ML20137H237
| ML20137H237 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1994 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20137H118 | List: |
| References | |
| FOIA-96-434 NUDOCS 9704020103 | |
| Download: ML20137H237 (13) | |
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k NUCLEAR REGULATORY COMMISSION t j REGION IV 8 611 RYAN PLAZA DRIVE, SUITE 400 Y, [ AR LINGTON, TEXAS 76011 8064 MAY 5 BIM MEMORANDUM FOR: Russ Wise, Allegations Coordinator FROM: Samuel J. Collins, Director Division of Radiation Safety and Safeguards
SUBJECT:
REVIEW 0F OI TRANSCRIPTS FOR SAFETY / TECHNICAL ISSUES The OI transcripts that were submitted to DRSS for review have been screened for any potential safety / technical concerns. As you may be aware, Mr. Robert Evans of the NHLB sat in on most of the interviews; therefore, we have already addressed most of the identified concerns. Other concerns identified will be followed up on during future visits to the facility.
Attached are written responses to each of the identified concerns and recommended DRSS responses.
If you have any questions, we will be pleased to discuss them with you.
5 e . n ector
/Division of Radiation Safety and Safeguards Attachments:
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Interviewee: K.L. Zahrt. SEG Radiation Protection 00erations Supervisor Concern: "Maybe we didn't convey enough to them (the staff, including craft workers) that anybody can write...a radiological occurrence
, report" (Page 22).
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...the craft people have felt that they never. ..could. . . write an i ROR." (Page 27). )
DRSS Comment: There previously was a perception at the facility that only radiation protection staff personnel could write RORs although the Decommissioning Plan clearly states that anybody could write RORs. This confusion was apparently cleared cp in subsequent licensee contractor staff meetings.
i and by distribution of internal memorandums to staff members.
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- DRSS Response
No response required other than ensuring the ROR program is effectively implemented during future inspections.
. Concern: "My staff felt that there was not adequate disciplinary actions <
given out... based on this one-two-three strikes philosophy" (Page 24). 4 DRSS Comment: The "one-two-three strikes, your out" was a philosophy that i was' verbally stated early in the project to ensure craft 1
. worker compliance with radiation protection rules. The philosophy was not written in any document but was common knowledge. The licensee contractors have since retracted this philosophy in staff meetings and in internal memos.
It should be noted that this subject area was discussed in most interviews.
DRSS Response: No response required.
Concern: "Did I agree with some of the corrective actions (for RORs)?
4 Probably not..." (Page 54).
DRSS Comment: This statement implied that the RP operations supervisor was not pleased with corrective actions taken with problematic personnel performance, and not technical issues.
DRSS Response: The licensee and the NRC now have a heightened awareness of the ROR program and its implementation. RORs are briefly discussed in Inspection Report 94-02 (currently in draft).
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Interviewee: C. Calton, Westinghouse pro.iect Director Concern: "I... learned that there were some misconceptions and concerns over the (ROR) program" (Page 20-21).
...some of the group (RP technicians) responded...that they did not feel like the ROR program was working" (Page 31).
DRSS Comrcent: These statements were made in response to RP technician comments that they felt the ROR corrective actions were of concern, not timely, u.d inadequate for the circumstances.
The licensee contractor held a series of meetings after this discovery to clarify management's expectations with the program to their staff.
DRSS Response: The licensee.has taken positive action to ensure proper implementation of the ROR program. The NRC also has heightened awareness of this problem area. No specific response to this issue is required at this time other than ensuring the ROR program is effectively implemented during ;
future inspections.
Concern: "The general trend is RORs were written on engineers and supervisors but not craft personnel" (Page 37).
DRSS Comment: This trend was NRC identified during a review of the R0R logbook during the investigation.
DRSS Response: This subject area is discussed in Inspection Report 94-02, where the most blatant example of a failure to follow procedures and RWP requirements is analyzed. Further NRC review of this trend will depend on the licensee's response to the Inspection Report.
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! 4 I Interviewee: M. H. Holmes. PSC Proiect Assurance Manager Concern: ...as mentioned on Page 6 (of the PSC audit 93-04 of the radiation protection program) is that the radiation protection technician's procedural knowledge was weak in the radiological occurrence report. Do you have any idea on if corrective action
! was taken in response...?" (Page 16-17).
...eight... contamination boundary breaches were observed and an individual did not frisk for contamination after exiting the (radiological) area...do you have any idea if corrective actions were actually implemented...?" (Page 17).
DRSS Comments: The NRC interviewers were concerned with PSC's failure to I follow up in a timely manner on proposed corrective actions to PSC- QN audit findings.
l DRSS Response: This subject area is discussed in Inspe.ction Report 94-02.
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Interviewee: F. J. Borst. PSC Facility Support Manaaer i
Concern: "I do feel there are certain situations where that communication link (between PSC and SEG) could be improved" (Page 17).
DRSS Remarks: This comment is repeated several times in the interviews.
DRSS believes the communication link between all departments and levels should be improved. The licensee is aware of
, this area of concern and plans to implement some sort of !
