IR 05000003/1974003
| ML20050D040 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/18/1974 |
| From: | Knapp P, Mann J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050D036 | List: |
| References | |
| 50-003-74-03, 50-247-74-07, 50-247-74-7, 50-3-74-3, NUDOCS 8204090499 | |
| Download: ML20050D040 (9) | |
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U.S. ATOMIC ENERGY CC:21ISSION i
DIRECTORATE OF RECULATORY OPERATIO"S
REGION I
50-3 50-3/74-03
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50-247
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50-247/74-07 Docket No:
RO Inspec tio: Re~ port No':
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Consolidated < Edison Company o'f New York, Inc.
License No:
DPR-26 Licensee:
4 Irving Place p
C New York, New York Category:
Indian Point 1 and 2 Location:
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Type of Licensee:
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Type of Inspection:
Dates of Inspection:
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Dates of Previous Inspection:
February 13, 14, 26, 27, 1974
, Principal Inspector.:
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Date John / ann, Radiation Specialist M
Accompanying Inspectors:
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NONE Other Accompanying-Personnel:
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Reviewed By:
s l Date P. J. Knapp, Section Chief y
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Facility Padiological Protection Section
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8204090499 740423
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PDR ADOCK 05000003 O
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SUFDIARY OF FINDINGS Enforcement Action
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A.
Violations Four individuals were exposed to whole body radiation in excess 1.
of limits stated in 10 CFR 20.101(a) and (b).
(Details, Section 3)
B.
Safety Items None Items Licensee Action on Previously Identified Enforcement
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Work has started on the installation of locks on certain shicided doors These locks will enable an individual leading to high radiation areas.
to open the door from the inside.
This item remains open.
(RO:I Inspec-tion Report 73-13, Details Section 6; letter from licensee to RO:I, dated December 7, 1973)
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Unusual Occurrences Four expo,,sures in excess of 10 CFR 20 limits (Details, Section 3).
Other Significant Findings
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A.
Current Findings _
Mr. W. Stein has replaced Mr. W. R. Cobean as Ibnager, Nuclear'
Total man-ren exposure for 1973 is Power Generation Department.
The next highest exposure occurred in 1970 and 5160 man-rem.
was 1376 man-rem.
The 1973 exposure was due to maintenance on the Nuclear boiler dcwncomers.
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Status of Previously Reported Unresolved Items B.
Final R$ GAD-8, "Whole Body Counting Program" has been written.
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approval is expected to be made by March 25, 1974.
This pro-
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cedure was required by Revision 48 to the Technical Specifica-
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tions.
This item is closed.
(RO:I Report 73-13)
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Clarification of approvals required for health physics pro-
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cedures-is unresolved pending submission of changes to Section i'
6 of the Technical Specifications.
This item r'emains open.
(RO:I Report 73-13)
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Ibnagement Interview The management interview was held on March 22, 1974 at the conclusion of the inspection.
The following individuals attended:
W. Stein, Manager, Nuclear Power Ceneration Department R. W. Van Wyck, Manager, Nuclear Services A. Cheifetz, Director, Radiation Safety J. Cullen, Radiological Engineer W. Ferreina Quality Assurance The following subjects were discussed:
The inspector stated that the exposures to four employees in excess.
A.
of 10 CFR 20 limits during the third and fourth calendar quarters of 1973 was an apparent violation.
(Details, Section 3)
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The status of a Radiation Safety Procedure Manual was discussed.
B.
The licensee stated that a manual would be completed by the end of the calendar year.
This iten remains open.
the status of proposed changes to Section The inspector asked about C.
6 of the Technical Specifications regarding clarification of NFSC (Nuclear Facility Safety Ccemittae) approval for health physics pro-The licensee stated that this will be forthcoming, but cedures.
could not commit to a date at this time.
This item remains open.
The inspector discussed his findings of the administration of the D.
particularly in retraining of
"as low as practicable" program,
personnel and methods of advanced planning for minimizing radiation The licensee agreed to add "ALAP" to their exposure to personnel.
retraining program and to accelerate their advance planning program development.
This item remains *open.
(Details, Section 3)
The inspector discussed his findings with regard to the full term E.
license review for Unit 1 and stated that there were no further
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questions.
(Details, Sections 4, 5, 6, 7)
The inspector stated that housekeeping and contamination counted elevation)
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on the' pool floor of the Fuel llandling Building (70 f t.
of Unit 1 was not as good as the majority of the other areas of both Unit 1 and Unit 2.
The licensee agreed and stated that this (Details, Section area would be attended to as soon as possible.
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DETAILS _
1.
