IR 05000003/1976003

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IE Insp Repts 50-003/76-03, & 50-247/76-05 on 760316-19. Noncompliance Noted:Notice of Violation Involving Radiological Working Conditions Issued W/Insp Rept 50-003/75-11 & 50-247/75-20 on 760123 Not Posted
ML20042A793
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 05/18/1976
From: Neely D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20042A790 List:
References
50-003-76-03, 50-247-76-05, 50-247-76-5, 50-3-76-3, NUDOCS 8203240084
Download: ML20042A793 (10)


Text

{{#Wiki_filter:I . - IE IJorn,12 - * , O E ' (Jan 75)- (Rev-)

_ AS OF Prv 91 1976 REG!CN I MS fiVi 05TAINED PT&K;Eit. :y , CLFRACE IM ACC0dDAi4C6 hitM 10 Cid 2790 , . U.

S.' NUCLEAR REGULATORY CO:CIISSION i 0FFICE OF IN3PECTION AND ENFORCD!E:TT

REGION I

50-0n3 I l 50-003/76-03; 50-247/76-05 Sn-247 IE Inspection Report No: Docket No: DPP.-5 Licensce: Consolidated Edison Co=pany of New York, Inc.

License No: DPR-26 4 Irving Place Priority: , ' New York, New York Category: C . . Safeguards _ _, Loca tion: Buchanan, New York PER 615 MUt (BMi) ! -

' Type of Licensec: PIGt 2758 Wt (to T)Te of Inspec tion: Routine, Announced . Dates of Inspection: March 16-19, 1976 bates of Previous Inspection: December 9-12 and 18-19, 1975 . Reporting Inspector: _ //.[ N ;0% f[/E/jf / ~ D. R j' eely ( ind tion Specialist DATE t,n O LMM (% Acco:panying Inspector-: fl{ 5 /[[ 7[, L(E. Reynolas,sBafiationSpecialist .DATE

DATE - . DATE Other Apcompanyinp, Personnel: , _ DATE I 6% --h & %,,? -

itcviewed 3y: ' ' .. P. J. Knapp, Chief,'Fadiatiok Support Section / 57.[: ' FF & MS Br.

i 8203240084 760520 i PDR ADOCK 05000003

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, SUMMARY OF FINDINGS l i . Enforcement Action l A.. Items of Noncemoliance 1.

Violations . None 2.

Infractions . None 3.

Deficiencies Contrary to 10 CFR 19.11, the Nctice of Violation involving radiological working conditions issued with Inspection Reoorts 50-03/75-11 and 50-247/75-20 on January 23, 1976 and the reply dated February 17, 1976, vera not posted.

(Details, 6)

Licensee Action on Previous 1v Identified Enforcerent Action l A.

Enforcerent Action Identified in Inspection Reoort 50-03/75-11 and 50-247/75-20 i The inspector reviewed the licensee's corrective, action described in the letter dated February 17, 1976, W. J. Cahill, Jr. to James P.

O'Reilly, and found that the licensee's corrective action appeared to be as described in the referenced letter. There are no further questions at this time.

(Details, 4) - l Design Changes Not inspected.

Licensee Events - Not inspected.

Other Significant Findings , . A.

Current Findines 1.

Acceptahic Areas No inadequacies were identified during inspection of the following areas:

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Radioactive materials packaging and shipping.

b.

Health physics procedures.

c.

Instrument calibration.

d.

Organization and staffing.

e.

Health Physics training and records.

' f.

Radiation work permits.

g.

Survey records.

h.

Air sample records.

2.

Unresolved Items None i 3.

Infractions and Deficiencies Identified bv the Licensee Ncne ' 4.

Deviations ' i None B.

Status of Previousiv Identified Unresolved Items (Inspection Report 75-11/73-20) - ! Posting of radiation areas within the restricted area of the facility.

  • This item remains unresolved.

(Details, 5) Management Interview A management interview was conducted at Buchanan, New York (Site) on March 19, 1976.

Persons Presdnt Mr. W. Stein, Manager, Nucicar Power Generating Department Mr. R. W. VanWyck, Manager, Nuclear Services Mr. T.,M. Law, Manager, Quality Assurance Mr. A. S. Chiefett, Radic: ion Safety Director Mr. J. M. Makepeace, Technical Engineering Director Mr. J. J. Kelly, Station Chemistry Director - Mr. N. Hartmann, QS&R Consultant , Mr. M. Byster, QA Engineer < l l l l ! ! l <

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. Items Discussed l ' A.

Puronse of the Insnection l The inspector stated that the purpose of the inspection was to i review the health physics program for Unit 2 and review the radio- ~ , active materials packing and shipping activities for Unit 1.

i B.

