IR 05000003/1976010
| ML20042B167 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/13/1976 |
| From: | Knapp P, Neely D, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B161 | List: |
| References | |
| 50-003-76-10, 50-247-76-23, 50-286-76-25, 50-3-76-10, NUDOCS 8203250047 | |
| Download: ML20042B167 (15) | |
Text
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) ' IE:I Form 12
. Rev)
i (Jan 75)
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ts U. S. NUCLEAR REGULiTORY COMMISSION'
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0FFICE OF INSPECTION AND ENFORCDIENT
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REGION I
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50-286/
50-247
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IE Inspection Report No: 50-03/76-10, 50-247/76-23, 76-25 Docket No:
50-286 DPR-5 h
Licensee:
Consolidated Edison Company of New York, Inc. License No:
DPR-26 g
4 Irving' Place Priority:
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Category:
Safeguards
Group:
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Buchanan, New York
Location:
Type of Licensee:
PWR, 615 MWt (B&W), PWR, 2758 MWt (W), PWR, 3025 MWt (W)
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Type of Inspection:
SPecial, Unannounced c
b-Dates of Inspection:
September 27-October 1, October 12-13, and 19-20, 1976
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Dates of Previous InspectionA_ September 13-16, September 27-October 1, 1976
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Reporting Inspector:
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Neely, Radia'h3.on Sphcialist DATE Accompanying Inspectors:
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Streeter, Reactor Inspector DATE I
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DATE
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DATE r.
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NONE
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Other Kcccapanying Personnel:
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DATE Reviewed By:
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P. J) Knapp, Chief, dadiation Support Section DATE
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8203250047 761126 PDR ADOCK 05000003
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SUMMARY OF FINDINGS
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Enforcement Action
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Items of Noncompliance
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Violations
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B.
Infractions 1.
76-23-01 - Control of High Radiation" Areas.
10 CFR 20.203(c)(2) requires that high radiation areas es-I tablished for more than 30 days, be equipped with control
,
devices to reduce the level of radiation upon entry into the
area, or be equipped with control devices to energize conspic-
uous visible or audible alarm signals upon entry into the i
area, or be maintained locked except during periods when
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access is required, with positive control over each individual i
entry.
,
g Contrary to the above, on September 29, 1976, a h'igh radiation area at the Refueling '4ater Storage Tank which had been
i established for more than 30 days, was not equipped with the specified control device or locked with positive control
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maintained over each individual entry.
(Details 5)
2.
76-25-01 - Adherence to Radiation Protection Procedures.
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j Technical Specification 6.11 requires that procedures for
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personnel radiation protection be prepared consistent with
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the requirements of 10 CFR 20 and be approved, =aintained and lf adhered to for all operations involving personnel radiation
,y exposure.
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General Administrative Directive RS GAD-2, Revision 1, " Radio-(,e e
logical Health and Safety Procedures," dated February 24, 1975, specifies that employees are not to smoke in the Controlled i
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Area except for areas that have been approved for smoking.
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Contrary to the above, General Administrative Directive RS
GAD-2, Revision 1. was not adhered to on September 28, 1976,
in that an individual was observed smoking on the 73' elevation i
of the Unit 3 Primary Auxiliary Building, an area not approved for smoking.
(Details 6)
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Deficiencies
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,D None.
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Licensee Action on Previously Identified Enforcement Action i
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A.
Inspection Nos. 50-003/76-05 and 50-247/76-08, Limits for whole
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body exposures of individuals required by 10 CFR 20.101(b).
(De-df-tails 8)
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B.
Inspection Nos. 50-003/76-05 and 50-247/76-08, Adherence to re-
quirements of Station Administrative Order No. 105, Revision 3,
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" Work Permits."
(Details 7)
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Inspection Nos. 50-003/76-05 and 50-247/76-08, Adhering to radia-
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tion protection procedures; (1) Revised Controlled Area Sign-In fi Procedure, (2) General Administrative Directive RS GAD-2, Revision
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3, " Radiological Health and Safety Procedures," (3) Station Ad-j$
ministrative Order No. 105, Revision 3, " Work Permits."
(Details
7)
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D.