Persons Contacted
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R. Van Wyck, P.anager, Nucicar Services A. Cheifetz, Director, Radiation Safety P. Gaudio, licalth Physics General Supervisor E. Imbimbo, IIcalth Phy: sics Supervisor J. Perrotta,IIcalth Physics Supervisor J. Cullen, Radiological Engineer R. Roland,11calth Physics Technician R. Ibrcinkewicz, IIcalth Physics Technician J. Kelley, Station Chemist J. liiggins, Chemistry General Supervisor
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Administration
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The current plant organization pertaining to chemistry and health physics is as follows:
bbnager Nuclear Power Generation Dept.
I Manager Nuclear Services
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Technical I
Director Station Radiation Safety Operations Chemist
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i Supv. Nuclear In-Plant Radiological Arca llP Director Engineer l
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li.P. Gen.
Supervisor
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IIP Supv.
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IIP Supv.
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lIlP Techs l LIP Techsl IIP Techs l
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Qualifications of personnel presently employed in the radiation safety department appear to be consistent with those specified llcalth Physics duties on shift are performed in ANSI N18.1 l
by a supervisor and llP technicians.
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3.
Personnel Exposures Four cases of personnel exposure in excess of 10 CFR 20.101 limits I
were reported by the licensee as follows:
i Date Reported-Exposure Dates Dose, rem
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11-23-73 3rd quarter, 1973 3.710 2.
12-13-73 4th quarter, 1973 3.730 4th quarter, 1973 2.190 3.
12-18-73
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2-14-74 4th quarter, 1973" 3.050
Cases 1, 2 and 4 resulted from large discrepancies between daily In dosimeter reading accumulations and the film badge results.
No each case the dosimeter was used to control exposure times.
exposure probicas were suspected until film badge results were returned showing exposures in excess of 3 rem.
Case 3 was a contractor enployee, 1-8 years of age.
Erroneous data
from the contractor allowed the employee to exceed the 1.25 rem limit, according to the licensee.
When the individuals' age becace known, the exposure was reported.
The licensee stated that in order to help control exposures, admin-istrative exposure limits and authorizations have been changed twice; procedure SAO-120 (Rev. 2) " Control of Personnel tihole Body Radiation and Airborne Radioactivity Exposure - Issuance of Film Badges" has been revised twice, once on January. 11, 1974 and again
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on February 25, 1974.
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The inspector stated that Regulatory Guide 8.8 specifically dis-cusses the concepts of advanced planning and study of work cethods in order to reduce exposures, rather than after-the-fact procedure r
The licensee agreed,and stated that a new program designed
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around Regulatory Guide 8.8 was being developed.
The inspector noted that similar exposures in excess of 10 CFR 20 limits had occurred in the past (RO:I Reports 50-3/73-13 and 72-11) and ex-pressed concern over the recurrence of these exposures.
Use of Radiation and Radioactivity Measuring Instrumentation
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4.
hren Radiation Monitors a.
According to the licensee, five areas in Unit 1 are provided These are gac=a with NMC Model GA-2T arca radiation monitors.
scintillation detectors set to alarm at 3 mr/hr above back-
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There is a read-out and alarm in the Control Room as
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well as a local alarm.
The units are located,as follows:
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(1) Pedestrian tunnel between Chem Systems and Nuclear Scr-vices Buildings.
(2) Outside Evaporator Bottoms Room on the 53 f t elevation of
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the Chem Systems Building.
(3) Outside drumming station on the 70 ft. elevation of the
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Chem Systems Building.
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Fuel llandling Building floor near sphere entrance.
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(5) Valve Callery, 33 f t. elevation, Chem Systems Building.
The licensee stated that the units are located in the most likely areas to exhibit sudden, excessive gamma radiation i
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b.
Airborne Radioactivity Monitdring Both fixed and portable particulate and gaseous radioactivity
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monitoring systems are used extensively in Unit 1.
I (1) Fixed monitors are Tracealab Model MAP-1B moving paper and gas detectors.
Sensitivity is 10-11 pCi/cc fer 137 s C
60 o.
Locations are:
and 8 x 10-12 pCi/cc for C
(a) Containment Cooling Air
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(b) Annulus
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(c) Drain Stack (d) Fuel P.andling Pool Exhaust (c) Chen Systems Building Exhaust (f) Decontamination Waste Pit i
Portabic units are NMC Model CRM-51M particulate or parti-(2)
culate and gaseous radioactivity monitors.
There are 13 of these units used extensively throughout the controlled area for all work or processes involving the potential re-lease of airborne radioactivity.
Tritium monitors are
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also used in certain locations.
Vacuum cleaner type hoses are commonly used to monitor the breathing zone of the Inspection findings showed extensive coverage of
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worker.
all work in process.
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Portabic Instruments
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A check of available instruments showed all to have an op-to-date calibration sticker and to be in good working order.
In-struments were readily availabic for the immediate use of the health physics technicians.
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Cencral Henith Physics Operation
The inspector examined' access control. point procedures for keeping track of daily personnel exposures..All personnel entering the l
controlled area are required to wear film and/or TLD badges and scif-reading dosimeters.
