IR 05000003/1976007
| ML20042B171 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/01/1976 |
| From: | Knapp P, Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B163 | List: |
| References | |
| 50-003-76-07, 50-286-76-14, 50-3-76-7, NUDOCS 8203250051 | |
| Download: ML20042B171 (11) | |
Text
-
.
..
IE:I Form 12 gone, (Jan 75) (Rev)
A3 0F __
JUL 1 3 E76
$h min
.
U. S. NUCLEAR REGUI.ATORY CC:CiISSIO:1 0FFICE OF INSPECTIO:( AND ENFORCC1ENT
REGION I
50-03/76-07 50-03
'
50-286/76-14 50-286 Docket No-IE Inspection Report No:
DPR-5 Consolidated Edison Company of New York. Inc.
License Ne:
DPR-64 Licensce:
4 Irving Place p
D /B2 New York, New York Category-
,
_
Safeguards Group:
Buchanan, New York Location:
PWR 965 MWe (W)
,
,
Type of Licensec:
Routine - Unannounced Type of Inspection:
May 10-13, 1976
,
Dates of Inspect. ion:
Pril 29-May 8, 1976 Dates of Previcus Insocction:
7 /hb
Reporting Inspect r:
90L bM
/ DUE
'L.D. R) Neely, RadiaEion' Specialist Accompanying Inspectors:
DAT E
-
DATE l
DATE
!
l l
Other Accompanying Personnel:
DATE
/
-
l Reviewed By:
ll dAU C
'
[bg P. Jh Knapp, Chief, Radiation Support Section
-
B203250051 760709 PDR ADOCK 05000003
,
G PDR i
.
-
.-
_-
,
\\
.
i l
j SUMMARY OF FINDINGS Enforcement Action A.
Items of Noncompliance 1.
Violations
'
None 2.
Infractions Unit 3 Technical Specification 6.11 requires that proced-a.
- ures for radiation protection of personnel be prepared consistent with the requirements of 10 CFR Part 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Station Admin-istrative Order No. 105, Revision 3, " Work Permits,"
dated March 1,1976, requires that Work Permits (WP)
and Radiation Work Permits (RWP) be issued and followed.
This order was modified March 9, 1976, to state, that with regard to Unit 3, the RWP is replaced with a Radiation Exposure Authorization which does not require '
the Watch Foreman's signature.
Contrary to the above, the provisions of a Radiation Exposure Authorization were not followed on May 11, 1976, in that individuals worked on the 67' elevation of the Unit 3 Primary Auxiliary Building without the protective equipment (lab coats) required by Radiation Exposure Authorization 76-3-93.
(Details, 5)
b.
Unit 1 Technical Specification 3.2.6 requires that radia-tion control procedures be maintained and made available to all station personnel and be adhered to.
Station Administrative Order No. 105, Revision 3, " Work Permits,"
dated March 1,1976, requires that Work Permits (WP)
i
and Radiation Work Permits (RWP) be issued and followed.
Contrary to the above, Station Administrative Order No.
105 was not adhered to on May-10, 1976,-in that individ-uals worked in the Integrated Waste System Room of the Unit 1 Primary Auxilary Building without the protective
!
equipment (gloves) required by RWP 075-1-319.
(Details, l
6)
>
.
'
.
.
.
-2-
~
3.
Deficiencies 10 CFR 20.203(b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radia-tion caution symbol and the words, " Caution - Radiation Area."
Contrsry to the above, on May 11, 1976, the Non-Regenerative Heat Exchanger Room in the Unit 3 PAB had radiation fields up to 7 mR/hr and was not posted as a radiation area.
(Details, 7)
Licensee Action on Previously Identified EnfSrcement Action The inspector reviewed the licensee's progress concerning corrective and preventive measures associated with items of noncompliance identified in Inspection Reports 50-03/76-05 and 50-247/76-08.
These items were also discussed in a letter, J. P. O'Reilly to W. J. Cahill dated April 9, 1976.
The inspector noted that corrective action for these items of noncompliance had been initiated by the licensee but that the actions had not been completed.
These items will be reviewed further during a subsequent inspection.
Design Changes Not Inspected Licensee Events Not Inspected
.
Other Significant Findings A.
Current Findings
.
1.
