ML20137H255

Forwards Copy of OI Rept,Reviewing Licensee Investigation Rept & Confirmed Licensee Conclusions That Radiation Survey Records & Radiation Work Permits Falsified.W/O Encl

ML20137H255
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/03/1995
From:	Sanborn G NRC
To:	Beth Brown, Callan J, Jonathan Montgomery NRC
Shared Package
ML20137H118	List: ML20137H113 ML20137H133 ML20137H173 ML20137H237 ML20137H247 ML20137H255 ML20137H265 ML20137H295 ML20137H311 ML20137H320 ML20137H353
References
FOIA-96-434 NUDOCS 9704020110
Download: ML20137H255 (1)

Text

..

.P

)

i June 3, 1995

]

.0TE T0:

Joe Callan 2.

John Montgomery 3.

Bill Brown j

4.

Russ Wise 5.

Bill Jones j

6.

Sam Collins > Ross Scarano

.l 1

7.

Chuck Cain (2) i FROM:

Gary Sanborn, Enforcement Officer

SUBJECT:

01 4-94-010 (Fort St. Vrain), issued 5/26/95 '

Attached is a copy of an O! report where OI reviewed the licensee's investigation report and confirmed the licensee's conclusions that radiation survey records and

)

radiation work permits were falsified.

We need to review this report to determine an enforcement approach. Please contact me if you need to see any of the exhibits.

This matter will be discussed at an enforcement board to be scheduled at a later date.

i NOTE: I PRESUME WE WILL BE DISCUSSING THIS WITH OE, ET. AL., DURING AN UPCOMING j

REGULARLY SCHEDULED CONFERENCE CALL WHICH, BY THE WAY, ARE NOW SCHEDULED AT 12:30 i

ON THURSDAYS, NOT TUESDAYS.

cc: Joe Gray via E-mail w/o' attachments f, S. c6 cm a bra m M sw bd cAud N Q a$2A y i

er"* f 2

WARNINGiTATTACHED:NATERIAt!?MAYJCONTAIN;INFORMATIONATHATiSHOULD{NOT[BE DI_SS,EMINATEDj 0R).D.ISCUSSE,010VTSIDELOF-(THE;NRC; 9704020110 970324 PDR FOIA SAURO96-434 PDR

- - ~ ~y r n u

.. ~ -.

~..- - -. -

-.. -. ~....

~.,.. ~.

.-~

i gae aa r:4,,

UNillDSTATES

[

/

NUCLEAR REGULATORY COMMISSION R EGION IV 0,

611 RY AN PLAZA DRIVE, suite 400

,f ARLINGTON TEXAS 76011 8064 June 16, 1995 s

Public Service Company of Colorado ATTN:

A. Clegg Crawford, Vice President

.i Electric Operations P.O. Bo:: 840 Denver, Colorado 80201-0840 I

SUBJECT:

ENFORCEMENT-CONFERENCE WITH FORT ST. VRAIN This refers to the Enforcement Conference conducted-at the NRC's request in the Region IV office on June 1, 1995. This meeting related to activities authorized by NRC License DPR-34 for Fort St. Vrain and was attended by those on the attached Attendance List.

The subjects discussed at this meeting are described in the enclosed Meeting Summary.

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2, i

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure l

will be placed in the NRC's Public Document Room.

Should you.have any questions concerning this matter, we will be pleased to

{

discuss them with you.

i Sincerely,-

)

Samuel J. Collins, Director Division of Radiation Safety and Safeguards Docket:

50-267 License: -DPR-34

Enclosure:

Meeting Summary w/ attachments cc w/ enclosure:

Public Service Company of Colorado ATIN:

M. H. Holmes Project Assurance Manager 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 i

l 1

i l

(

< ?$k Public Service Company of Colorado GA International. Services Corporation Fort St. Vrain Services ATTN: David Alberstein, Manager P.O. Box 85608-

. San Diego, California 92138 Public Service Company of Colorado ATTN:

D. D; Hock, President and Chief Executive Officer P.O. Box 840 Denver, Colorado 80201-0840 Public Service Company of Colorado ATTN:

Patricia T. Smith, Senior Vice President and General Counsel P.O. Box 840 Denver, Colorado 80201-0840 Chairman Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Itegional Representative Radiation Programs Environmental Protection Agency l

1 Denver Place 999 18th Street, Suite 1300 Denver,-Colorado 80202-2413 Colorado ~ Department of Health ATTN:

Robert M. Quillin, Director Radiation Control Division 4300 Cherry Drive South Denver, Colorado 80220-1530 Colorado Public Utilities Commission ATTN:

Ralph Teague, P.E.

1580 Logan Street OLI Denver, Colorado 80203 l

Commitment Control Program Coordinator Public Service Company of Colorado 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Morrison Knudsen Corporation i

ATIN:

R. R.-Edmister, Associate General Counsel i

MK-Ferguson Plaza 1

1500 West 3rd Street Cleveland, Ohio 44113-1406 i

i

I X

Public Service Company

• of Colorado-bcc:

DMB (IE01)

L. J.' Callan, RA-

' J. M. Montgomery, DRA i

S. J. Collins, D/DRSS l

-R. A. Scarano, DD/DRSS C. L. Cain, DRSS/FCDB F. A. Wenslawski, WCF0, R. J. Evans, DRSS/FCDB J. V. Everett, DRSS/FCDB L. C. Carson, DRSS/FCDB l

M. L. McLean, DRSS/FCDB G. M. Vasquez, DRSS/FCDB C.

L'. Pittiglio, NMSS/DWM (T7F27) l P. B. Erickson, NRR/DOPS (011B20)

J. D. Weiss, OC/LFDCB (.T9E10)

MIS System i

RIV Files FCDB i

i

~

l I

l l

l DOCUMENT NAME: 0:\\FCDB\\RJE\\ MEETING.FSV To receeve a cory of pus document. mdeceu a the bos *C" Copy wahout nonchment/ enclosure *E'. Copy with snachment/enclosurs *N'. No Copy l

OFFICE RIV:FCDB Q.

C:FCDB E

DD:DRSS /a/ 0:DRSS2/

2 NAME.

RJEvans VA N CLCain W RAScarano SJCollins l

r r

,1 i

DATE 6/ lz/95 6/1'k/95 6/r'1/95 6/jy/95 l

i i

i l

L

\\.

=

4

. ]

a j

ENCLOSURE i

)

MEETING

SUMMARY

Licensee:

Public Service Company of Colorado P. O. Box 840

[

Denver, Colorado 80201-0840 i

i facility:

Fort St. Vrain Nuclear Generating Station l

Licenses:

DPR-34 i

SNM-2504 Dockets:

50-267 72-009

Subject:

Enforcement Conference On June 1, 1995, representat'res of Public Service Company of Colorado (PSC),

i Morrison Knudsen-Ferguson (Mrf), and Westinghouse Electric Corporation met with Region IV personnel in Arlington,' Texas, to discuss the apparent violation of 10 CFR 50.7 during decommissioning activities at Fort St. Vrain.

l The attendance list is attached as Attachment I to this Letter.

Licensee-handouts at the meeting are attached as Attachment 2.

The meeting was held at the request of the NRC.

1 4

The meeting agenda included introduction and opening remarks by the NRC,

~

introduction and opening remarks by the PSC Vice President of Electric Operations, a historical overview, concerns and corrective actions summary by the PSC Decommissioning Program Director, MKF actions by the Morrison Knudsen Executive Vice President, and closing remark; the PSC Vice President.

l At the end of the meeting, PSC provided the NRC with a copy of the handout used during Commissioner briefings held on May 25-26, 1995.

The briefings i

were held to provide the NRC with an update of decommissioning activates at Fort St. Vrain.

Attachments:

1, Attendance List 2.