Each person logs in and out of the area A security and enters his dosimeter readings in the log each time.
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guard insures that the procedure is followed.
Daily dose accumula-
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tions on each person ar.c maintained.
Radiation Uork Permits are required for all work within the controlled area, according to the All personnel are required to exit thru portal monitors.
licensee.
The licensee stated that a system of advance planning for maintenance
An work involving potential radiation exposure is being designed.
advance planning engineer will be appointed as soon as his present
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duties can be co=pleted.
Training in ALAP concepts begins for all employees on April 4, 1974.
This will be a part of the station's
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annual radiation safety retraining" program.
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Radiation Arcas and Contamination Zones Except as noted below, housekeeping, contamination. control and 'use f
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of radiation and high radiation areas are in accord with ANSI N45.2.3 Exceptions noted and generally accepted hcalth physics practices.
are as follows:
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Hallway outside Purification Outlet Chem Systems l
Filters blocked by contaminzation zone.
l Bldg., 53 ft. elev.
Leak onto ficor causing contamination Condition has existed 2-3 weeks accord--
I ing to. licensee representative.
Entire area delineated as contamination Fuel Handling Bldg.
Large crates, boxes, misec11aneous Pool Floor, 70 ft. elev.-
zone.
tools, parts and equipment haphazardly stored throughout the area.
(Left over
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from recent nucicar boiler work).
Licensee representative stated that action to correct-
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this situation'was underway.
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Valve Callery To/From Contamination zone.
Maintenance job in progress to change piping and drain sys-
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Floor contaminated. Water Icak at a-
flange, drippir.g onto. floor.
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Hall cutside Sewage Ejector Pump Room Chem Systems Bldg.,
messy, used as temporary storage area, 14 ft. elev.
water on floor.
011 leaks from ceiling create hazardous
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Nuclear Services Bldg.,
70 ft. elev. First-Aid condition.
Housekeeping poor.
Room 7.
Training
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New employces and visitors are given a formal orientation lecture in A written examination is given and radiation protection practices. Retraining is conducted for all filed in the personnel file.
This will include respiratory protec-personnel on an annual basis.
tion and "ALAP" concepts, according to the licensee, for the cycle Instruction includes use of " friskers" beginning April 4, 1974.
and portal monitors to minimize th,e spread of contamination.
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Records Review _
Observed Sample Requirecent Liquid Release Permits Units 1 and 2:
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Permits from November, 1973 10 CFR 20, Appendix B, to date:
Discharges limited Table II to 3% of most restrictive
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limit.
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Gaseous Release Permits f or Unit 2_ (No releases Unit 1)
Permits from November, 1973 10 CTR 20, Appendix B, to date:
All releases less Table II than 10% of limits before dilution with plant air.
Personnel Exposure Records:
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Fihn badge reports from 10 CFR 20.101 October, 1973 to date:
98 employees exceeded 5 rem total for 1973.
The highest None exposure was 9.120 rem.
l exceeded limits except as pre-
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viously reported.
(Sphere) were Radiation Work Permits for jobs in Unit 1 Containment Required data, infor-reviewed for the period 7-26-73 to 12-31-73.Tuc of these were examined in mation and signatures were complete.
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detail for completeness and adequacy of surveys, air sampics and radiation dose measurements.
The RUP's and all associated records were complete and indicated that appropriate procedures had been followed.
9.
ALAP Status A managccent statement on keeping personnel exposures as low as
practicable is'includdd in procedure RSGAD-2.
A Corporate-Wide document stating the position has been drafted and is waiting for corporate approval.
The plant radiation safety director is res-ponsible for the ALAP Program.
Audits are performed by the Cor-porate Quality Standards and Reliability Group.
Qualifications of the radiation safety director and his staff appear to meet requirements of Regulatory Guide 8.8.
His supervisor is a Certified Health Physicist.
ALAP training for all personnel
begins on April 4, 1974.
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A program of advanced planning and pre-job exposure analysis is being developed, according to a licensee representative.
An ad-vanced planning (radiological) engineer is to begin his duties
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shortly.
Corporate approval for the program has not been obtained, yet, the licensee stated.
The inspector stated that this program commitment should be an integral part of the solution to the expo-sure contrci nroblems associated with the f our exposures in excess
of 1G CFR 20 limits that occurred in 1973.
10.
Respiratory Prote_ction Program *
The radiat$on safety director is responsible for the program.
Opera-ting procedures required by TS Rev. 48 are complete.
Users are re-trained annually as well as just before using the equipment.
Fitting, use, cleaning, maintenance, inspection and storage appear to meet requirements of ANSI Z88.2.
Extensive air sampling issued before, during and af ter jobs requiring respiratory protection.
Whole body counting is also used as a follow-up for suspected exposures and verification of proper respirator fit.
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