IR 05000003/1975003

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IE Insp Repts 50-003/75-03 & 50-247/75-07 on 750520-22. Noncompliance Noted:Failure to Conspicuosly Post High Radiation Area Per 10CFR20.203 Requirements & Failure to Calibr Survey to Take Into Account Nonlinearity
ML20050B638
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/20/1975
From: Knapp P, Panzarino N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20050B632 List:
References
50-003-75-03, 50-247-75-07, 50-247-75-7, 50-3-75-3, NUDOCS 8204070024
Download: ML20050B638 (10)


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IE I Form 12

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(Jan 75) (Rev)

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U. S. NUCLEAR REGUIATORY COFD11SSION

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OFFICE OF INSPECTION AND ENFORCDIENT

REGION I

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50-3

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IE Inspection Report No:

50-3/75-03 &'50-247/75-07

Docket No:

50-247

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DPR-5 Licensee:

Consolidated Edison Company of New York, Inc.

License No: DPR-26 4 Irving Place Priority:

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New York, New York 10003 Category:

C Safeguards Loca tion:

Indian Point 1 & 2 Buchanan, New York Typc of Licensee:

PWR, 615 MWt (B&W)/PWR, 2758 MWt 60 Type of Inspection:

Routine, Unannounced, Health Physics Dates of Inspection:

May 20-22, 1975 Dates of Previous Inspection: May 1-2, 1975/ March 3-7, 1975 f - -- ~ - ~ ~ -- ;,

Reporting Inspect

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N. M. Panzarino, Radiation ' Specialist DATE Accompanying Inspectors:

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DATE Other Accompanying Personnel:

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Reviewed By:

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P. J. Knapp, Chief, FRP Section DATE

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8204070024 7507d5

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PDR ADOCK 05000003 G

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sum 1ARY OF FINDINGS Enforcement Action A.

Items of Noncompliance 1.

Violations None

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2.

Infractions None 3.

Deficiency

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Failure to conspicuously post a high radiation area in accord-ance with the requirements specified in 10 CFR Part. 20,203(c)(1).

(Details, Paragraph 7)

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B.

Deviation i

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Failure to calibrate survey instruments at more than one point on each scale to take account of possible non-linearity.

(Details,

Paragraph 3.c)

Licensee Action on Previously Identified Enforcement Items Item of Noncompliance, IE Inspection Report 50-247/75-01 The licensee's corrective actions with respect to the above referenced report were reviewed by the inspector.

Procedure SAO-105 has been re-vised to direct the holder of an RWP to advise all personnel working on the job of the specific radiation protection requirements (including any modifications).

Design Changes

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Not inspected i

Unusual Occurrences

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None

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Other Significant Findings A.

Current Findings 1.

Accentable Areas

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Audit Program.

(Details, Paragraph 2)

b.

Ibterials Inventory.

(Details, Paragraph 4)

c.

Receipt and Transfer of Materials.

(Details, Paragraph 5)

d.

Notifications and Reports.

(Details, Paragraph 6)

e.

Personnel Exposures.

(Details, ' Paragraph 8)

2.

Unresolved Items Status of modifications to waste drumming facility.

a.

(Details, Paragraph 9)

b.

Status of engineering study on interfaces between con-

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taminated and non-contaminated systems.

(Deta.ils, Para-graph 10)

Status of changes to calibration of survey instruments, c.

j (Details, Paragraph 3.d)

3.

Infractions and Deficiencies Identified by Licensee None B.

Status of Previous Unresolved Item

The licensee has decided not to produce a Radiation Safety Manual.

The present radiological protection procedures will serve as 'the-manual.

This item is closed.

(RO Inspection Report 50-247/74-07, IE Inspection Report 50-247/75-01)

Management Interview A management interview was held at the site on May 22, 1975.

Persons Present

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W. Stein, Manager, Nuclear Pouer Generation Department T. Law, !!anager, QA J. Makepiece, _ Director, Technical Engineering A. Cheifet, Director, Radiation Safety J. Cullen, Director, In-Plant llealth Physics l

M. Byster, QA l

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Items Discussed

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A.

Purpose cf the-Inspection

The inspector stated that the purpose of the inspection was to review the licensee's health physics program.

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B.

Review of Item of Noncomoliance and Deviation

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I The items are as identified under Enforcement Action in the I.

Summary of Findings section of this report.