Meeting Handouts t

e l

I i

ATTACHMENT 1 j

ATTENDANCE LIST l

~

1

~ Attendance at the Public Service Company of Colorado - NRC meeting held on June 1, 1995, at the Region IV office-

~ '

\\

-Public Service Company of Colorado'(PSC)

A. Crawford, Vice President,. Electric Operations, PSC f

R. Edmister, Associate General Counsel, Morrison Knudsen i

M. Fisher, Decommissioning Program Director, PSC-M. Holmes, Project Assurance Manager, PSC T..Howard, Project Director,' Westinghouse j

W. Hug, Project Manager, MKF L. Parde, Executive Vice President, Power Division, Morrison Knudsen l

J. Scarboro, Attorney,'PSC D. Warembourg, Consultant, PSC NRC, Region IV t

W. Brown, Regional Counsel f

C. Cain, Chief, Fuel Cycle and Decommissioning Branch, Division of Radiation l-

~ Safety and Safeguards

[

L. Callan, Regional Administrator S. Collins, Director, Division of Radiation Safety and Safeguards R. Evans, Health Physicist, Fuel Cycle and Decommissioning Branch, Division of Radiation Safety and Safeguards l

W. Jones, Enforcement Specialist i

J.'Lieberman, Director, Office of Enforcement G. Sanborn, Enforcement Officer i

L 4

l t

f i

r

--n.r--

,e w-n,

1 I

ATTACHMENT 2 MEETING HANDOUT Attached are two handouts provided to the NRC during the June 1, 1995' meeting in the Region IV office.

l I

l i

I I

f i

i l

I t

l

4 hg.m-4

,aa, ma 4

.A d

ts A,g hai.

-..~..

O O

FORT ST. VRAIN m

nummmmmmmmmmmmmmmmmme mumummmmmmmmmmmmmmmmmmmmmmmmmmmme h

NUCLEAR REGULATORY COMMISSION ENFORCEMENT CONFERENCE JUNE 1,1995

- - - - ' ~ -

R w

442e 4

g

_a g

m b.h-E 4.-

5=-

344*

A

-h

• -2b.& Wa_au% A a---he-A e-W4-L-

L8L4-.---+-

%h---A6_-4.a

+4-4

%,.-s E4 A

s,.A,,

A-e%

e.4 s.-__.E_-

W

__..B-.

m.a&

L.

4 FORT ST. VRAIN r

NUCLEAR REGULATORY COMMISSION ENFORCEMENT CONFERENCE JUNE 1,1995 4

.r

-... m m

m

['

l

)

t AGENDA t

INTRODUCTION AND OPENING REMARKS A. C. CRAWFORD i

EVENTS AT FORT ST. VRAIN M. J. FISHER i

HISTOF.lCAL OVERVIEW a

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

MK ACTIONS L.E.PARDI L

l C O N SID E R ATI ON S /MITIG ATIO N/C LOSIN G A. C. CRAWFORD QUESTIONS / DISCUSSION s

f i

l Page 2

I INTRODUCTION AND OPENING REMARKS I

t i

~

PUBLIQ SERVICE COMPANY OF COL ORADO IS HERE TO ADDR VIOLA TION i

IN MA Y 19,1995, LETTER, NRC STA TED THA T THE OFFICE OFINVESTIGA TIO FOLLOWING CONCLUSION:

1 FOUR FORMER MK EMPLOYEES WERE HARASSED, INTIMIDATED AND ULT TERMINATED BY THEIR SUPERVISORS FOR RAISING SAFE SAME SUPERVISORS CREA TED A HOSTILE WORK ENVIRONMENT PSC/MK CONCLUSION:

t i

AN A TMOSPHEREEXISTED IN WHICH THEPERCEPTION OF f

1 PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCE RAISING SAFETY CONCERNS COULD RESUL TIN RETAllA TION i

AS WILL:BEEXPLAINED, THERE WAS ANINDEPENDENT BASIS FOR THE t

REPORT SUPPORTS THE PERCEPTION THA T T SOMEINFLUENCE ON LA YOFF DECISION i

t i

Page 3 I

f I

f i

1

k INTRODUCTION AND OPENING REMARKS (CONTINUED)

UPON LEARNING OF POTENTIAL HARASSMENT AND INTIMIDATION CONCERN IN JANUARY

1994, PSC/WT INITIATED AN EXTENSIVE INVESTIGATION AN'D CORRECTIVE ACTION PLAN IN THE FOLLOWING APPROPRIATE AND AGGRESSIVE MANNER:

RESPONDED TO QUESTIONS FROM OSHA, NRC, LABORER'S INTERNATIONAL UNION OF NORTH AMERICA, NLRB, IN TIMELY MANNER i

HAD DIRECT EXECUTIVE MANAGEMENT INVOLVEMENT 3

INITIATED INDEPENDENT INVESTIGATION BY LAW FIRM OF STIERyDERSON AND MALONE (SAM), 'AT A COST OF APPROXIMATEQ $1 MILLION,OVER 9 MONTHS, INTERVIEWING APPROXIMATELY 50% OF THE WORDORCE

[

TOOK APPROPRIATE PERSONNEL

ACTIONS, CONDUCTED EMPLOYEE TRAINING, TEAM BUILDING t

PROVIDED SUPPORT, OPEN COMMUNICATIONS AND FULL COOPERATION WITH NRC INVESTIGATION l

ENHANCED COMMUNICAT!ONS BETWEEN PROJECT TEAM MEMBERS REGARDING PERSONNEL ISSUES PRESENTED PRELIMINARY FINDINGS TO NRC ON AUGUST 4,1994

[

t Page 4 I

t

i INTRODUCTION AND OPENING REMARKS t

(CONTINUED) j

[

UPON LEARNING THAT PERCEPTION OF SOME EMPLOYEES WAS T

~

WAS EMPHASIZED OVER SAFETY AND PROCEDURAL COMPLIANCE, AND THAT RAISING SAFETY CONCERNS COULD RESULT IN RETAllATION, PSC/WT TOOK CORHECTIVE ACTIONS k

ENCOURAGED CONSTANT COMMUNICATIONS BETWEEN WORK F SAFETY REPRESENTATIVES OF PSC AND MK INCREASED PRESENCE OF PSC OVERSIGHT PERSONNEL I

i INITIATED MEETINGS BETWEEN PSC AND WT MANAGEMENT I

BASIS, AS A MINIMUM -- SPECIFICALLY CONCENTRATING ON PERSONNEL ISSUES CONTINUED WEEKLY TOOLBOX SAFETY MEETINGS FOR CRA MONTHLY SAFETY MEETINGS INCLUDE RADIATION PROTE (RPT) 1 INCLUDED SAFETY DISCUSSIONS DURING DAILY SITE-WIDE MEETINGS ENCOUR AGED OPEN DISCUSSIONS OF DlSAGREEMENTS I

TO ACHIEVE TIMELY RESOLUTION Page 5 s

i

t INTRODUCTION AND OPENING REMARKS (CONTINUED)

PSC/WT ACTIONS (CONTINUED)

I i

PROViDED CONSTANT REMINDERS. EMPHASIZING THE IMPORTANCE OF SAFETY OVER PRODUCTION l

CONDUCTED 10 CFR 50.7 TRAINING FOR ALL WT BADGED PERSONNEL HELD DETAILED MANAGEMENT ROUND TABLE DISCUSSIONS TO ENSURE CONSISTENT UNDERSTANDING OF 10 CFR 50.7 EMPHASIZED CORPORATE PHILOSOPHIES, IMPORTANCE OF SAFETY, AND ELEMENTS OF 10 CFR 50.7 DURING ALL-EMPLOYEE MEETIN'GS i

f a

I i

i i

Page 6 i

m_

L il i

INTRODUCTION AND OPENING REMARKS (CONTINUED)

WE HAVE IMPLEMENTED A PROGRAM THAT WORKS i

WORKERS FEEL _THAT FORT ST. VRAIN DECOMMISSIONING PROJECT IS SAFE, AND THEY ARE COMFORTABLE BRINGING UP SAFETY CONCERNS i

WORKER PERCEPTIONS ARE DETERMINED BY PERIODIC MONITORINGS, SURVEYS, QUESTIONNAIRES, AND INTERVIEWS WHEN CONFLICTS AND PROBLEMS ARISE, THEY ARE IDENTIFIED, BROUGHT I

TO MANAGEMENT'S ATTENTION, AND RESOLVED OMBUDSMAN (HOT LINE) ESTABLISHED IN MARCH 1994 TO ALLOW i

I CONFIDENTIAL IDENTIFICATION OF CONCERNS VARIOUS COMMUNICATION AVENUES ARE AVAILABLE TO i

ENSURE A COMFORTABLE ROUTE FOR ALL EMPLOYEES TO RAISE SAFETY CO SAM CONCLUSION: BY MARCH 1994 WORK STOPPAGE, MAJGR ELEMENTS OF ATMOSPHERE OF HARASSMENT AND INTIMIDATION WERE NO LO FACTORS I