Inspection Nos. 50-003/76-05 and 50-247/76-08, High radiation area Vi_
access controls required by 10 CFR 20.203(c)(2).
(Details 5)
2f E.
Inspection Nos. 50-003/76-05 and 50-247/76-08, Posting of high
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ip radiation areas required by 10 CFR 20.203(e)(1).
This item is con-
Y sidered closed.
(Details 9)
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F.
Inspection Nos. 50-003/76-05 and 50-247/76-08, Posting of Radia-
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tion Areas required by 10 CFR 20.203(b).
(Details 9)
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Design Changes
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Other Significant Findings l
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Current Findings i%
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Acceptable Areas fW7 No inadequacies were identified during inspection of the
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Radiation Work Permits.
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Survey Records.
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Air Sample Records.
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d.
Maintenance Procedure No. 2/3 CM-RV1/2.4, " Removal of
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Reactor Vessel Upper Internals and Closure Head."
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2.
Unresolved Items i
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None.
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3.
Infractions and Deficiencies Identified by the Licensee
I A number of items of noncompliance were identified by the licensee through their internal audit system conducted April
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13, 1976 through September 29, 1976.
Because of the number
of items identified, the items have been grouped into the f;
four categories listed below:
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Contrary to 10 CFR 20.203(b), during the period April a.
13, 1976 to September 29, 1976 at least 27 instances it were identified by the licensee's audit program in which i
areas had radiation fields in excess of 5 mr/hr and k
were not posbed as radiation areas by the licensee.
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(Details 4)
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b.
Contrary to 10 CFR 20.203(c)(1), during the period April 13, 1976 to September 29, 1976 at least 25 in-i stances were identified by the licensee's audit program J
in which areas had radiation fields in excess of 100
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mr/hr and the licensee failed to post the areas as high
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radiation areas.
(Details 4)
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c.
Contrary to 10 CFR 20.203(c)(2), during the period April
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13, 1976 to September 29, 1976 at least 103 instances i
were identified by the licensee's audit program in which j
high radiation areas established for more than 30 days, s
were not equipped with the specified control device or
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locked with positive control maintained over each individ-5{
ual entry.
(Details 4)
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Contrary to Technical Specification 3.2.6 (Unit 1) and 6.8 (Unit 2), during the period April 13, 1976 to September i
yi 29, 1976 at least 40 instances were identified by the
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licensee's audit program in which Station Administrative s
Order No. 105, Revision 3, " Work Permits," dated March 1, l
1976, was not adhered to.
(Details 4)
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Deviations
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None.
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B.
Status of Previousiv Identified Unresolved Items
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i Not inspected.
.y Management Inte rview s
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A management interview was conducted at Buchar.cn, Met-York (site) on e
g October 1, 1976,
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Persons Present
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I E. Kessig, Acting Manager, Nuclear Power Generation Department IE J. Bayne, Power Authority State of New York
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S. Cantone, Superintendent of Power, Power Authority State of New York l1 W
T. Law, Plant Manager
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J. Makepeace, Director Technical Engineering
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,j R. Hayman, Manager, QA Monitoring and Review l N'
B. Moroney, Chief Operations Engineer S. Zulla, Operations Engineer i
R. VanWyck, Manager, Nuclear Services
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A. Cheifetz, Radiation Safety Director
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N. Hartman, Consultant, QS&R
j P. Upson, Quality Assurance and Review J. Cullen, Director Health Physics
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A second management interview was conducted at Buchanan, New York (site)
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on October 13, 1976.
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Persons Present
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T. Law, Plant Manager
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R. VanWyck, Manager, Nuclear Services
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j R. Hayman, Manager, QA Monitoring and Review t-e
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3-J. Makepeace, Director, Technical Engineering
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A. Cheifetz, Radiation Safety Director 2b J. Cullen, Director, Health Physics
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W. Sipperly, Planning Engineer r
Items Discussed li-
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A.
Purpose of the Inspection
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The inspector stated that the purpose of the inspection was to S
review the licensee's corrective action with regard to their re-
sponse to the Notice of Violation, issued June 21, 1976 and to review additional licensee commitments established during tele-a (-
phone discussions on July 15 and 16, 1976'.
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B.