Acceptable Areas No inadequacies were identified during inspection of the following areas:
i
- -.. -
-
._
,
'.
.
.
-3-a.
Survey Records.
b.
Area Radiation Monitor Calibration and Tests.
Process Radiation Monitor Calibration and Tests.
c.
d.
Radiation Exposure Authorization Records, Radiation Shielding Survey Procedure and Results.
e.
'
f.
Containment Entry and Egress Procedure.
2.
Unresolved Items Routine HP Monitoring Program Implementation.
3.
Infractions and Deficiencies Identified by the Licensee None 4.
Deviations Section ll, " Waste Disposal and Radiation Protection System,"
of the Unit 3 Final Safety Analysis Report describes the Facilities and Access Provisions.
One of these provisions is that entry to and. exit from the Controlled Area is through the Security Room only.
Contrary to this provision, an additional change room has been established near the Unit 3 control room, which is being i
used by individuals for entry and exit of the Unit 3 Con-
trolled Area.
(Details, 8)
B.
Status of Previously Identifigg Unresolved Items None Management Interview A management interview was conducted at Buchanan, New York (site) on May 13, 1976.
l
l i
_
.
'.
<
A
%
.
-4 Persons Present W. Stein, Manager, Nuclear Power Generation Department R. W. Van Yyck, Manager, Nuclear Services R. H. Hayman, Manager, QA Monitoring and Review J. M. Makepeace, Director, Technical Engineering A. Cheifetz, Manager, Radiation Safety J. Cullen, Director, Health Physics
'
S. Salay, Plant Manager T. J. Kawula, Test Engineer Items Discussed A.
Purpose of the Inspection The inspector stated that the purpose of the inspection was to review the licensee's Health Physics Program specifically, startup radiation shielding surveys, evaluation of surveys, procedure changes and radioactive waste system tests luring startup and power ascension of Unit 3 and review the status o? corrective action regarding items of noncompliance for Unit 1.
B.
Acceptable Areas The items discussed are as identified under the "Other Significant Findings" section of this report.
C.
Items of Noncompliance a
The items discussed are as identified under the " Enforcement Action" section of this report.
.
_ _ -.
__.
-
_
_
.
.
.
.
DETAILS 1.
Persons Contacted W. Stein, Manager, Nuclear Power Generation Department
,
R. Van Wyck, Manager, Nuclear Services
. Cheifetz, Manager, Radiation Safety
'
J. Cullen, Director, Health Physics G. Liebler, Radiological Engineer
'
G. Imbimbo, Health Physics Supervisor J. Perrota, Health Physics Supervisor S. Zulla, Operations Engineer, Unit 3 J. Kelly, Station Chemistry Director C. Caputo, Assistant Engineer, Test 2.
Scope of the Inspection The scope of the inspection consisted of a review of the licensee's health physics program, specifically, radiation shielding surveys, test evaluations and radioactive waste systems management during startup and power ascension of Unit 3 and a review of corrective action of items of noncompliance for Unit 1.
3.
Plant Records
.
The inspector reviewed the following records for the period in-dicated and found that they appeared to be acceptable.
a.
Survey Records - 4/7/76-5/12/76.
b.
Survey Instrument Calibration Records - 4/25-28/76-5/8-11/76.
c.
Area Radiation Monitors - 1/29/76.
'd.
Process Radiation Monitors - 4/29/76.
e.
Radiation Shielding Survey Records - 4/28/76-5/11/76.
i
-.
..
. -.
.
.
.
.
.
.
-6 '
t 4.
Work Permit and Radiation Exposure Authorization System In order to assure that all necessary measures are taken in connec-tion with work performed, the licensee utilizes a Work Permit System (specified by Station Administrative Order No.105, Revision 3, dated March 1, 1975.) The provisions of this system are summar-ized briefly here as an aid in following the chronology of events described in a later section.
The steps to be taken are controlled and documented by means of a permit, called a Work Permit (WP), which is prepared and utilized as follows:
A foreman with a task to accomplish consults with the Watch Foreman,
(the highest level of operating management who is responsible for all activities carried out at the unit during his shift) or the General Watch Foreman-(the next highest level of management, responsible for all units).
An Operating Order, which requires all necessary isolation, lockout, inspection, and other safety measures, must be issued and its pro-visions must be carried out and documented with signature on the Work Permit.
