ML20059L660
| ML20059L660 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/10/1993 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-93106, NUDOCS 9311170263 | |
| Download: ML20059L660 (4) | |
Text
.
O Public Service' P0fl1,.
P O BOX 840 DENVER CO 80201-0840 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 A. Clegg Crawford Wce President Electric Production November 10, 1993 Fort St. Vrain P-93106 Director, Office of Enforcement U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 DOCKET NO. 50-267
SUBJECT:
Response
to Demand for Information (NRC Investigation OI-4-91-019; DOL 91-ERA-037)
REFERENCE:
1)
NRC Letter, J.
L.
Milhoan to A.
C.
- Crawford, dated October 13, 1993 (G-93162)
Dear Director:
Enclosed is the response of Public Service Company of Colorado (PSC) to the Demand for Information contained in Reference 1.
Reference 1 demands
"...an explanation as to why the NRC can have confidence that the Radiation Protection Manager will perform his duties in licensed activities without discriminating against individuals who raise safety concerns and without creating an environment in which employees working for him fear retaliation for raising safety concerns." The NRC can have such a desired level of confidence based on the following factors:
Oualifications of the Radiation Protection Manaaer (RPM)
The RPM has a Master of Science degree in Radiation Biology and is Certified by the American Board of Health Physics in the Power Reactor specialty.
When the RPM received his certification in
- 1983, he was one of only 23 people in the world who had accomplished this.
The RPM has been recertified in 1987 and 1991 which reflects his commitment to continuing his formal education in
)
the field of radiation protection.
The RPM served for approximately two years as a region-based inspector for the NRC, and became cognizant of the importance of compliance with all NRC Rules and Regulations.
The RPM also served as a Research Scientist for a DOE prime contractor at the Hanford reservation where he performed evaluations of the adequacy of power reactor emergency planning and radiation protection programs under contract to the NRC.
In all, the RPM has over 17 years of experience dealing with complicated technical issues in the field of radiation protection.
9311170263 931110 DR ADOCK 05000267 j
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i In addition to his technical expertise, the RPM has been in a middle management position with PSC since 1981.
During this period of time, the RPM has developed and improved his management skills l
l through formal training in the areas of Supervisory Training and refresher, Middle Management Development and refresher, Advanced Management Skills, Effective Performance Appraisals, Business i
Negotiation, Applied Problem Solving, Service Leadership, Effective Communications, Conflict Management, Total Quality Management, i
I Business Ethics, Team Leadership, Goalsetting, and.many others.
j
{
Performance of the RPM Throughout the period of time that the RPM was in his position, the NRC Systematic Assessment of Licensee Performance (SALP) reports gave no lower than a "2" or acceptable rating to the Fort St. Vrain radiation protection program.
In fact, for the period October 1, 1983, through April 30, 1987, the radiation protection program was accorded a "1" or superior rating.
The NRC recognized the program j
as aggressive, strong, of high quality, and effective in reducing i
radiation exposures to plant workers and the public.
Radiation exposures at FSV have been two orders of magnitude lower than the industry best performers.
It was recommended by the NRC review team that consideration be given to reducing the NRC inspection effort in this area.
In September of 1987, the RPM took the position of Nuclear Training Manager where he was successful in achieving INPO accreditation of all Fort St. Vrain training programs.
However, during the absence of the RPM, the radiation protection program received a SALP rating of "2
and declining" for the period May 1,
1987, to August 31, 1988.
As it turned out, this constituted the final SALP rating period at Fort St.
Vrain.
However, the program continued to degrade, resulting in an Enforcement Conference with the NRC in mid-1990.
Based on the PSC commitment to an excellent radiation protection program, the RPM was reassigned to responsibility for the radiation protection program in September of 1990.
By late
- 1991, the NP.C had noted improvement in the program, and the inspection reports written in 1992 by the NRC Senior Resident Inspector, himself a Certified Health Physicist, verified that the radiation protection program was again a strength at Fort St.
Vrain.
r P-93106 November 10, 1993 Page 3 On the management side, several effectiveness evaluations have indicated that the RPM has a very effective management style which relies on the principles of participative management, collaborative problem solving, teambuilding, and mentoring.
In addition to his radiation protection responsibilities, the RPM is currently in charge of
- training, emergency preparedness, record
- storage, security, and clerical functions at Fort St. Vrain. Ongoing audits of these programs indicate that they have been properly developed and effectively implemented.
The ability to establish and implement programs in diverse areas as noted above speaks well to the management abilities of the RPM.
The RPM has consistently achieved " Superior" ratings on his annual performance evaluations, as he did for the period of time in which the alleged violation occurred.
Included in the performance evaluations are " Common Management Responsibilities" including problem solving, leadership, service excellence, teamwork, and discipline. The RPM was accorded a " Superior" rating in the " Common Management Responsibilities" area for the period of time in which the alleged violation occurred.
10 CFR 50.7 Experience Prior to the alleged violation included in Reference 1, there have been no allegations or violations of the provisions of 10 CFR 50.7 on the part of the RPM, either with respect to the radiation protection program, or any of the other areas for which the RPM has had management responsibility.
PSC denies the alleged violation contained in Reference 1.
Since the alleged violation included in Reference 1,
the RPM has continued to perform his duties in licensed activities without any allegations or violations of the provisions of 10 CFR 50.7.
PSC Cornorate Philosonhv PSC has shown itself to be a good corporate neighbor.
Key to this position of trust is a corporate philosophy of open communications, service excellence, and continuous improvement.
If we were convinced that the RPM had willfully violated the provisions of 10 CFR 50.7, steps would have been taken immediately to remove this individual from his position.
PSC recognizes the responsibilities that come with the operation / decommissioning of a
nuclear generating station.
A critical element of our success is the performance of our management staff.
Included in the PSC Corporate Principles are,
" Competent managers at all levels," and "High ethical and moral standards in all we do."
The types of behavior that would lead to willful violations of any regulatory requirement are simply not acceptable to PSC.
l
P-93106 November 10, 1993 Page 4 In conclusion, I am convinced that the RPM will continue to discharge his duties in licensed activities without discriminating against individuals who raise safety concerns, and without creating an environment in which employees working for him fear retaliation for raising safety concerns.
The RPM has reported directly to me in the past.
My conclusion is based on my personal observations of the management style of the RPM.
The NRC should not hesitate to place full confidence and trust in the RPM.
If you have questions regarding this matter, please contact the Fort St.
Vrain Decommissioning Program Director, Mr.
Don W.
Warembourg, at (303) 620-1009.
Sincerely, A.
Clegg Crawford Vice President Electric Production ACC/bj cc:
Assistant General Counsel for Hearings and Enforcement U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Regional Administrator, NRC Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 I
a
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