Acceptable Areas The items discussed are as identified under the "Other Significant Findings" section of this report.

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, . . . . . . ! DETAILS , , 1.

Persons contacted I Mr. S. Salay, Plant Manager , l Mr. R. W. VanWyck, Manager, Nuclear Services Mr. A. S. Chiefetz, Fadiation Safety Director Mr. G. Liebler, Padiological Engineer Mr. J. Cullen, Director, Health Physics Mr. G. Imbimbo, Health Physics Sunervisor Mr. P. Guadio, Health Physics Supervisor Mr. J. Perrotta, Health Physics Suotrvisor Mr. W. Carson, Engineer. Tests Mr. W. Jahnke, Forecan ' , 2.

Scope of the Insnection ! The inspection consisted of a revieu of the radiation protection nrogram, review of selected records, nrocedures, plant facilities and waste storage areas. The inspection also included a review of radioactive caterial packing and shioping activities for Unit 1.

  • 3.

Plant Records The inspector reviewed the following records for the per,iods indicated and fou'nd that they appeared to be acceotable.

Air sample records, 3/1/76 - 3/15/76 2.

Radiation vork permits, 3/1/76 - 3/14/76 3.

Plant survey reports, 3/1/76 - 3/18/76 4.

Contamination control. 3/1/76 - 3/16/76

5.

Instrument calibration records, 12/75 - 3/5/76 ! 6.

Containment air sampling system records, 1/16/75 - 1/3/76

7.

Performance test records, (recombiner air supply blowers) f i 7/8/75 - 2/17/76 8.

Radiation protection training records, 2/3/75 - 3/1/76 l ' 9.

Health physics technician training records, 1975 - 1976 10.

Radiation monitor calibrations, 1975 - 1976 11.

Radwaste shinnent records, 1/6/75 - 3/18/76

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1.icensee Action on Previous 1v Identified Enforcement Action f ' (Insucction Repor.t 50-03/75-11 and 50-247/75-20) a.

Failure to perform survevs (In CFR 20.7nl(h)) The insocctor reviewed the licensee's corrective action with regard to the survey reauirements for Unit I radwaste ' ! . . _n ____ -..-- -

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building and the decontrolled areas adjoining Unit 1.

The doorway going into the radwaste Baling Station from the Unit 1 decontrolled arca is now covered with N 1/2" of , lead sheeting that is secured to the wall.

The inspector , I surveyed the shicided area which revealed radiation levels ! to be <5 mrem /hr at contact.

[ ! A cognizant licensee rcoresentative stated that health ! physics personnel have.been instructed to survey the Baling , Station room as a daily routine and to audit the alarming ' radiation monitor (located in the Baling Room) for proper operation. The licensee representative further stated that the alarming radiation monitor is required to be operating , at all times.

The inspector noted that the licensee's corrective action appeared to be adeauate to meet the reauirements.

The inspector had no further cuestions on this matter.

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Failure to nerforn air survevs (10 CFR 20. )n3(a)) , ! The licensee's corrective action with regard to taking air ! surveys consisted of revising health physics procedures HP-6 l and HP-5.

It was stated to the inspector that ghese revised j procedurcs were discussed with the health physics technicians l during a training session conducted on 3/11/76.- The revised

' procedure !!P-6, Rev. 3 (Determining Radiological Controls and Monitoring Reauirements) has been changed in order to provide instructions and guidance for health physics per-sonnel in doing pre-job evaluations on the job follow-up and re-evaluation of the job if necessary.

Procedure HP-6 includes guidelines such as performing radiation surveys, contanination surveys, determination of air sampling and tbc changing and counting of particulate filters. A specific guide has been added to HP-6 for deter-mining the need for, pre-jcb air sampling and on-the-job air sampling and/or monitoring.

t The procedure describes the use of constant air monitors -(CN51)

. and the storing of data taken from the air monitors.

Further- , more, the procedure reauires that at the conclusion of the job, a conplete package pertaining to the job he compiled and filed in the health physics office.

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. " . -6- ! Procedure HP-5, Rev. 2 (Issuing Radiation Vork Permits (RWP) and Radiation Exposure Authorizations) has been revised in order to use the guidelines of HP-6.

The inspector reviewed revised procedure HP-6 and HP-5 and found the procedures to be adeounte.

A review of air sample records, CAM charts, RWPs and radiation surveys from 3/1/76 confirmed that the revised procedures are sufficient and that personnel were following the pro-cedures. The inspector did not have any further nuestions on this matter.

Failure to maintain records of survevs (10 CFR 20.401(b)) f c.