If the Work Permit is to authorize work within the controlled area, an additional document, a Radiation Work Permit, which is designed
'
to ensure that all necessary radiation protection measures are taken, must be prepared and approved. A statement to this effect must appear on the Work Permit.
Station Administrative Order-105/Rev. 3, Section C requires a Radia-tion Work Permit (RWP) to be issued for each job in the Controlled Area and for RT inspection in any part of the Station with the exception of work of a repetitive nature or work done on a routine basis covered by a Health Physics approved procedure and normal operations activities.
A variance to Station Administrative Order No. 105 was issued March 9, 1976 which modified the requirement of a Radiation Work Permit for Unit 3 and was replaced with a requirement for a Radia-tion Exposure Authorization (REA) effective with criticality of Unit No. 3.
-.
.
-.
.
.
~
-
..
-
.
-
,
.
-7-The Radiation Exposure Authorization (REA) system is such that-Operations gives authorization for the work to be performed (i.e.
issuance of Work Permit) and Health Physics authorizes receipt of exposure to perform the work.
The requirements for a REA are the same as those for a Radiation Work Permit.
That is, a REA shall be issued for each job in the Controlled Area of Unit No. 3 and for RT inspection in any part of Unit No. 3 with the exception of work of a repetative nature or done on a routine basis. covered by a Health Physics approved procedure on normal operations activities.
-
The REA form may be initiated prior to receipt of Operations authorization to perform a job.
However, the REA shall not be issued (signed by job supervisor and Health Physics Representative)
until said Operations authorization is verified by a Health Physics Representative.
This verification shall take the form of Health
'
Physics Representative seeing the approved Work Permit for the job or contacting the Unit No. 3 Watch Foreman to obtain the verifica-tion for those jobs for which Work Permits are not issued.
Each REA expires as of 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on the day following date of issuance unless otherwise indicated on the front side of the REA.
Re-issuance of the REA requires the initials of the job supervisor and Health Physics Representative each day the job continues.
The location of each REA covered job should be re-surveyed on the off-shift prior to the re-issuance of the REA to determine any changes in radiological conditions which might require specifying different radiological controls.
Failure to re-survey shall not preclude re-issuance of the REA, however, any area not re-surveyed shall be placed on a priority list by Health Physics for re-survey during the working, day.
Finally, any REA that has expired may be reacti-vated upon request of the job supervisor.
In the event three (3)
consecutive working days have elasped since the job was last worked, the job location shall be re-surveyed prior to activation of the REA.
The Health Physcis Technician manning the Security Desk is respon-sible for maintaining the files of active REA's and for re-issuing the REA's.
The job supervisor shall present his copy of the REA to l
this technician who shall obtain the Health Physics copy from his
!
files.
Both individuals shall then initial the two copies of the REA signifying the re-issuance.
.
l l
l l
_
_.
_
_
.
. -
-
-
.
s
.
,
.
.
_
-8-5.
Radiation Exposure Authorization On May 11, 1976, during an inspection of the Unit 3 Primary Auxiliary Building, the inspector observed workers, working in the area of the component coolant pumps without protective clothing.
The inspector observed lab coats lying on a piece of equipment located near the workers.
The inspector asked the licensee representatives what the protective clothing requirements were for work in this-The licensee representative stated that Radiation Exposure area.
-
Authorization No. 76-3-93 covering this job required the use of lab Coats.
The inspector noted that contrary to this Radiation Exposure Author-ization, the workers were not wearing lab coats or any type of body protection.
The licensee representative immediately took action requiring the workers to wear lab coats.
6.
Radiation Work Permits On May 10, 1976, during an inspection of the Unit 1 Primary Auxil-inry Building, the inspector observed workers, working in the Integrated Waste System room. The inspector noted that the workers were working without protective equipment (gloves) and asked the
- '
licensee representative if gloves were required while working in this area.
The licensee represen'tative did not know what the pro-tective equipment requirements were for this specific job. The licensee representative reviewed Radiation Work Permit No. 076-1-319, covering work in the Integrated Waste Systems Room and stated to the inspector that protective equipment (gloves) were required.
