection with activities of a SEG l technician who had not been performing instrument response checks as required by procedure.
!~ 4.0 ADDITIONAL CORRECTIVE STEPS THAT WILL BE TAKEN TO PREVENT l RECURRENCE i
Additional corrective actions have been developed to ensure that lessons learned from these
- l. violations are communicated to all SEG employees involved in licensed activities corporate wide.
This includes the following:
At a series of home office meetings, for all Oak Ridge Operations employees and
, managers, Mr. H. W. Arrowsmith (SEG President) discussed the NOV and
} management's" commitment to conduct operations in compliance with all
- regulatory, license, and procedural requirements. Mr. Arrowsmith emphasized every employee's responsibility to ensure that all radiation protection related documentation is ampleted accurately and truthfully and in accordance with
- procedural requirients. The potential for disciplinary action if an employee
! engages in this type of misconduct was also discussed.
f These meetings were conducted November 17, 1995.
j
- A letter will be transmitted to SEG's offsite employees involved in j decommissioning / decontamination activities relaying Mr. Arrowsmith's message.
This action will be completed by December 6,1995.
I J
4 i The SEG Corporate General Employee Training (initial and refresher) syllabus
- will be revised to include a discussion of the events leading to this NOV and the j importance of correct and accurate documentation, including appropriate methods j for correcting documentation omissions.
J
$ This action will be completed by December 20,1995.
m *s.o u o w ,
P 6 M ~/
1
- NRC - Response to Notice of Violation i Appendix A November 29,1995 In addition, letters will be transmitted to tho'se current SEG FSV employees that i
received individual NRC letters of concern in connection with the NOV reiterating the seriousness of misrepresenting or falsifying docuinents andm' forming them that a copy of the NRC letter will be placed in their company personnel file.
This action will be completed by December 20,1995.
4 5.0 DATE WHEN FULL COMPLIAh i WILL BE ACHIEVED The substantial corrective actions already taken by SEG, together with the other members on the Westinghouse Team and PSCo, have resulted in SEG currently being in full compliance with the requirements of 10 CFR Part 50.5 and in mechanisms being in place to prevent recurrence at FSV. In addition, certain corporate corrective actions will be complete on the dates noted above. !
i
(
l i
n:995-ozuzo 949 p 7g7 s
l
. 1 h PublicService- . ,,, s, .
Company of Colorado P.O. Box 840 16805 WCR 191/2; P!atteville, Colorado 80651 A. Clegg Crawford November 29,1995 $',n"Q",'n, operaten suppen Fort St. Vrain ,
P-95104 U. S. Nuclear Regulatory Commission 5,f ,
ATTN: Document Control Desk Washington, D. C. 20555 - D 3 0M
~
Docket No. 50-267 f' 20N;:,-
i
SUBJECT:
Reply to a Notice of Violation (NRC Inspection Report 50-267/94-03 and Office of Investigations Reports 4-94 010 and 4-95-015, EA 95-110 and EA 95-185)
REFERENCE:
NRC Letter, Callan to Crawford, dated October 30,1995 (G-95181)
Gentlemen:
This provides Public Service Company of Colorado's (PSCo) response to the Notice of Violation transmitted by the referenced letter, regarding activities at the Fort St. Vrain (FSV) Nuclear Station. This Notice of Violation involved radiation survey documentation irregularities that were discovered during an independent investigation initiated by PSCo and conducted from March 1994 to March 1995, by the law firm of Stier, Anderson, r.nd Maloni:. NRC's Office of Investigations reviewed the Stier, Anderson, and Malone report and completed their investigation in May 1995.
During these investigations, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600 (60 FR 34381, June 30,1995), the violations are set forth below:
Falsification of Radiation Protection Survey Dov eotation 10 CFR 50.9 requires, in pan, that information required to be maintained by the licensee shall be complete and accurate in all marxial respects.
Contrary to the above, in Fe': uary, hurch, and September 1993, records of radiation surveys were created which were not complete and accitrate in all kl '
/5/9 /U AAM %- 0%[s h wn- ~
i
i l
l P-95104 1 November 29,1995
. Page 2 l l
1 material respects. Specifically, during February and March, 1993,14 records t which were required to suppon the release of material from the facility, and 20 records, which were required to support work conducted under various radiation work permits were dated and signed to falsely indicate that they had been created substantially earlier. These records also contained false information regardmg survey instrument usage and calibration dates. In September 1993, a survey
- record supporting release of the hot service facility plug was created to indicate that the survey had been completed when in fact it had not. These records were material to the NRC because they were required to ensure compliance with the regulations in 10 CFR Pan 20.
This is a Severity Level III violation (Supplement VII).