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DRSS Response: DRSSwillperformaninspectioninthenearfuturethatwili
, focus on the licensee's ability to provide adequate oversight of the contractor's actions. This inspection will also look at the communication link.
Concern: "SEG... agreed that there appeared to be a (negative ROR) trend with MK management..." (page 30). l I .DRSS Remarks: This comment suggested that the licensee was not providing l adequate levels of contractor oversight, trending of ROR '
events, and corrective action implementation.
i i DRSS Response: As mentioned above, DRSS will review the licensee's ability i 1 to provide adequate levels of oversight during the !
4 performance of the Audit module. The licensee's 4 effectiveness in implementing the ROR program will be l monitored over time.
- Concern
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...there was a general feeling that production and schedule came
- ahead of safety" (page 45).
3 DRSS Remarks: This concern is discussed in several.NRC inspection reports, including 92-12 and 93-01.
j DRSS Response: No imniediate response to this concern is required.
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Interviewee: M. E. Niehoff, PSC Engineerina Manager l
4 Concern: "
...it is... unusual that follow up items (to a PSC audit) be left
- open for this long (8-9 months)...Is there a reason why it has taken so long to address these items?" (Page 16).
"I don't have a reason that I know of as to why is has taken so
- long" (Page 16).
DRSS Comments: The interviewee was responding to questions as to why audit findings in a PSC radiation protection program audit were j still open after 8 months.
2 i DRSS Response: This issue is discussed in Inspection Report 94-02.
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Interviewee: M. J. Fisher. PSC Deputy Program Manaaer i
Concern: "There has been two instances where we (PSC) believed that the potential was there that they .(MKF) had pushed production ahead of safety..." (Page 31).
f DRSS Comment: These two instances are documented in NRC Inspection Reports !
92-12 and 93-01. )
DRSS Response: No response required for this specific concern.
Concern: ... incidents were not being reported up through the management 4
- chain in Public Service Company..." (Page 39).
l DRSS Comment: This statement is subjective in nature; however, DRSS believes that the licensee's communication chain should be improved based on recent events..
DRSS Response: DRSS will review the licensee's planne'd corrective actions J
to this concern. Further NRC follow up actions will depend on the licensee's resolution, or lack of resolution, of the concern. No immediate response is required for this specific concern.
DRSS Comment: The interview transcript seemed to end prematurely. The last statements suggest that M. J. Fisher had a final comment that was not recorded.
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I Interviewee: J. E. Parsons. SEG Proiect Radiation Protection Manager Concern: ...I think there was a perception of a problem by some of the technicians that in their opinion, that the (R0R) program did not carry the weight of enforcement that it should" (page 18-19).
DRSS Remarks: This comment was in reference to the idea that certain HP technicians thought that the ROR program was ineffective in "recalibrating" probl.ematic people. Both the contractor and the licensee are aware of NRC concerns with ROR corrective actions. This subject area is briefly discussed in NRC Inspection Report 94-02.
4 DRSS Response: The NRC will monitor the licensee's corrective actions taken in response to this area of concern prior to taking any specific actions.
Concern: ...there had been another individual that had questioned the ROR program from a technical standpoint, why we did things the way we did" (Page 20).
DRSS Remarks: This concern seemed to challenge the technical aspects of the ROR program. Very little was provided to indicate specifically what the technical issue was; however, the ROR program is consistent with the requirements in the approved Decommissioning Plan.
DRSS Response: No response is required because the program follows the requirements of the Decommissioning Plan.
Concern: "(The Radiation Protection Operations Supervisor) ... evaluates RORs with the technicians as they are presented, and that not all RORs considered are processed" (page 25-26).
DRSS Remarks: This issue was of major concern to the NRC. The RPOS was suspected of screening RORs prior to the RORs entering the system. The RPOS was not authorized to do this. The RPOS is no longer onsite for other reasons. This subject area is under review by 01.
s DRSS Response: No imediate response is required. The implementation of the ROR program will be monitored by the NRC to ensure compliance with procedure requirements.
Concern: ...the ROR is not an ROR until Mr. Dick Sexton (SEG Technical Support Supervisor) determines that that is a radiological occurrence report." (page 28).
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DRSS Remarks: This comment seems to imply that an ROR, although written, is not an official R0R until the form is given a tracking number. The concept that the SEG staff can screen RORs prior to their input into the system is not allowed by the program. This subject area is under 0I review.
DRSS Response: No response is required at this time. Future inspections will ensure that the ROR program is properly implemented.
Concern: "
...the (QA Audit 93-04) inspection stated that there were 83 radioactive shipments that left (the) site with the paperwork improperly filled out. In fact, he (the lead auditor) was talking about there were 83 line items on the rad waste shipping checklist that were not marked N/A." (Page 64-65).
DRSS Remarks: This coment was technically incorrect. There were 91 I radioactive material shipments. A total of 16 cases of missing signatures, blanks, incorrect form usage or blanks incorrectly filled in were identified by the audit team.
Two examples of af sing forms were also identified and the forms were reprouuced.
DRSS Response: DRSS will confirm that this subject area is not associated ,
with the recent falsification of records issues.