The inspector stated that contrary to this Radiation Work Permit, the workers were not wearing gloves. The licensee representative Lamediately took action requiring the workers to don gloves.
7.
Posting of Radiation Areas During an inspection May 11, 1976, of the Unit 3 Primary Auxiliary Building, the inspector measured radiation levels up to 7 mR/hr in the Non-Regenerative Heat Exchanger Room.
The inspector noted that the area was not posted as a radiation area and that this consti-tuted noncompliance with 10 CFR 20.203.
The area was posted as a radiation area prior to completion of the Unit 3 inspection on May 11, 197.
.
.
.
.
'
-9-8.
Facilities and Access Provisions Section ll, " Waste Disposal and Radiation Protection System," of the Unit 3 Final Safety Analysis Report, describes the facilities and access provisions.
Access provisions are as follows:
The plant site is divided into two categories, the Conventional Area and the Controlled Area.
The Radiation Control Area encompasses all plant areas in which radioactive materials and radiation are present in excess of limits specfied in 10 CFR 20, 20.202, b2. Access to the Controlled Area is limited to those persons authorized for entry by the General Superintendent or his designated representatives.
Entry to and exit from the Controlled Area is through the Security Room only.
Contrary to the above, a change room has been established and being used by Unit 3 operations personnel for entry to and exit from the Unit 3 Controlled Area.
It was stated to the inspector that access to this change area was controlled by key cards and that only per-sonnel authorized key cards could enter the Controlled Area through this change area. All other personnel requiring access to the Unit 3 Controlled Area are required to use the Security Room, located in Unit 1.
The inspector asked a licensee representative if members of the Health Physics staff had access to the Unit 3 Controlled Area through this change room.
It was stated to the inspector that the llealth Physics staff did not have authorized access to this area or entry into the Unit 3, Controlled Area by way of this change room.
The licensee representative stated that when surveys are required in the change area, film badges are to be changed or dosimeters read, the IIealth Physics staff is allowed entry into the change area to do so.
,
The inspector asked the licensee representative if there was docu-mentation authorizing the use of this change room (entry and exit to Unit 3 Controlled Area) instead of the Security Room, located in l
Unit 1.
The licensee representative stated that subject was dis-cussed but could not recall if written authorization for this
'
change had been issued.
The inspector stated that in using this additional change area for entry and exit of the Unit 3 Controlled Area, this constitutes a deviation from the Unit 3 Final Safety Analysis Report.
.
D
_ - ___ _
- - _.
- _. _ _ _ _. _
_. _ _ _ _. _.
.
.
.-
_ -. _
..
,
,
.
.
-10-
.
'
9.
Health Physics Program The inspector reviewed the Uni *. 3 Health Physics Program which did not appear to be fully implemented.
The inspector reviewed radia-tion survey records which indicated that a routine check of con-trolled areas, specifically, air sampling, radiation levels and
contamination levels had not been implemented and that it appeared
'
that monitoring was done on a call basis only.
The inspector asked the licensee representative if a program for routine sampling and radiation monitoring was in effect.
The licensee representative
'
stated to the inspector that he gave instructions to his personnel to implement a routine area check, but he found that it had not
,
been done.
The licensee representative took immediate action to fully implement the Unit 3 Health Physics Program by initiating a routine monitoring program which consisted of taking routine air samples, floor smears, area radiation levels, and source checking of instruments.
The inspector stated that this is an Unresolved Item review by the inspector of the implementation of the'pending further
'
routine monitoring program,
,
i 10.
Startup Radiation Measurements
.
The inspector reviewed the records and schedules of radiation shielding surveys to determine whether all surveys were performed as required by the Unit 3 Final Safety Analysis Report and in accordance with the licensee's procedures.
The records reviewed by the inspector consisted of 10% and 50% radiation shielding surveys,
.
instrument calibration, survey procedures and the evaluation of
'
test results.
The inspector accompanied the survey team on the 50%
power survey and determined that procedures were followed for
,
containment entry and radiation shielding surveys.
After reviewing radiation shielding survey records and discussions with licensee representatives as to their evaluation of the test results, it was j
determined by the inspector that there appeared to be no problems associated with the power ascension and the inspector had no
,
i further questions at this time.
l
--. -
-
-
, --,
_
-_
.--
-
- -.
---
.-
-
.