'Ihis violation involves actions on the pan of both PSCo and the Scientific Ecology 3 Group (SEG), a major contractor on the Fort St. Vrain decommissioning project. As the .j licensee for the Fon St. Vrain Nuclear Station, PSCo assumes responsibility for the violation, and this letter 2ddresses PSCo's reasons for the violation and corrective actions talr.c by PSCo in response. Scientific Ecology Group actions are being addressed via separate correspondence, in response to the Notice of Violation issued to them on October 30,1995 (EA 95-164).
- 1) Peason for the Violation l This violation is admitted. PS o concurs with the independent assessment conducted by the law firm of Stier, Anderson, and Malone that there were three instances of radiation protection survey records falsifications:
In February 1993, 14 radiation protection survey records documenting the ;
unconditional release of material from September to December of 1992 were '
backdated; In March 1993,28 radiation protection records documenting surveys conducted to suppon work in Radiation Work Permit (RWP) controlled areas in the first quaner of 1993 were or appeared to have been backdated; although the NRC cited 20 RWP survey records as being backdated, the Stier, Anderson, and Malone repon identified that 9 RWP survey forms were admittedly backdawl and 19 RWP survey forms appeared to have been backdated; and In September 1993, one radiation protection survey documenting the unconditional release of a hot service facility plug was falsified.
k
__y <
i .
i p.
t 4
P-95104
{ November 29,1995 Page 3
{
There are numerous contributing causal factors for this violation which will be addressed i
in this response letter. De underlying reason why PSCo did not prevent or identify these records falsifications at an earlier time is that our management oversight over contractor activities was more focused on project and task performance than on
- documentation requirements; in addition, based on strong performance indicators in the radiation protection area, we had developed an inappropriate sense of satisfaction and j complacency in this area.
J 4
At the beginning of the decommissioning project, PSCo and the Westinghouse Team developed a comprehensive system of work controls to ensure that dismantlement work act:vities were carried out as described in the Decommissioning Plan. As the Westinghouse Team was aggressively removing components and interferences from the l Fort St. Vrain Reactor Building, PSCo's oversight personnel were working closely to
)
4 ensure compliance with our work control requirements and with good industrial safety practices. With regards to radiation protection, PSCo focused on ensuring that personnel i used appropriate monitoring instrumentation and dosimetry, wore protective clothing where required, followed RWP requirements, survey.d areas where work was being l performed, and surveyed material prior to release. The focus was on performance of i
required tasks, and not on recordkeeping and documentation of completed tasks.
)
j PSCo's oversight of records and documents was conducted during Quality Assurance j audits. Records were reviewed on a sample basis, after they were approved by Radi=rian !
! Protection supervision and considered as completed records. This type of review checks ,
- for completeness of records, but would not likely detect a survey record that had been j created after the fact and then, backdated to appear correct. Parenthetically, PSCo was I
~
only made aware of the survey records discrepancies because a survey technician came forward and volunteered the information; even the Stier, Anderson, and Malone investigation had difficulty determming whether a record had been falsified if the 5 preparer did not admit it. A Quality Assurance audit in June 1993 did detect errors in documentation for radioactive waste shipping and instrument calibrations. In hindsight, this deficiency was an indication that radiation protection records should have been examined more closely. but this was the first critical observation of a ra:iiation protection program that, by all other measures, had been considered strong.
De strong performance of the radiation protection program was a significant factor behind PSCo's inadequate management oversight in this area. Based on low worker exposures, a low number of individual contaminations, numerous worker suggestions in the ALARA suggestion program, and, at the time, zero positive bioassay results, PSCo felt that there was a strong ALARA program in effect. Also, the NRC's Resident Inspector, who was a certified health physicist, and subsequent Region IV inspectors provided positive reports in the radiation protection area, at one time stating that we were
" maintaining good radiological control" of the facility. All of these strong positive i
- e P-95104 November 29,1995 Page 4 1
indicators contributed to a false sehse of security and an inappropriate complacency about j
the radiation protection orogram and the amount of oversight required in this area. l
' 1 Another contributing cause factor was that PSCo did not establish a cohesive team !
1 between all of the decommissioning contractors and PSCo at the beginning of the project.
This failure to build a team attitude contributed to a lack of open communications that 1
may have permitted an identification of radiation protection records concerns at an earlier j time.
I-
- 2) Corrective Stem That Have Been Taken And The Results Achieved 4
- PSCo's immediate and long term corrective actions have been comprehensive and extensive, as described during a briefing to NRC Region IV on August 4,1994, and i during the predecisional enforcement conference on August 29,1995. The August 4 j
1994 meeting presentation materials were entered onto the docket as part of the NRC's j
meeting summary letter-dated August 17, 1994, from S. J. Collins (NRC) to A. C.