(Details, Para-j graphs 3 and 7)

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DETAILS 1.

Persons Contacted J. Cullen, Health Physics Director E. Imbimbo, Health Physics Supervisor

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J. Pierrotta, Health Physics Supervisor G. Liebler, Radiological Engineer W. Carson, Acting Test Engineer

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J. Higgins, General Chemistry Supervisor 2.

Audit Program a.

The licensee's audit program was reviewed to determine its effectiveness and scope.

The following areas were reviewed with respect to the above criteria:

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(1) Audits of internal programs.

(2) Audits of services and contractors.

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(3)

Records of audits.

(4)

Qualification of auditors.

(5)

Follow-up actions.

The Radiation Safety Sub-Committee minutes from January 1974 through May 14, 1975 were examined.

The minutes of the ::uclear Facility Safety Committee (NFSC) were also reviewed.

I b.

The staffing and audit function of the Radiation Safety Sub-Committee are defined by procedure.

The functioning of this subcommittee is consistent with the procedure.

The constitution and function of the NFSC is consistent with c.

Technical Specification 6.5.

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3.

Instrumentation and Equipment An evaluation was made of the licensee's.use of instrumentation a.

j and equipment with respect to the following areas:

(1)

Procedure adequacy.

(2) Adequacy of supplies.

(3)

Interpretation of results.

(4)

Program implementation.

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b.

With respect to item (1) above, the inspector noted that Procedure HP-13, Revision 0 (Calibration of Health Physics Monitoring Instruments), specifies the calibration technique to be used on instruments.

The licensee is apparently using a different technique for the calibration of an instrument (portal monitor).

The inspector noted that.more than one procedure is in existence.

The licensee stated that quali-fled management personnel are responsible for instrument calibration and noted that HP-13 does not prevent the use

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of other calibration techniques.

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c.

With respect to item (4) above, the inspector noted from observation of records, procedures and discussions with the cognizant licensee representatives that all survey instru-ments, Unit 1 functional radiation monitors and Unit 2 proc-ess radiation monitors were only calibrated at one point on each scale.

The inspector informed the licensee that this appeared to constitute a failure to check for non-linearity errors associated with each scale of the instrumentation as is indicated to be appropriate by accepted radiological practices.

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d.

The inspector determined from discussion with the cognizant licensee representative that a calibrator has been purchased for calibration of survey instruments. This individual stated that once a new calibration program (including changes-to procedures) is implemented using the new machine, linearity checks will be performed at some appropriate interval.

4.

Materials Inventorv A review was made of the licensee's inventory of byproduct a.

material held, under License No. 31-03112-01 with respect to the following:

(1)

Isotopes.

(2)

Quantities.

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(3)

Forms.

(4)

Uses.

(5)

Leak tests of scaled sources.

No items of noncompliance were observed.

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Receipt and Transfer of Materials The licensee's program for shipping and receiving radioactive a.

materials was reviewed.

The inspector determined that the licensee has procedures for receiving, inspecting, and open-ing packages.

b.

The inspector was informed by the cognizant licensee repre-sentative that shipment of irradiated fuel in the past was performed by a contractor.

He was told that when irradiated fuel is shipped in the future a contractor will most likely be employed again.

6.

Notifications and Reports a.

By discussion with the cognizant licensee representative the inspector determined that there have been no incidents requir-ing reports to the NRC under 10 CFR 20.402 (reports of thefts

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or loss of licensed material),10 CFR 20.403 (incidents re-

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quiring immediate or 24-hour notification),10 CFR 20.405 (reports of overexposures and excessive levels and concentra-tions).

No reports have therefore been required under 10 CFR 20.409 (b).

b.

By direct observation of a copy of the report, the inspector determined that the licensee has complied with the require-

ments of 10 CFR 20.407 with respect to personnel exposure and monitoring reports.

The inspector examined approximately 30 reports of personnel c.

exposure on termination of employment or work.

The licensee's

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system for notification in this area is consistent with the requirements of 10 CFR 20.408.

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7.

Posting During a tour of the facility (Units 1 and 2) for purposes of ob-servations with respect to radiological control practices, the inspector noted that the entrance to the Unit 2 volume control

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tank cubicle was not posted as required by 10 CFR 20.203(c).

The inspector noted from_ the survey report and sign posted at the en-trance to the cubicle that the radiation level on contact with l

the tank was 2500 mr/hr.