Page 7 l

3 m.m..-

m m.m

T 4

4 HISTORICAL OVERVIEW OF EVENTS AND

SUMMARY

OF PARALLEL ACTIONS i

i I

f i

t l

Page 8

i HISTORICAL OVERVIEW FIRST QUARTER OF 1993, 4 MK WORKERS RAISED INDUSTRIAL SAFETY AND I

I RADIOLOGICAL CONCERNS REGARDING HIGH DENSITY BLOCK REMOVAL I

DRILLING OPERATIONS I

MARCH 9,1993,4 MK LASORERS LAID OFF t

i MAP.CH 1993, UNION REPRESENTATIVE INFORMED MK THAT LABORERS RAIS COMPLIANT DUE TO THE LAYOFF - UNION CONCLUDED THAT THE CO 1

MERIT i

MARCH 16,1993, OSHA NOTIFIED MK OF A COMPLAINT REGARDING ASB REMOVAL AND HIGH DUST LEVELS AT FORT ST. VRAIN -- MK RESPONDED APRIL 6,19 JULY 1993, NRC INSPECTED SPECIFIC RADIOLOGICAL CONCERNS RAISED BY 4 FORM MK LABORERS AND CONCLUDED THAT APPROPRIATE RADIOLOGICAL PRACTICES WERE IN PLACE t

t

+

Page 9

{

I

h HISTORICAL OVERVIEW (Continued)

DECEMBER 14,1993, NRC LETTER QUESTIONED WHETHER SAFETY CONCERNS RAISED DURING MARCH 1993 HIGH DENSITY BLOCK REMOVAL ACTIVITIES HAD BEEN ADEQUATELY ADDRESSED

~

i JANUARY 17,1994, PSC RESPONDED TO NRC LETTER - RESPONSE BASED ON A MARCH 1993 PSC PROBLEM REPORT AND APRll 1993 OSHA RESPONSE WHICH CONCLUDED THAT THE SAFETY CONCERNS RAISED WERE WITHOUT FOUNDATION JANUARY 19, 1994, NRC OFFICE OF INVESTIGATION NOTIFIED PSC OF POTENTIAL HARASSMENT AND INTIMIDATION ALLEGATIONS INVOLVING 4 FORMER MK LABORER FEBRUARY 3,1994, CONFRONTATION OCCURRED BETWEEN AN MK SUPERINTENDENT AND A RADIATION PROTECTION TECHNICIAN (RPT) i FEBRUARY 8,1994. UFON LEARNING OF THE FEBRUARY 3 INCIDENT, PSC REQUESTED THAT WT CONDUCT AN INVESTIGATION OF ISSUES SURROUNDING THE

{

CONFRONTATION AND DEVELOP AN ACTION PLAN TO ADDRESS POSSIBLE CHILL i

EFFECTS i

Page 10 I

i

[

l i

i HISTORICAL OVERVIEW (Continued) i l

WEEK OF FEBRUARY 14,1994, WT IMPLEMENTED ACTION PLAN TO MEET WITH ALL WT ON-SITE PERSONNEL, AND HELD ROUND TABLE DISCUSSIONS WITH WT MANAGEMENT PERSONNEL 'TO DISCUSS H & I AND CHILLING EFFECTS -- INCLUDED 10 CFR SENSITIVITY DISCUSSION FEEDBACK FROM MEETINGS REVEALED A LOT OF MISCONCEPTIONS ABOUT RADIOLOGICAL OCCURRENCE REPORT (ROR)

PROGRAM AND MANAGEMENT'S l

PHILOSOPHY

~

?

PSC MET WITH WT UPPER MANAGEMENT TO DISCUSS THIRD PARTY INVE AND WT AGREED TO BE INVOLVED t

PSC CONTRACTED WITH SAM TO CONDUCT A THIRD Pf FEBRUARY 22,1994, INVESTIGATION OF POTENTIAL H & IISSUES AND OVERALL SITE RELATION l

i FEBRUARY 24,

1994, POTENTIAL H&l CONCERNS WERE DISCUSSED DURING SEMIANNUAL EXECUTIVE MEETING -- MK SUPERINTENDENT REMOVED i

i Page 11 i

i.

HISTORICAL OVERVIEW (Continued)

ON MARCH 10,1994, PSC/WT SITE MANAGEMENT CONDUCTED MEETINGS WITH ALL I

SITE EMPLOYEES TO EMPHASIZE MANAGEMENT VALUES, PHILOSOPHY, PROJECT EXPECTATIONS, AND TO INTRODUCE THE THIRD PARTY INVESTIGATION i

i MARCH 31,1994, PSC, WESTINGHOUSE, MK, AND SEG SENIOR EXECUTIVES MET WITH e

ALL SITE MANAGEMENT TO DISCUSS CORPORATE CORE VALUES AND EXPECTATIONS, NRC REGULATIONS INCLUDING 10 CFR 50.7, AND RE-EMPHASIZE ON-SITE MANAGEMENT l

RESPONSIBILITIES I

JUNE 30,1994, PSC/WT MET WITH REGION IV ANDIPRESENTED INITIAL OVERVIEW OF H & IISSUES l

r I

AUGUST 4.1994, MEETING HELD WITH NRC REGION IV TO PRESENT INITIAL FINDINGS

[

AND CORii:CTIVE ACTIONS

?

AUGUST 10,1994, ALL SITE EMPLOYEE MEETING REINFORCED CORE VALUES, PROVIDED STATUS OF INVESTIGATION, AND PRESENTED ELEMENTS OF 10 CFR 50.7 Page 12

^

l J

HISTORICAL OVERVIEW (Continued)

. MARCH 27,1995, INDEPENDENT ASSESSMENT lBY STIER, ANDERSON, AND MALONE COMPLETE, REPORT PROVIDED TO NRC IN DEPTH ASSESSMENT INVOLVED 9 MONTHS, APPROXIMATELY $1 MILLION INTERVIEWED OVER 100 PEOPLE -- APPROXIMATELY 50% OF WORKFOR TIME REVIEWED 15,000 PAGES OF DOCUMENTATION INVESTIGATORS HAD FREE REIN AND WERE NOT RESTRICTED IN ANY WAY PSC COMMITTED 1 FULL TIME RADIATION PROTECTION PROFESSIONAL INVESTIGATION TEAM PSC AND WT DEVELOPED AND IMPLEMENTED CORRECTIVE ACTIONS TO

=

I ISSUES AT FORT ST. VRAIN IN PARALLEL WITH THE SAM INVESTIGATION Page 13

~

. -~

.. _.. _ ~. _._._._ _._. _. _ __._.....__ _._.. _ _ _...__ _. -._ _ _.- _. _._..-__ _. _ _._.. _... - _,

j i.

i HISTORICAL OVERVIEW (Continued)

ORIGIN AND SCOPE OF SAM INVESTIGATION I

REQUESTED BY PUBLIC SERVICE COMPANY OF COLORADO AND WESTINGHOUSEl TEAM i

POTENTIAL ATMOSPHERE OFINTIMIDATION AND HARASSMENT; INITIAL SCOPE:

EFFECTIVENESS OF RADIOLOGICAL OCCURRENCE REPORT ("ROR") PROGRAM ADDITIONAL SCOPE: POSSIBLE FALSIFICA TION OF RADIA TION SURVEY RECOR:

ISSUES INVESTIGATED 1

WHETHER AN ATMOSPHERE EXISTED WHERE WORKERS WERE RELUCTANT TO

\\

RAISE SAFETY CONCERNS d

WHETHER MK PERSONNEL INTIMIDATED AND HARASSED SEG RPTS i

t WHETHER SEG EMPLO YEES USED THEROR PROCESS TO INTIMIDA TE AN MORRISON KNUDSEN ("MK")

WORKERS - SAM CONCLUDED THA T THIS l

ALLEGATION WAS UNFOUNDED i

t i

Page 14 t

i h

i

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

CONCERN NO.1:

i A PERCEPTION EXISTED IN A CROSS SECTION OF THE WORK FORCE THAT PRODUCTION WAS EMPHASIZED OVER SAFETY COWORKERS FELT THAT THE LAYOFF DECISION WAS NOT BASED ON WOR EXPRESSION OF CONCERNS WOULD RESULT IN RETAllATiON i

Page 15

i CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIONS:

I MK AND SEG RE-EMPHASIZED POLICIES OF SAFETY OVER PRODUCTION DECOMMISSION!NG ACTIVITIES WERE SHUT DOWN FOR 16 CALENDAR DAYS -

- PRIMARILY DUE TO RP RECORDS ISSUES ALL EMPLOYEES WERE TRAINED IN THE IMPORTANCE OF SAFETY, STOP WORK AUTHORITY, PROCEDURE COMPLIANCE CONDUCTED ADDITIONAL 10 CFR 50.7 TRAINING FOR ALL WT BADGED i