. The licensee's revis, ion of procedure HP-6 (Guidelines for Determining Radiological Controls and Monitoring Requirements) appears to be adequate in establishing a procedure for main-taining records. The procedure requires that at the conclusion of the job, a complete package pertaining to the job should be compiled consisting of the following items: ! (1) Radiation Work Permit (s) or Radiation Exposure Authorization (s) (2) Initial survey sheet (3) Daily survey sheets (4) CAM strip chart (if CAM used) (5) Summary exposure sheet, whole body, gas, particulate, etc.

The insp'ector reviewed several job packages which had been ' compiled since procedure HP-5 was initiated (3-4-76) and found the records to be adecuate. The inspector ' stated that the corrective action taken by the licensee was,satisfsetory and there were no further questions on this matter.

d.

Failure to maintain locked or otherwise control a Fich 1-adiation Area within the restricted area of Unit 1. (10 CFR 20.203(c)) An inspection of High Radiation Areas, within the restricted area of Unit 1, was performed by the inspector. The inspection con-sisted of inspect.ing all the High Radiation Areas including t e Boron Pump Roem, to determine if the doors were locked or con-trolled. The inspection revealed that all High Radiation Areas were locked as required.

A cognizant licensee representative stated that station personnel ' have been in'structed to keep the doors locked if continuous sur-veillance cannot be provided.

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Faf' lure to survey, nost. and take air samnles as reouired by procedure DD-7-A. developed nursuant to Technical Snecifi- ' cation 6.11 The inspector reviewed the licensee's corrective action in regard to, the transfer of liquid radioactive vaste from Unit 2 to Unit 1.

. The licensee's corrective action consisted of revising pro-cedure DD-7-A (Transfer of Licuid Radioactive Waste from Unit 2 to Unit 1).

The reauirements of procedure DP-7-A, revised 3/1/76, are as follows: l "3.0 Precautions and Linitations 3.1 During transfer operations a station security guard shall be assiFned to continuousiv patrol ! the outside section of hose batween Unit No. 2 , and Unit No. I with specific instructions to ! ! report any observed leakage to the Unit No. 2 Watch Foreman and.to nrevent ii. advertent damage ! to the hose while in use.

3.2 The Unit Fo. 2 waste evanordtor shall be removed fron service during periods of waste transfer.

3.3 If at any time during transfer, water is noted outside the outer. hose or if water is noted at either end of the outer hose, transfer will be stopped immediately and the control room notified.

The Patch Foreman shall immediately notifv Health d Physics who shall evaluate the leakage.

NOTE: Health Physics shall periodically perform field surveys of the transfer hose.

Said surveys should be conducted both during a typical waste transfer, to determine radiation levels as a result of vaste being transferred, and during non-transfer periods to determine notential l > build-up of radioactive material in the transfer line."

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. The licensee representative stated to the inspector that the revision to procedure DP-7-A deleted the requirement of taking - air. samples during the transfer because the area where the liquid waste enters into the transfer line is enclosed, preventing any airborne activity.

It was further stated by the licensee repre-

! sentative that with the transfer line being located within the ' restricted area (inside fenced a'rea) the levels of radiation created during transfer were not significant to reauire a health physics technician to survey the transfer line each time a transfer is made. The licensee representative stated that the security guards are being notified prior to the liauid waste transfer and that health physics personnel are doing surveys of the trans-fer hose periodically.

. t ! The insocetor questioned the licensee representative in regard j to the term "periedically".

The licensee stated ihat periodical]y ' would be at least once every 30 days.

The inspector reviewed the liquid waste transfer log hooks for the period March 1, 1976 to March 16, 1076.

The log books indicated that security guards had been notified of these transfers.

The inspector stated that the licensee's corrective acticn appears to be satisfactory and had no further questions on this matter.

This item is considered closed.

5.

Previous 1v Identified Unresolved Iten " Postine of Radiation Areas Within the Restricted Area (Inspection Report 75-11/75-20) This item remains unresolved until further evaluation and inspection by the inspector is done.

6.

Posting of Notices The insnector asked a licensee representative whether the Notice of Violation issued with Inspection Reports 50-03/75-11 and 50-247/75-20 had been posted. He noted that it had been railed from the Region I office on January 23, 1976 and that it contained items of noncompliance involving radiological working conditions.

The licensee representative stated that neither the Notice of Violation r.or the reply to it had been - . .

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i i posted because the Notice of Violation contained only infractions l , nnd a deficiency'and did not contain any items of noncompliance which ' were classified as violations. The inspector stated that 10 CFR 19.ll(a)(4) requires the posting of any Notice of Violation involving radiological working conditions regardless of the classification of the itens of noncompliance it contains, and the licensee reply and that failure to do so constitutes noncompliance with 1,0 CFR 10.11.

The licensee representative posted the Notice of Violation prior to the completion'of the inspection.

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