Crawford (PSCo). The presentation materials from the predecisional enforcement conference were entered omo the docket as part of the meeting summary letter dated September 1,1995, from R. A. Scarano (NRC) to A. C. Crawford (PSCo). !
PSCo's corrective actions and the results achieved are summa ized below:
Third Party Investigation The Stier, Anderson, and Malone independent assessment was a comprehensive and thorough review wherein the investigators were not restricted in any manner. This investigation also dealt with workforce problems regarding discrimination for engaging in protected activities, which has been addressed separately with the NRC [see NRC letter dated September 25,1995, from R. A. Scarano to A. C. Crawford, EA 95-045].
The Stier, Anderson, and Malone assessment required over one year before the final report was issued, at a cost to PSCo of approximately $1 million. Over a nine month period of time, more than 100' individuals were interviewed, which spweeuted approximately 50% of the workforce at the time, and 15,000 pages of documentation were reviewed. PSCo also committed one full time radiation protection professional to assist the investigation team.
This investigation 6rst identified the problem of potentially falsified radiation protection records and also provided a documented, independent definition of the extent of the problem. This investigation also allowed PSCo to review SEG's corrective actions in
S i
P-95104 November 29,1995 Page 5 l j
their Radiation Improvement Program and to confirm'with a large degree of confidence i
that all identified problem areas were addressed.
Work Stoppage
! Upon confirmation that radiation protection survey records had apparently been falsified,
! the Westinghouse Team stopped physical work on decommissioning activities, with PSCo's endorsement. The work stoppage occurred on March 25,1994, and on March
! 28, the following Monday, PSCo issued a written stop work order that identified l
numerous provisions that needed to be addressed prior to restart. During the 16 day l
work stoppage, PSCo met with senior executives and all site management of SEG and !
Westinghouse, to discuss management responsibilities and ccre values. High standards of business ethics were stressed, including open communications,7rncedure compliance, and teamwork.
i One of the requirements identified by PSCo was for the Westinghouse Team to prepare !
an assessment of the safety significance of the radiation protection survey records l discrepancies. Prior to resuming physical work activities, the Fort St. Vrain Decommissioning Safety Review Committee reviewed and approved the Westinghouse Team's safety assessment and, in addition, the status and appropnateness of their corrective actions. The safety assessment concluded that there were no significant safety implications, that materials released from the FSV site had been surveyed prior to release and no radioactive material was inappropriately released from the site, and that workers and members of the public did not receive unexpected radiation exposures.
Enhanced Oversight of Material Releases PSCo enhanced its oversight of material release activities with three additional actions:
PSCo's radiation protection oversight personnel perform independent surveys of matenal being released, on a sample basis; they observe material release surveys being performed by SEG technicians, also on a sample basis; and they review all material release records and survey data prior to release of the material for unrestricted use. In addition to activities undertaken by SEG to enhance the material release program, these actions have provided PSCo with total confidence that material is released in accordance with procedure requirements.
i.
j P-95104 i November 29,1995 Page 6 j Enhanced Communications and Ovemight i
PSCo site management met with all oversight personnel to emphasize the importance of i
the oversight function and to explain management expectations. This effon was also pan j of oversight enhancement activities that were implemented in response to the workforce discrimination problem identified earlier. In conjunction with those activities, PSCo increased the presence of all oversight personnel in the field, not just in the radiation l protection area. Although many PSCo personnel had been observing project performance j in the field, a group of radiation protection professionals, engineers, quality assuran:e j
personnel, and PSCo's safety advisor were tasked with performing monitoring and other field observations, and reporting to management at least twice per month. Management emphastzed to this oversight group the importance of maintaining open communications and of reviewing field documentation on a day to day basis, instead of waiting for the j final record review. Oversight personnel have established relationships with SEG i rudution protection personnel and emphasized teamwork, so that concerns can be identified at an early stage and brought to appropriate management attention. The enhanced oversight effort has permitted a more directed oversight effon in all disciplines, and has provided greater management awareness of project concerns.
2 l PSCo has also initiated meetings between management of PSCo and the WT on a weekly basis, which provide an opponunity to discuss various concernt,, including any regarding j the radiation protection program. In addition, PSCo has implemented an cxit interview
! program for PSCo and contractor employees whereby employees who are terminated or l
- released from the project may jdentify any concerns. ;
1 j
- Expanded Fonnal Monitoring Program 4
In radiation protection and all project disciplines, PSCo has instituted a program to i conduct documented monitorings. In areas such as material releases, respiratory protection, or access control, checklists are prepared based on procedure requirements
! to ensure complete and directed observations by oversight personnel, and to ensure that day to day documentation is reviewed in addition to final records. Monitoring repons !