Licensee representatives stated at the l

closcout of the inspection and during a subsequent phone call on June 5, 1975 that the appropriate posting was accomplished and that the appropriate individuals were reinstructed in posting l

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requirements.

This instruction is also part of the retraining program.

8.

Personnel Exposures

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a.

The inspector examined records of film badge results.for the period January 1, 1975 through March 31, 1975 which included

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the period of the steam generator outage.

No exposures in excess of, regulatory limits were noted.

b.

The licensee's summary of exposures for 1974 was examined.

Monitoring was provided for 1636 individuals.

Of this num-ber 617 individuals or 38% had no measurable exposure; 682 individuals or 41% had whole body exposures of less than one rem.

In the range of one to six rem, there were 337 individ-uals (21% of the total).

The highest exposure for the year was 5.08 rem.

There were no exposures in excess of regulatory limits.

9.

Drum Handling a.

The inspector observed the licensee's drum handling operation.

The drums are filled with evaporator bottoms using a hose until they are about one-third full or are reading 1 R/hr on contact.

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The liquid is mixed with vermiculite and concrete. The mix-

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ture is manually stirred.

b.

The inspector was informed by the cognizant licensee represen-tative that during the handling of 22 drums on May 22, 1975 the following exposures were received by the individuals

involved:

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Operator 150 mr

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Health Physics Technician 50 mr.

i The drums were reading between 5 and 200 mr/hr.

The licensee representative stated that the usual dose rates from the drums were as high_as.1 R/hr.

The average number of drums shipped per month.in 1974 was 138 drums.

Significant exposure is therefore being accumulated during the drum handling opera-

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tion and exposures are likely to increase with the startup l

of Unit 3 because its waste will also be drummed in Unit 1.

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c.

The inspector determined that the licensee's Nuclear Facility l

Safety Committee has decided to upgrade the drum handling process by going to a vaste solidification system which will

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virtually eliminate personnel exposure from the waste handling process.

d.

Although the NFSC has approved the expenditure of money for a new system, the final design and date of installation have not been decided.

10.

Clean-Contaminated System Interfaces a.

The inspector discussed systems in which contaminated fluids interface with noncontaminated systems with a licensee repre-sentative during the inspection and a subsequent phone call on June 13, 1975.

The licensee representative stated that an Engineering Request has been issued to review these systems.

The systems identified are shown in the following paragraphs.

b.

The auxiliary boiler system supplies house steam to the following:

(1) Waste evaporator steam coils.

(2)

Boric Acid evaporator steam coils.

(3) CVCS gas stripper heat coils.

(4 ) RWST heat coils.

(5)

FWST heat coils.

It is anticipated that the auxiliary steam condensate receiver tank will be continuously monitored.

A sampling and analysis program was established for this system on May 21, 1975.

Once each month a sample will be analyzed for gross and isotopic activity.

h The fresh water cooling system at Unit 1 is used to cool systems c.

in the controlled area.

There are two branches to this system.

Each branch has a continuous radiation monitor (NaI scintilla-

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tion detector) on the suction line to the branch's pump.

Grab samples are taken from this system quarterly and analyzed for gross activity.

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d.

The component cooling system cools system in the controlled

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area at Unit 2.

A continuous monitor (R-17; scintillation detector) monitors the common suction line to pumps in this system.

A grab sample from this system is taken quarterly and analyzed for gross activity.

c.

The continuous monitors alarm in the respective control rooms.

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The turbine hall contains two cooling systems.

These are the

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instrument air and conventional plant closed cooling.

The cognizant licensee representative stated that these systems are not monitored in any way as the probability of being con-taminated is zero for the instrument air system and extremely low for the convantional plant closed cooling system.

(Accord-ing to the licensee representative, even with a primary to secondary leak, this system has low contamination potential.)

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Review of March 1975 Outage The inspector determined that a review was made of the Unit 2 a.

outage in March 1975* by the licensee for the purpose of expo-

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sure reduction.

Based on this review various suggestions were made by the plant health physics staff to reduce exposures during the next outage.

The following are some of these suggestions:

(1)

Erection of permanent scaffolding.

(2)

Improvement of manway and diaphragm removal and installation procedures.

(3) Training on a mock-up.

(4) Reduction of the size of work groups.

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  • IE Inspection Report 50-247/75-02.

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