PERSONNEL L

TEAM BUILDING SESSIONS CONDUCTED BY THE WT TO CREATE ATMOSPHERE 4

WHERE EMPLOYEES FEEL SAFE RAISlNG SAFETY CONCERNS

/>

MANAGEMENT ENCOURAGED WORKERS TO BRING UP SAFETY CONCERNS t

WITHOUT FEAR OF RETAllATION, IN EFFORT TO DEVELOP TRUST WITH THE wORKFORCE PSC AND WT MANAGEMENT MEET WEEKLY TO DISCUSS ISSUES AND POTENTIAL CONCERNS, ESPECIALLY REGARDING PERSONNEL ISSUES Page 16

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIO'NS (Continued):

(

JOINT WT SAFETY WALKDOWNS INCLUDING MANAGEMENT, RADIATION PROTECTION, MK SAFETY REPRESENTATIVE, AND CRAFT LABOR TO P TEAM CONCEPT AND PROVIDE OPPORTUNITY TO RAISE WEEKLY WT MANAGEMENT MEETINGS WITH RPT AND CRA TO DISCUSS OPERATIONAL ISSUES AND POTENTIAL CONCERNS i

MK ESTABLISHED ENHANCED / WRITTEN LAYOFF POLICIES MK ROUND TABLE DISCUSSIONS ON MANAGEMENT EXPECTATIONS i

i REGARDING LAYOFFS i

{

l

^

Page 17 l

m

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued) i CONCERN NO. 2:

THE FEBRUARY 3,1994, INCIDENT BETWEEN THE MK SUPERINTENDENT AND AN RPT FOUR VIOLATIONS OF RADIATION PROTECTION PRACTICES BY MK SUPERINTENDENT SEG RPTS COMPLAINED OF INTIMIDATING CONDUCT OF MK SUPERINTENDENTS / SUPERVISORS 1

SEG MANAGEMENT FAILED TO FORCEFULLY ADDRESS INTIMIDATING BEHAVIOR i

AND THE RPTS LOST CONFIDENCE IN BOTH THE ROR PROGRAM AND IN THEIR MANAGEMENT THE ROR PROGRAM WAS PERCEIVED TO BE A DISCIPLINARY TOOL i

i I

l l

Page 18 j

~

i I

P CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIONS:

i PROGRESSIVE DISCIPLINARY ACTIONS TAKEN AGAINST MK SUPERINTE LEADING TO THE FINAL REMOVAL FROM THE SITE MANAGEMENT TEAM BUILDING SESSIONS HELD BETWEEN WT ORGANIZATIONS TO ADD 3ESS PROBLEM RESOLUTION WITHOUT INTIMIDATION i

POSITIVE CHANGE IN BEHAVIOR OF OTHER MK SUPERVISORS SEG INCREASED PERSONNEL TO PROVIDE ADEQUATE SovPORT TO AV UNNECESSARY PRODUCTION DELAYS AND CONFRONTATIONS l

REGARDING ROR PROCESS:

L SEG REORGANIZED TO PROVIDE SUPPLEMENTAL STAFF AND BETT[

MANAGEMENT INVOLVEMENT - PRIMARILY RELATED TO RP RECO REMOVAL FROM SITE OF SPECIFIC SEG SUPERVISORS -- PRIMA TO RP RECORDS ISSUE Page 19

..m.

m

l CONCERNS Arid CORRECTIVE ACTIONS

SUMMARY

(Continued) t CORRECTIVE ACT!ONS (Continued):

COMMUNICATED MANAGEMENT'S INTENT ON THE ROR PROCESS -- TO CORRECT RADIOLOGICAL OCCURRENCES AND BEHAVIOR, NOT. AS A DISCIPLINARY TOOL IMPROVED THE RJR PROCEDURE AND PROCESS NEW SEG SUPERVISORS WERE SENSITIZED TO DETECT POTENTIAL INTIMIDATION ATMOSPHERE INCREASED PSC AND SEG MANAGEMENT INVOLVEMENT IN THE ROR PRO WITH REORGANIZATION OF SEG IMPROVED VISIBILITY OF THE ROR PROCESS IN QA SURVEILLANCE AND OVERSIGHT ACTIVITIES PSC PERIODICALLY INVOLVED IN INVESTIGATION OF RORs Page 20

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

IN CONCLUSION, SAM REPORT DETERMINED THAT THE MAJOR ELEMENTS CONTRIBUTING TO AN ATMOSPHERE OF H & I WEP" "O LONGER F FEW WEEKS OF DISCOVERY

ALSO, SAM REPORT CONCLUDED WORKERS FOUND EFFECTIVE MEANS OF SAFETY CONCERNS SUCH THAT THE IDENTIFICATION AND RESOL CONCERNS WERE NOT COMFROMISED Page 21 h

a

,s.

m -

m-

~ -

S O

NN e

C) 80 Q.

1 e

Z O

O<

w E

J 4

MK BACKGROUND MK HAS LONG HISTORY OF EXCELLENCE IN NUCLEAR POWER INDUSTRY, AND MK'S GOVERNMENT AND ENVIRONMENTAL GROUP HAS SIMILAR HISTORY IN DECOMMISSIONING AND CLEANUP OF DOE AND DOD FACILITIES CURRENT OTHER NUCLEAR PROJECTS INCLUDE TWO STEAM GENERATOR REPLACEMENTS AND WORK WITH WESTINGHOUSE ON AP600 MK HAS 80 YEAR HISTORY OF SUCCESSFUL PROJECTS EMPLOYING CR t

PROFESSIONAL PEOPLE -- TAKE PRIDE IN BEING FAIR AND EQUITABLE EM MK HAS NOT AND WILL NOT CONDONE HARASSMENT AND/OR INTIMID

=

EMPLOYEES OR THE EMPLOYEES OF OTHERS INVOLVED IN ANY PROJECT l

i t

i

?

?

Page 23

t MK POSITION MK HAS REVIEWED THE SAM INVESTIGATION REPORT AND THE SYNOPSIS OF T OFFICE OF INVESTIGATION'S REPORT THERE WAS AN INDEPENDENT BASIS FOR LAYING OFF THE 4 LABORERS -- THA WAS THE FACT THAT THEIR WORK TASKS WERE COMPLETE WE AGREE THAT A PERCEPTIO'!J WAS INADVERTENTLY CREATED THAT RAIS CONCERNS COULD RESULT IN RETALIATION WE ALSO AGREE THAT WE HAD AN MK SUPER'.4TENDENT THAT DID NOT INT APPROPRIATELY WITH SEG RPTs UPON DISCOVERY, MK PROJECT AND EXECUTIVE MANAGEMENT ALONG WITH PSC AND WT INVESTIGATED AND INITIATED IMMEDIATE CORRECTIVE ACTIONS: AN i WAS THE PROMPT REMOVAL OF THE SUPERINTENDENT FROM THE PROJECT t

r 1

b Page 24

LAYOFF OF 4 LABORERS 4 LABORERS WERE ASSIGNED TO CONCRETE CORE DRILLING TASK I 1992, WHICH WAS COMPLETED IN EARLY MARCH 1993 RE-ASSIGNED TO HIGH DENSITY BLOCK REMOVAL TASK, WHICH LASTED APPROXIMATELY ONE WEEK NO ADDITIONAL ASSIGNMENTS WERE IDENTIFIED 4 LABORERS WERE OBVIOUS CANDIDATES FOR LAYOFF WITHOUT D EXISTING WORK CREWS LAYOFF OF 4 LABORERS WAS ONE OF SEVERAL LAYOFFS IN 1993:

JANUARY 7 7 LABORERS MARCH 9 4 LABORERS MARCH 25 2 LABORERS LABORERS' UNION DETERMINED THEIR CLAIMS HAD NO MERIT Page 25 I

i i

LAYOFF OF 4 LABORERS (Continued)

"OPEN DOOR POLICY" INCIDENT INVOLVED UNION GENERAL FOREMAN WHO DID NOT UNDERSTAND POLICY -- UNION GENERAL FOREMAN WAS COUNSELED AND RETRAINED TO AVOID FUTURE PROBLEMS

)

Page 26 t

I RESPONSE ~TO WORKERS CONCERNS IDENTIFIED TO NRC i

NRC INDICATED 4 MK LABORERS WERE LAID OFF FOR RAISING RADIOL INDUSTRIAL SAFETY CONCERNS, INCLUDING:

1)

AIR QUAllTY

\\

WORKERS WERE PROVIDED RESPIRATORS APPROPRIATE FOR TH DURING HIGH DENSITY BLOCK REMOVAL, LABORERS IN HALF-FACE RESPIRATO WERE WORKING IN THE SAME AREA AS WORKERS IN FULL-FAC QUESTIONED THE DISPARITY REASON FOR DISPARITY WAS THAT FULL-FACE RESPIRATORS OPERATORS OF JACKHAMMERS FOR PROTECTION AGAINST FLYlN CHIPS AIR MONITORING INDICATED AREA WAS NOT RADIOLOGICAL HAZARD, ONLY D NRC INSPECTION IN JULY 1993 CONCLUDED NO RADIOLOGICAL C t

i Page 27

t RESPONSE TO WORKERS CONCERNS IDENTIFIED TO NRC (Continued) 2)

WORK IN A RADIOLOGICALLY CONTROLLED AREA WITHOUT AN APPROPRIATE i

RADIA TION WORK PERMIT PSC AND THE WT ARE NOT AWARE OF THIS CONCERN; DURING OUR INVESTIGATIONS, THIS ISSUE DID NOT ARISE -- PROPER RWP COVERAGE HAS ALWAYS BEEN EMPHASlZED DURING THE FSV DECOMMISSIONING PROJECT DURING THE NRC'S JULY 19931NSPECTION, RWP PRACTICES WERE REVIEWED AND FOUND ACCEPTABLE i,

3)

PERSONNEL CONTAMINA TION WHILE CORE DRILLING i

L SOME PERSONNEL WERE WETTED WITH CONCRETE SLURRY WHICH CONTAINED LOW LEVELS OF TRITIUM - NO PERSONNEL CONTAMINATIONS RESULTED 1

NRC'S JULY 1993 INSPECTION CONCLUDED APPROPRIATE CORRECTIVE ACT WERE TAKEN t

Page 28

[

FORT ST. VRAIN PROJECT SAFETY

~ MK HAS MADE SUBSTANTIAL COMMITMENT TO SAFETY:

INDUSTRIAL SAFETY i

1 MK PROVIDED 3 FULL TIME SAFETY PROFESSIONALS AND 1 FULL i

i ADDRESS SAFETY ISSUES -- SPEND MOST OF THEIR TIME WITH WORKERS, ADDRESS SAFETY CONCERNS'AS THEY ARISE SAFETY INCENTIVE PROGRAM i

RADIOLOGICAL SAFETY ALARA SUGGESTION PROGRAM INCREASED COMMUNICATION WITH RPTS WORK PLANNING AND ALARA ENGINEERING MK MEMBERS ON ALARA COMMITTEE l

I I

l Page 29

~.

1 l

FSV SAFETY STATISTICS LOST DAY INCIDENCE RATE I

6.9 t

INDUSTRY AVERAGE t

L F

i t

0.58 FSV LOST TIME ACCIDENTS PER l

200,000 PERSON HOURS WORKED I

i Page 30 l

l l

FSV ALARA STATISTICS 315.7 14 BWR 251 ESTIMATE FOR WORK PERFORMED TO DATE ACTUAL TO DATE PWR i,

6.5 4.4 L

4 v

FSV

-;^

PERSONNEL CONTAMINATIONS TOTAL DOSAGE PER 10,000 RCA PERSON HOURS (PERSON REM)

Page 31 e

MK ACTIONS MK OPEN DOOR POLICY MK MAINTAINS AN OPEN DOOR POLICY WHEREIN PERSONNEL ARE ENCOURAGED TO BRlNG FORTH ISSUES TO MANAGEMENT AND/OR THEIR RESPECTIVE UNION l

REPRESENTA TIVES

\\

THIS OPEN DOOR POLICY WAS DISCUSSED WITH ALL LEVELS OFMKMANAGEMENT l

ON MARCH 14, 1994 TO ENSURE A COMPLETE UNDERSTANDING OF THE POLICY AMONG ALL MANAGEMENT PERSONNEL y

OPEN DOOR POLICY WAS DISCUSSED WITH ALL EMPLO YEES ON MARCH 10,1994, AUGUST 10, 1994, AND PERIODICALLY DURING WEEKLY TOOLBOX SAFETY MEETINGS l

SPECIFICALL Y, THE UNION GENERAL FOREMAN DID NO T UNDERSTAND OPEN DOOR POLICY -- WAS COUNSELED AND RETRAINED TO A VOID FUTURE PROBLEMS t

I Page 32 r

f

i MK ACTIONS (Continued) t MK LAYOFF PROCEDURES SENSITIVITY TRAINING WAS CONDUCTED WITHALL MKAND UNIONMANAGEMEN ON HARASSMENT AND INTIMIDA TION ISSUES AND THE ASSOCIA TED ELEM

\\

OF 10 CFR 50.7 AS RELATED TO LAYOFFIMPACTS

)

MANAGEMENT MEETINGS WERE HELD TO ENSURE UNIFIED EXPECTA TION INVOLVEMENT OF ALL MANAGEMENT LEVELS REGARDING FUTURE LA YOFF DECISIONS EMPHASIS PLACED ON WORK PLANNING TO MINIMlZE LA Y-OFF AND REH CYCLES i

PUBLISHED ENHANCED GUIDELINES ON MAKING LA YOFF CECISIONS TO 1

MANAGEMENT PERSONNEL ON AUGUST 15,1994 f

i P

i Page 33

[

t i

I

t i

MK ACTIONS (Continued)

~

MK FEEDBACK MECHANISMS:

i TOOL BOX SESSIONS WITH CRAFT AND RPT PERSONNEL e

JOB BRIEFINGS t

MEETINGS WITH THE UNION REPRESENTATIVES i

l MANAGEMENT FEEDBACK FROM SUPERVISORY AND FOREMAN LEVELS t

STOP WORK AUTHORITY MANAGEMENT MEETINGS WITH PSC AND WT PSC/WT QA MONITORINGS AND AUDITS t

i RORs e

EMPLOYEE MEETINGS TO ADDRESS INAPPROPRIATE PERCEPTIONS AND THE POTENTIAL CHILLING EFFECTS i

PSC ENHANCED OVERSIGHT AND PSC HOTLINE TO IDENTIFY POTENTIAL i AREAS Page 34

l MK PERFORMANCE CONSIDERATIONS I

PERFORMANCE SHOULD BE CONSIDERED IN EVALUATING THIS APPARENT VIOLA PROJECT SAFETY RECORD i

PROJECT ALARA RECORD i

PROMPT, DECISIVE ACTIONS TAKEN BY PSC AND THE WT, INCLUDING REMOVAL i

OF A SUPERINTENDENT i

I OSHA, DEPARTMENT OF LABOR, AND THE UNION TOOK NO ACTION RELATIVE TO THE 4 LABORERS' CLAIMS 4 LABORERS' GRIEVANCE WAS ONLY GRIEVANCE FILED, WAS RESOLVED AT FIRST STEP, IN FAVOR OF MK i

MK'S LONG HISTORY OF EXCELLENCE IN NUCLEAR ACTIVITIES l

[

i i

f f

I i

i Page 35 f

s k

l 4

tI

. D

DISCRETIONARY CONSIDERATIONS Page 36

i DISCRETIONARY CONSIDERATIONS AS STATED PREVIOUSLY, THERE WAS AN INDEPENDENT BASIS FOR CRAFT LAYOFF, i

.HOWEVER, THE WEIGHT OF EVIDENCE FROM THE SAM REPORT SUPPORTS THE PERCEPTION THAT THE EXPRESSION OF SAFETY CONCERNS HAD SOME INFLUEN[

LAYOFF DECISION I

t AN ATMOSPHERE EXISTED IN WH!CH THE PERCEPTION OF SOME EMPLOYEES WAl PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCEDURE COMPLIANCE, AND RAISING SAFETY CONCERNS COULD RESULT IN RETAllATION ii YOUR MAY 19,1995, LETTER ASKED PSC TO ADDRESS THE ISSUES OF SEVERITY AND F

i civil PENALTY PSC BELIEVES THIS APPARENT VIOLATION SHOULD BE NO MORE THAN SE LEVEL IV, BECAUSE:

t PROMPT MANAGEMENT INVOLVEMENT AND CORRECTIVE ACTION MAJOR H & I ISSUES WERE SELF-IDENTIFIED H&l ACTS INVOLVED ONLY FIRST LINE SUPERVISION NO SIGNIFICANT IMPACT ON ENVIRONMENT OR PUBLIC HEALTH A f

i Page 37

DISCRETIONARY CONSIDERATIONS (Continued)