document specific tasks observed, individuals contacted, procedures used, and comments or concerns identified by the oversight individual. These reports are then provided to the quality assurance manager and the manager of the area being monitored; problem repons are initiated for violations or serious concerns. The expanded monitoring !
program has provided a more consistent, organized, methodical, comprehensive, procedure based oversight effen that also highlights concerns so that they receive appropriate management attention.
i i
! P-95104 i November 29,1995 Page 7
- Review of SEG Radiation Improvement Pro' gram i
{ PSCo management and oversight personnel have reviewed the Management Oversight i Risk Tree (MORT) analysis of SEG's radiation protection program, and the Rattimrion
- Improvement Program that SEG instituted in response. All improvement items that were j incorporated into their revised procedures were approved by PSCo, and some have been
! included in monitoring checklists as mentioned above. In addition, in February 1995,
! PSCo retamed an independent consulting finn to perform a special audit for the FSV i i Decommissioning Safety Review Committee. This special audit reviewed the MORT '
findings and the 339 corrective actions in SEG's Radiation Improvement Program. In July 1995, PSCo's Quality Assurance audit of radiation protection activities followed up on the special audit observations. These efforts have provided PSCo with confidence that the identified deficiencies in the radiation protection program have been adequately addressed.
- Hot Line In conjunction with our response to the workforce discrimination problem noted previously, PSCo established a telephone line whereby individuals can identify radiation protection or other concerns in a manner which is independent of the supervisory chain.
The hot line is an off-site, monitored telephone line, and is identified on various site-wide bulletin boards. Individuals using the hot line may remain anonymous, if desired, ,
and concerns are addressed to appropriate corporate management. The hot line has been used on three occasions tot date, although none of these calls has dealt with documentation irregularities. -
- 3) Corrective Stens That Will Be Taken To Avoid Further Violmela==
PSCo and the Westinghouse Team will continue the programs and management involvement described above. PSCo will continue their oversight presence and will periodically monitor all aspects of the radiation protection program by personal observations, independent surveys, records reviews, and documented monitorings. The results of these oversight activities will be communicated to management and any identified problems will be documented through our corrective action system. This will maintain management awareness of field concerns and allow management to direct oversight emphasis.
P-95104 November 29,1995 Page 8
- 4) Date When Full Comnliance Will Be Achieved PSCo considers that the Fort St. Vrain decommissioning project is currently in full compliance with the requirements of 10 CFR 50.9, and has been in full compliance since shortly after the concern was identified in early 1994.
PSCo considers that our corrective actions have been shown to be effective. No further indications of falsified records have been identified during subsequent records reviews, monitorings, or during the 1995 Quality Assurance audit of the rarfinrinn protection i program. In addition, no allegations or indications of falsified documents have been received.
Our actions to promote open communications and ensure an atmospher. " workers feel comfortable raising concerns in the radiatior protection area have a. . -
.1 shown effective. Concerns have been ideatified to rnanagement and have bee. erfectivelf l resolved, although none have involved falsified radiation protection records.
Closing j l
PSCo regrets the events and actions that resulted in the serious violation identified above.
l However, we consider that the extensive corrective actions undertaken by both PSCo and !
SEG, our corporate emphasis on quality and regulatory comoliance, and our strong corporate team approach will ensure completion of the Fort St. Vrain decommissioning i project in a manner that protects the radiological safety of our workforce and the general public.
if you have any questions regarding this information, please contact Mr. M. H. Holmes at (303) 620-1701.
Sincerely, i
'8 A. Clegg Crawford Vice President )
Engineermg and Operations Support ACC/SWC i
P-95104 November 29,1995 Page 9 cc: Regional Administrator, NRC Region IV Mr. Roben M. Quillin, Director Radiation Control Division Colorado Department of Public nealth and Environment Mr. H. W. Arrowsmith President Scientific Ecology Group l
~
i*
1
- UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION 4
In the Matter )
)
1 Public Service Company of Colorado ) Docket No. 50-267 l Fort St. Vrain .
)
AFFIDAVIT l' A. Clegg Crawford, being first duly sworn, deposes and says: That he is Vice i President, Engineering and Operations Support, of Public Service Company of Colorado, I i the Licensee 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 theran are true
- and correct to the best of his knowledge, information and belief.
} l M '
A. Clegg Crawford '
Vice President 4 I
Engineering and Operations Support I
STATE OF [de/IM )
COUNTY OF .bA'A , )
Subscribed and swom to before me, a Notary Public on this 2M day of //ot/entJ4L,1995 Notary Publidi #
My commission expires 7/C#6M[ML 2 9 .19ff i
4 l
l l
l i
I l
3 f (o ~ h$$ - 50 ls S 9
l u
asy~A+'s 2 .a~ a & gg l S q u 's d el 4 9- m g a p 1
l 1
1 I
I
-