Concern: "
...part of the friction (between SEG RP technicians and the MKF supervisors) was a lack of understanding that the HP technicians roles are independent of the overall project management...in fact, some of them (the technicians) believed it was a direct line management, that the technicians had a reporting responsibility to the MK supervision" (page 78-79).
DRSS Remarks: These comments suggested that the RP technicians were not fully aware of their chain of command. This problem may be the result of training or interdepartmental communications.
DRSS Response: This iubject area will be reviewed in 'a future inspection.
DRSS wants to get a good ur % rstanding of the licensee's ability to oversee, contr5., comunicate, and audit the contractor's actions. The training area is briefly discussed in Inspection Report 94-02. The othe h reas will be reviewed during the Audit module inspection.
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9 Interviewee: D. W. Waremboura. PSC Proaram Manaaer Concern: ...that original (NRC) allegation was without foundation." ;
(Page 22). '
.DRSS Comment: The NRC submitted NRC Allegation No. RIV-93-A-0025 to PSC for review and comment. The licensee responded on January 17, 1994. DRSS believes that the licensee responded to the wrong event. The original allegation involved core drilling operations on the per._fhtor of the reactor building, which occurred in t a -July time frame (the allegation was !
prtved167,19 . The licensee responded to the NRC l y letter by stating, "from the information provided, it appears that the activity of concern was the removal of F4 shield plugs from the fuel storage well enclosures during M the first two weeks of March 1993." In other words, the licensee believes the original allegation was "without foundation," however, they responded to the wrong incident.
One other comment about the original allegation. The l telephone conversation notes state that the event occurred '
on the upper floor of the reactor building. If this person meant the refueling floor, then this location is called Level 11. The alleged statement of concern that was sent to the licensee may have stated that the work occurred on Level i 10, one floor below the refueling floor. This difference in '
locations may have misdirected the licensee in their response letter.
DRSS, Response: DRSS will await the Allegations Coordinator response to these comments prior to undertaking any actions.
Concern: ...there were several other instances (involving Mr. D. Hicks, a MKF assistant superintendent) that had occurred in the past that had not necessarily been documented, written up on RORs." ,
(Page 25).
DRSS Remarks: The comment seemed to suggest that several events that met the criteria for RORs were not documented on ROR forms. The NRC received a tip during the 01 interviews thafthe radiation protection technicians felt that writing up selected individuals, specifically this Mr. Hicks, was a waste of time. 01 is investigating this area of concern.
DRSS Response: No response is required for this specific concern, other than ensuring that the licensee is effectively implementing the ROR program during future DRSS inspections.
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Interviewee: M. Kachun. Westinghouse Senior 0A Encineer l
No additional safety / technical concerns were identified during the review of -
this person's transcripts. I Interviewee: T. J. Dieter. MKF Superintendent !
l No additional safety / technical concerns were identified during the review of '
this person's transcripts. ;
l Interviewee: W. J. Hug MKF Operations Manaaer i
No additional safety / technical concerns were identified during the review of this person's transcripts.
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In UNITED STATES g3 EEcoq d g NUCLEAR REGULATORY COMMISSION
[ .) )f.lf 1, j REGION tV 1gvh [j! 8' 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON. TEXAS 760118064 JUL I 51994 Dockets: 50-267 72-009 Licenses: DPR-34 SNM-2504 Public Service Company of Colorado ATTN: A. Clegg Crawford, Vice President Electric Operations P.O. Box 840 Denver, Colorado 80201-0840 The purpose of this letter is to confirm arrangements made with your staff for a management meeting in the Region IV office on Thursday, August 4, 1994, at 2:30 p.m., Central Day'ight Time. The meeting was requested by you and your staff to discuss the status of two of your internal investigations and the resulting assessments of the investigations. This meeting is open to the public per your request.
Should you have any questions concerning these arrangements, we will be pleased to discuss them with you.
Sincerely, S irector
' Division of Radiation Safety and Safeguards cc:
Public Service Company of Colorado ATTN: M. H. Holmes Project Assurance Manager 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 GA International Services Corporation Fort St. Vrain Services ATTN: David Alberstein, Manager P.O. Box 85608 San Diego, California 92138
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Public Service Company of Colorado 1 AT??: D. D. Hock, President and i Chief Executive Officer !
P.O. Box 840 l Denver, Colorado 80201-0840 !
0'Malley & Associates, P.C.
ATTN: Salie B. O'Malley j 950 South Cherry Street, Suite 520 :
Denver, Colorado 80222 j i
Chairman Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 1
. Regional Representative Radiation Programs Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver, Colorado 80202-2413 Department of Health j ATTN: Robert M. Quillin, Director i Radiation Control Division 1 4210 East lith Avenue l Denver, Colorado 80220 l Colorado Public Utilities Commission ATTN: Ralph Teague, P.E.
1580 Logan Street OL1' Denver, Colorado 80203 Commitment Control Program Coordinator Public Service Company of Colorado 16805 Weld County Road 19-1/2 1 Platteville, Colorado 80651 .
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