REASONS WHY APPARENT VIOLATION SHOULD BE NO MORE THAN SEVERITY LEVEL IV (Continued):

NO SAFETY SIGNIFICANCE SAM REPORT CONCLUDED WORKERS. FOUND EFFECTIVE MEANS OF o

ADDRESSING SAFETY CONCERNS SUCH THAT THE IDENTIFICATION AND RESOLUTION OF SAFETY CONCERNS WERE NOT COMPROMISED SAFETY SIGNIFICANCE OF FORT ST. VRAIN DECOMMISSIONING IS NOT o

COMPARABLE TO POWER REACTOR t

o NO WORKER WAS OVEREXPOSED NO CIVIL PENALTY SHOULD BE ASSESSED I

Page 38 r

i I

DISCRETIONARY CONSIDERATIONS i

i (Continued)

ENFORCEMENT DISCRETION IS APPROPRIATE, PER NRC ENFORCEMENT POLICY SECTION Vll.B.7:

PSC/WT SELF-IDENTIFIED WORV.ER PERCEPTIONS AND RELUCTANC 1.

SAFETY CONCERNS PSC/WT TOOK PROMPT, COMPREHENSIVE, AND EFFECTIVE CORRECTIVE 2.

ACTIONS TO ADDRESS BOTH PARTICULAR SITUATION AND OVERAL ENVIRONMENT 3.

ADDITIONAL MITIGATING CONSIDERATIONS i

L 1

b Page 39 l

t DISCRETIONARY CONSIDERATIONS t

(Continued) l

~1.

IDENTIFICA TION I

l THE 4 LABORERS CONTACTED NRC DIRECTLY AS OPPOSED TO CONTACTING PSC/WT MAN AGEMENT --THIS CIRCUMVENTED THE SELF-IDENTIFICATION PROCESS IDENTIFICATION WAS MORE COMPLEX BECAUSE WORKERS DID NOT REPORT DIRECTLY TO PSC WE DID SELF-IDENTIFY:

THE FEBRUARY 3,1994, INCIDENT BETWEEN THE MK SUPERINTENDENT AND AN RPT A PERCEPTION IN A CROSS SECTION OF THE WORK FORCE THAT PRODUCTION WAS EMPHASIZED OVER SAFETY THREATS BY MK SUPERINTENDENTS / SUPERVISORS AGAINST RPTS VIOLATIONS OF RADIATION PROTECTION PRACTICES BY MK

't SUPERINTENDENTS / SUPERVISORS i

Page 40 l

I i

4 DISCRETIONARY CONSIDERATIONS (Continued) i WE DID SELF-IDENTIFY:

COWORKERS' PERCEPTION THAT THE LAYOFF DECISION WA

\\

WORKERS SKILLS PERCEPTION OF SOME EMPLOYEES THAT EXPRESSION OF i

RESULT IN RETAllATION FAILURE OF SEG MANAGEMENT TO FORCEFULLY ADDRE BEHAVIOR MISPERCEPTION THAT THE ROR PROGRAM WAS A DISCIPL LOSS OF CONFIDENCE ON PART OF RPTS IN BOTH THE R IN THElR MANAGEMENT I

i L

Page 41 i

i i

DISCRETIONARY CONSIDERATIONS (Continued) 2.

CORRECTIVE ACTIONS PSC AND THE WT TOOK PROMPT AND AGGRESSIVE ACTION AS SOON AS WE WERE AWARE OF THE POTENTIAL HARASSMENT AND INTIMIDATION CONCERNS WE WERE INFORMED OF THE POTENTIAL H & l CONCERN ON JANUARY 19, 1994 l

AFTER FEE.JARY 3,1994, INCIDENT WITH MK SUPERINTENDENT, PSC l

REQUESTED WT TO DEVELOP A CORRECTIVE ACTION PLAN TO PREVENT RECURRENCE r

WE RETAINED SERVICES OF STIER, ANDERSON, AND MALONE ON FEBRUARY 22,1994 i

SAM CONCLUDED MAJOR ELEVENTS OF H & I ATMOSPHERE WERE NO i

LONGER FACTORS AT THE TIME OF THE WORK STOPPAGE -- WITHIN A FEW i

WEEKS OF IDENTIFICATION t

ADEQUACY OF CORRECTIVE ACTIONS CONTINUES TO BE PERIODICALLY MONITORED TO ENSURE EFFECTIVENESS EFFECTIVE CORRECTIVE ACTIONS FULLY IMPLEMENTED BY AUGUST 1994, WELL BEFORE SAM REPORT WAS COMPLETED IN MARCH 1995 Page 42 i

i I

DISCRETIONARY CONSIDERATIONS i

(Continued) 3.

ADDITIONAL MITIGATING CONSIDERATIONS PSC/WTBELIEVE THEREAREADDITIONAL MITIGA TING CONSIDERA TIONS THA T THEN SHOULD CONSIDER IN ASSESSING THIS APPARENT VIOLA TION:

LICENSEE PERFORMANCE JULY 1993 NRC SPECIAL INSPECTION TEAM CONCLUDED RADIOLOGICAL CONTROLS WERE ACCEPTABLE OSHA FOUND NO MERIT IN MARCH 1993 COMPLAINTS PSC HAS HAD A GOOD PRIOR PERFORMANCE IN THIS AREA - WE HAVE LAID APPROXIMATELY 750 EMPLOYEES WITH ONLY ONE PRIOR INCIDENT IN 199 PSC DENIED WAS VALID.

[

t i-Page 43 s

- --a

DISCRETIONARY CONSIDERATIONS (Continued)

' MITIGATING FACTORS (Continued) i PRIOR OPPORTUNITY TO IDENTIFY PREVIOUS INSPECTIONS DID NOT REVEAL ANY CONCERNS -- BY PSC QA, NRC, OUTSIDE RP INSPECTION INDIVIDUAL RORs AND PROBLEM REPORTS WERE GENERATED, INVESTIGATED AND CORRECTIVE ACTIONS TAKEN WITHOUT IDENTIFYING WORKER PERCEPTION ABOUT RAISING SAFETY CONCERNS MULTIPLE OCCURREllCES AND DURATION PREVIOUSLY DE(SED DISCRIMINATION CASE WAS UNRELATED AND OCCUR MORE THAN 4 YEARS AGO THE SAM REPORT CONCLUDED THAT THE MAJOR ELEMENTS CONTRIBUT AN ATMOSPHERE OF H & I WERE NO LONGER FACTORS WITHIN A FEW DISCOVERY 4

Page 44 l

i J

- - - ". - ^ ^ ' ~

CLOSING 1.

AN ATMOSPHERE EXISTED IN WHICH THE PERCEPTION OF SOME EMPLOYEES-WAS THAT PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCEDURAL COMPLIANCE, AND RAISING SAFETY CONCERNS COULD RESULT IN RETAllATION i

2.

THERE WAS AN INDEPENDENT BASIS FOR CRAFT LAYOFFS; HOWEVER, THE WEIGHT OF EVIDENCE FROM SAM REPORT SUPPORTS PERCEPTION THAT THE EXPRESSION OF SAFETY CONCERNS HAD SOME INFLUENCE ON LAYOFF DECISIO OUR CORRECTIVE ACTIONS HAVE BEEN EXTENSIVE AND ONGOING, ENCOURAGING 3.

WORKERS TO IDENTIFY SAFETY CONCERNS WITHOUT FEAR OF REPRISAL OUR SYSTEM HAS BEEN SHOWN TO WORK -- WE HAVE THE ABILITY TO DEAL 4.

OPENLY AND FAIRLY WITH WORKFORCE PROBLEMS AND REACH EFFECTIVE SOLUTIONS l

t

?

b Page 45 f

i

l

)

4 FORT ST. VRAIN 1

l DECOMMISSIONING UPDATE l

1 i

l

\\

Presentation to tize i

i N ??C!aG7 l

-. o. g

,,mw-,k b R

a,r :

mr I

h[N?N $ $ 0$

t, ii 1

MAY 25 & 26, 1995 (WASHINGTON, D.C.)

JUNE 1, 1995 (REGION IV)

O _eubiic service-k

)

i-4 FORT ST. VRAIN i

DECOMMISSIONir' UPDATE PUBLIC SERVICE COMPANY OF COLORADO PRESENTATION TO THE NUCLEAR REGULATORY COMMISSION May 25 and 26,1995 (Washington, D.C.)

June 1,1995 (Region IV)

AGENDA Decommissioning Status Low Level Waste Shipping Safety and Radiological Performance Recent investigations Final Release Survey Spent Fuel Status Present Decommissioning Concerns Conclusions Supplemental Information Page 1 I

~-..

{

6 I

DECOMMISSIONING STATUS Page 2

- -. _ _.. _. ~ _. -. - - - - - -

4 FORT 51 vghlN HTGR l

CONTROL ROD

%E HitIUM PURif f(Aggay TOP HEAD SYSTIM wggg PENE TR ATIONS l

." PCRV j

10P etIgg c goy ORIFlcg yALVE5

~'

,',," ?

{-

I m.

THERMAt BApyggy WGOR CORE CONypogpo9

=

I

.,. 801 TOM CORE Suppopy l

REFLECTOR Post $

i l

j CORE BARREt COR( $UPPOpr l

OCj f' b AFTER FINAL CLEAN-UP THE

},

Q.

l PCRV WILL BE ll l

, t: (

LEFTAS SHOWN OY

)&

4 STEEL PLA TE CLOSURES WILL BE MADE FOR THE TOP HEAD AND THEPCRV WILL BELEFT FOR LONG TERM STORAGE FOR DISMANTLEMENT IN THE FUTURE.

l lh g

sh t

PCRV FINAL DISPOSITION Page 5

DECOMMISSIONING STATUS PROGRESS SINCE MAY 1994:

Removal of Core Barrel Complete 29-foot high,30-foot diameter, 2-1/2 inches thick steel cylinder Cut into 115 pieces Lower barrel contact dose rates up to 120 R/hr Removal of Core Support Floor (CSF) Complete 30-foot diameter, 5-foot thick, 340 ton reinforced concrete Raised CSF out of PCRV cavity with 4-point litt, using 12 hydraulic Jacks Cut into 10 sections with diamond wire saw, shipped to Richland, WA for burial l

Removal of Steam Generator Ducts Complete i

l l

Removal of Helium Circulators Complete l

PCRV and BOP Dismantlement, Decontamination Activities Are Approximately 75% Complete l

l Page 6

. ~.

i e

DECOMMISSIONING STATUS 1

CURRENT ACTIVITIES:

Removal of Steam Generators i

Removal of Beltline Concrete from PCRV l

i Fuel Storage Well Removal e

l Decontamination of Embedded Piping, Hot Service l

Facility i

Final Radiological Survey J

i l

l Page 7

iqqp I993 1994 J ln IS 0 [N l0 J If lH AIM lJ J I A 15 0lNlD J If lM AlMlJ J l A 15 0INlD J [f lM AIMiJ J l A_J S 0 IN lD J lF lM AlMl J J

1995 tqw.

2 LECilR5 W/fH 1 r

EAM GENE 1ATOR SECONDARIE5 MaWv' ret 0VE TOP HERD CONCRFTE S r. DUTER KEYS CORE SUPPORI Fl00R C

He CIRC'S t 53EAN GENERATOR PRin.wlts PCRV ACilVATED CONCRETE I

LENUM

= = - = = =. - -

_1 FINAL SURVEY & REP 0iiT

6 00ed a

5 8

8 8

8 8

8 8

8 5

e 8

e 8

e s

s 8

8 e

e

\\

\\\\k

@ M M M M % \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\x !

a SMMM%%

x S

8 BWMMMMM'M 3

a l

G u a n u n u m m \\ \\ \\ \\ \\ \\ \\ xx E u

RMM'6MENN\\\\\\\\\\\\\\\\\\\\\\\\\\\\1 e

m l

a dBM&%M 2* MM@MMENN\\\\\\M\\\\\\\\\\'

m 3e MM&M'd's\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\N H*

MMMMENNNNNNNNNNNWM e

E O

LIQUID WASTE M M R \\\\\\\\\\\\\\\\ M NN M M e

d hhhh DRAINS d

HVAC SYSTEMS bhhhbk\\\\\\Mhb 8

l

I l,

LOW LEVEL WASTE SHIPPING 4

i LLRW Shipments for disposal and volume reduction, to May 1,1995, including shipments to processors:

Disposal facilities at Beatty, Nevada and Richland, l

Washington l

Volume Activity Shipments (cu.ft.)

(Cl) t Direct 70,870 71,030 260 Disposal 4

Sent to 71,530 170 73 Processors TOTAL 142,400 71,200 333 Total Project Estimate:

193,000 cu. ft.

l Page 10

I I

SAFETY AND RADIOLOGICAL PERFORMANCE RADIOLOGICAL PERFORMANCE i

From September 1,1992 to May 1,1995:

Performance of Radiation Protection Program has been i

excellent

{

Total Project Estimate 433 person-REM i

(per Decommissioning Plan) l Occupational Radiation Exposures to Date i

l j

Estimate 315.7 person-REM j

Goal 252.5 person-REM i

l Actual 251.0 person-REM l

Highest individual Occupational Exposures j

Annual (1994) 2.73 REM j

9/1/92 to 5/1/95 5.54 REM v

1 1526 Dives Since April 1994, Total of 77.9 Person-Rem

+

-- No Diver Exceeded Exposure Limits Project Approximately 75% Complete, With Only 58%

of 433 Person-REM Exposure Estimate Utilized LOW EXPOSURES DUE TO EFFECTIVE ALARA CONTROLS Page 11

i

~

i i

RADIOLOGICAL PERFORMANCE (Continued) j From September 1,1992 to May 1,1995:

49 skin contaminations,135 clothing contaminations 1

415.741 Radiologically Controlled Area (RCA) person-

+

l hours Industry experience in RCAs:

Plants Contaminations ner 10.000 RCA hours i

j FSV 4.4 j

BWR Outages 14.0 i

PWR Outages 6.5 1

?

I Only 1 positive whole body count, O positive tritium a

i analyses J

0 4

Page 12

i

~

l INDUSTRIAL SAFETY PERFORMANCE From August 1,1992 to May 1,1995:

Only 3 lost time work injuries Lost work day incidence rate (per 200,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) i Contractor 0.58 PSC 0

Severity rate (per 200,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />)

Contractor 56.1 PSC 0

Comparison with typical construction projects (National Bureau of Labor Statistics, accident rates per 200,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />):

Lost work day incidence rate 6.9 Severity rate 132 1

l l

Page 13

1 i

i 4

RECENT INVESTIGATIONS i

1 4

Harassment & Intimidation

)

December 1993, PSC received NRC letter questioning i

management response to certain safety concerns raised during high density block removal Explanation j

response submitted January 1994 NRC Office of Investigations began an investigation in 4

January 1994 -- Focused on March 1993 layoff of 4 laborers who had been involved with high density block i

removal 4

PSC/WT concerned about Chilling Effect on employees and their willingness to raise safety concerns -- On February 22,1994, initiated independent investigation

{

by Stier, Anderson and Malone PSC/WT presented initial findings and corrective actions

)

to -Region IV on August 4,1994 Enforcement Conference scheduled with Region IV on June 1,1995 1

e i

i Page 14

RECENT INVESTIGATIONS i

(Continued) i Falsification of Radiation Survev Records i

As part of Stier, Anderson and Malone independent e

j investigation, PSC discovered apparently falsified radiation survey records on March 17,1994 Material release surveys from September to j

December 1992 RWP surveys in first quarter 1993 No material was incorrectly released, no worker exposures exceeded limits, and there were no associated safety concerns i

l Contractor performed independent assessment of all 1

Radiation Protection activities using Management Oversight Risk Tree (MORT) analysis resulting i

corrective actions have been completed Explained to Region IV on August 4,1994 Enforcement Conference with Region IV will be held in about one_ month i

l I

l i

l i

i.

t i

l Page 15 l

i i

e RECENT INVESTIGATIONS (Continued)

Current Status Safety is continuously emphasized in meetings with workers a

]

and management i

e Raising safety concerns does not result in adverse employment actions Workers are reminded of Stop Work Authority s

4 1

MKF maintains Open Door policy Disagreements are elevated through management PSC oversight presence allows concems to be brought to management attention Current assessments indicate no harassment or intimidation at Fort St. Vrain Workers feel Fort St. Vrain is safe place to work, 2

feel free to raise safety concerns i

Worker perceptions determined through periodic monitorings, surveys, questionnaires, interviews We continue to have disagreements, but our system works --

issues are identified, brought to management attention, and resolved a

a Page 16

t FINAL RELEASE SURVEY i

i I

Remains major challenge of Project Final Survey Plan for Site Release Approved by NRC on January 26,1995 Initial Survey Performed in Repower Area Approximately 5 acres of open land area 4

Final Survey Report submitted March 2,1995 i

ORISE Confirmatory Survey performed March 21-23, 1995 NRC approval expected week of June 5 to support j

repowering construction start l

Widely varying background makes it difficult to prove satisfaction of exposure rate release criteria Release criteria is 5 pR/hr above background i

Background varies from 5 - 30 pR/hr WT developing methodology using in situ gamma j

spectrometer Need to ensure NRC's confirmatory survey uses same survey i

protocol, groundrules as PSC Excellent communications with NRC Staff Page 17

SPENT FUEL STATUS Final EIS for Spent Fuel Activities at Idaho Nuclear Engineering Laboratory issued April 1995 Preferred Alternative includes shipping FSV Spent Fuel to INEL Record of Decision expected June 1995 Certificate for new spent fuel shipping casks issued June 15, 1994 New spent fuel shipping casks scheduled for delivery in second quaner 1995 Negotiations continue with DOE regarding spent fuel Page 18

l PRESENT DECOMMISSIONING CONCERNS 2

i Completion of Final Survey for Site Release 1

Confirmation that established FSV site release criteria will not i

be subject to change Spent fuel disposition /High Level Waste repository Lack of a disposal facility for reactor-generated mixed waste i

i

)

i i

1 I

i I

i i

Page 19

4 CONCLUSION i

i FORT ST. VRAIN DECOMMISSIONING IS PROGRESSING

=

WELL RADIOLOGICAL AND INDUSTRIAL SAFETY a

PERFORMANCE IS EXCELLENT i

I THE PROJECT IS ON SCHEDULE AND ON BUDGET 4

l PSC APPRECIATES NRC'S PROFESSIONALISM AND DEDICATION DURING FSV DECOMMISSIONING PROJECT i

I j

i e

i d

1 I

4 I

O 4

Page 20

1 l

i J

SUPPLEMENTAL INFORMATION STAFFING CHART i

l Page 21

FORT ST. VRAIN g

DECOMMISSIONING STAFF LEVELS 900

---~

~

& Westinghouse Team

@ Contractor gg g,

PSC 700 k%

600 i

f m

4 d 500 i

9

$400 u)

.e 300

a:b'a.-

CONTRACT EMPLOYEES i

g.

. v..

"x

[how, Nbt : :V 3% --

200 -

{!

a

=

tik4/s.511 l lllllll l WESTINGHOUSE TEAM

si l>SC EMROMS

,,l;l i

1 100 -

.,qc,

w % ;..e

j.

'y I E

A.

-}

E[,

> g)}51MN9, ::; rih!:M

. _ it. ;ig6d J m ; y

., J..

O l 7/89 i

e i

i s.

i i

3/90 9/90 3/91 9/91 3/92 9/92 3/93 9/93 3/94 9/94 3

f 1/89 12/89 6/90 12/90 6/91 12/91 6/92 12/92 6/93 12/93 6/94 12/94 6/95 12/95 1

f e '...

UNIT E D ST ATES

/

,\\

NUCLEAR REGULATORY COMMISSION Nh4[) i 7..

R EGloN IV k

611 RY AN P, AZA DRIVE. SUIT E 400 L

't ARLINGTON T E x AS 760118064 August 18, 1995 NOTICE OF LICEf4SEE MEETING Name of Licensee:

Public Service Company of Colorado Name of Facility:

Fort St. Vrain Docket Number:

50-267 License:

DRP-34 EA No.

FSV - EA 95-110 Date and Time Tuesday. August 29, 1995' of Meeting:

1:00 - 4:00 p.m. CDT Location of Meeting:

NRC Region IV. Arlington Office Training Conference Room

Purpose:

Predecisional enforcement conference to discuss the apparent violation of 10 CFR 50.5 and 50.9 during decommissioning activities at Fort St. Vrain.

NRC Attendees:

L. J. Callan. Regional Administrator S. J. Collins. Deputy Regional Administrator R. P. Rosano. Office of Enforcement G. F. Sanborn. Enforcement Officer W. L. Brown. General Counsel R. A. Scarano. Director Division of Radiation Safety and Safeguards (DRSS)

D. D. Chamberlain, Deputy Director, DRSS C. L. Cain. Chief fuel Cycle and Decommissioning Branch (FCDB)

R. J. Evans, Health Physicist. FCDB

(

Licensee Attendees:

A. C. Crawford. Vice-President l

Engineering and Operations Support. PSC M. Fisher Decommissioning Program Director, PSC l

F. Prager. Legal Counsel. PSC l

T. Borst. Radiation Protection Manager. PSC l

D. Warembourg. Consultant. PSC G.

T. Howard. Propct Director Wmt inghou',e Team L

tampagna. Legal Counsel. Westinghouse D. W+1j. Vice President Sclent ifit Ecology Group (SEG)

H.

5tnr.

Peryrt Radiatlon Protection Manager. SEG r

~R:i&inrXG9- %f

9 i

i

)

i Public Service Company of Colorado NOTE:

l

.(1)

'Due to the. subject _ matter-and nature of_this meeting, the meeting is NOT open to attendance by members of the general public.

(2)

NRC personnel, not listed above, that-desire to attend this meeting 4

should notify Charles L. Cain at (817) 860-8186 by COB August 25, 1995.

Approved By*

)

yt Ross A. Scarano, Director v

)

Division of Radiation Safety and Safeguards j

CC:

j Public Service Company of Colorado ATTN; A. Clegg Crawford, Vice President Electric Operations i

P.O. Box 840 i

Denvar, Colorado 80201-0840

}

l Public Service Company of Colorado l

ATTN:

M. H. Holmes

-Project Assurance Manager i

16805 Weld County Road 19-l/2 i,

Platteville, Colorado 80651 i

GA International Services Corporation i

Fort St. Vrain Services ATTN:

David Alberstein, Manager

[

P.O. Box 85608 i

San Diego. California - 92138 1

Public Service Company of Colorado i

ATTN:

D. D. Hock, President and 3

i Chief Executive Officer l

P.O. Box 840 Denver, Colorado 80201-0840 j

LeBoeuf. Lamb Greene & MacRae ATIN:

James K. Tarpey Esq.

633 17th Street. Suite 2800 j

i Denver.. Colorado 80202 1

Chairman Board of County Commissioners

)

j of Weld County, Colorado l

Groeley. Colorado 80631 f

1

)

4 2

j N

L Imp ! n s - r s t e, c.ompans of rolorado Regional Representative Radiation Programs Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver. Colorado 80202-2413 Colorado Department of Health ATTN:

Robert M. Quillin, Director Radiation Control Division 4300 Cherry Drive South Denver, Colorado 80220-1530 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 i

16805 Weld County Road 19-1/2 Platteville, Colorado 80651 J

+

1

o 5

Public Service Company of Colorado l Distribution:

DMB (IE 46)

H. L. Thompson, DEDS (MS 17G21)

C. J. Paperiello, D/NMSS (T 8A 23)

D. A. Cool, D/IMNS (T 8FS)

J. T. Greeves, D/DWM (T 7J9)

C. L. Pittiglio, NMSS/DWN (T 7F27)

P. B. Erickson, NRR/DOPS (0WFN 11 B20)

R. L. Bangart, SP (MS 3D23)~

OEDO RIV Coordinator (MS 17G21)

Wm. Jones, AE0 C. A. Hackney, RSLO J. T. Gilliland, PA0 NRC Attendees RA Secretary DRA Secretary Carol Gordon Division Secretary L. S. Ousley RIV File FCDB E-Mail to:

CJG (Carol Gordon)

DMK1 (D. M. Kunihiro)

BWH (Breck Henderson)

PMNS (Mtg. Announcement Coordinator)

NRC Attendees i

l l

DOCUMENT NAME:

R:\\_FSV\\FSVMEET.LTR To receive copy of document. sndicate in boa: 'C" = Copy without enclosures E" e Copy with enclosures "N" No copy RIV:FCDB l

C:FCDB l Er(0 l

D D : Df}S b l D:DRSS/ l l

RJEvans QdL CLCain g QgfSanborn N DDC6Tmberlain RAScptano 08/15/95 08/l$/95

%08//b/95 08//7/95 08// /95 V

i