Acceptable Areas
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The items discussed are as identified under the "Other Significant
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Findings" section of this report.
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C.
Items of Noncompliance
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The items discussed are as identified under the " Enforcement Action"
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section of this report.
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DETAILS
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1.
Persons Contacted
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E. Kessig, Acting Manager, Nuclear Power Generation Department
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T. Law, Plant Manager
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J R. VanWyck, Manager, Nuclear Services
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A. Cheifetz, Radiation Safety Director
J. Makepeace, Director, Technical Engineering
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E W. Monti, Plant Engineer
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B. Moroney, Chief Operations Engineer S. Wisla, Senior Engineer
J. Cullen, Director, Health Physics
,
G. Liebler, Radiological Engineer G. Imbimbo, Health Physics Supervisor J. Perrotta. Health Physics Supervisor
,
P. Gaudio, Health Physics Supervisor W. Grassi, Administrative Supervisor
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S. Sadlon, Health Physics Technician
J. Odendahl, Senior Electrical Technician, Radiation Safety
2.
Scope of the Inspection i
g The scope of the inspection consisted of a review of survey records, i
W Radiation Work Permits l interviews with plant personnel and an in-i spection of the Unit 1, U.ni_t_2., and Uni._t _3'. c.o_n_ t_ r_ol_l'e_d_ areas.
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3.
Plant Records The inspector reviewed the following records for the periods in-dicated and found that they appeared to be acceptable.
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Radiation Work Permits 9/12/76 - 9/28/76
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Air Sample Records 8/24/76 - 9/28/76 l
Survey Records 9/12/76 - 9/28/76
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High Radiation area Door Checks 10/6/76 - 10/13/76 4.
Internal Audit Pro gram
The licensee in their response to the Notice of Violation, issued
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June 21, 1976, and in accordance with supplemental commitments i
made in telephone conversations on July 15 and 16, 1976 initiated
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a formal audit and inspection program.
The program was designed
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to assure compliance with the regulations and to strengthen =an-
agement controls over the radiation safety program.
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The licensee's commitments are as follows:
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"The inspections by an experienced staff member of the l
health physics organization will be conducted daily until
the end of the present outage, and will then be conducted weekly until the end of the year, at which time the program
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will be reviewed and the frequency adjusted as appropriate."
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b.
"The independent special audits initiated by the Assistant
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Vice President are done monthly."
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c.
"The audits by the Quality Assurance and Reliability organ-ization are conducted monthly."
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i During the course of inspection, the licensee's program was audited to determine that; (1) the audits were being conducted as specific.d, (2) the daily report of findings and the weekly summary reports were submitted to the levels of management as specified in the response letter dated July 9, 1976, and (3)
Y corrective action had been accomplished or instituted on a timely
basis for all of the licensee identified items of noncompliance.
d The inspector reviewed the results of the audits and inspections
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conducted during the period April 13, 1976 through September 29, llg 1976.
The inspector noted that the licensee had conducted appro-ximately 12 monthly audits (two organizations auditing monthly).
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During the conduct of these internal audits, the licensee identi-
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fied many items of noncompliance and documented that corrective
action had been accomplished or instituted on a timely basis.
In order to determine if the licensee's management control system
had been effective as a result of the audits, a trend analysis i
consisting of an arrangement of the licensee identified items into four categories was tabulated.
v The table showing the number 'f items identified during each o
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month, beginni g April 13, 1976 and ending September 29, 1976 i
follows:
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TABLE I
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Four of the categories of itema of noncompliance identified by the licensee
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during the period April 13, 1976 through September 29, 1976 r'
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d Ntaber of Instances Identified h
j Period Audited High Radiation Area Illgh Radiation Area Radiation Area Adherence to Radiation
,
Posting Access and Control Postina Work Permits
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4/13/76 - 4/30/76
6
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5/1/76 - 5/11/76
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j 6/1/16 - 6/10/76
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7/1/76 - 7/11/76
20
12
8/1/76 - 8/10/76
21
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Following 8/30/76 work areas were being closed and the number of individuals working in the controlled
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area was reduced by approximately 200.
9/1/76 - 9/29/76
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The inspector stated to a licensee' representative that in' reviewing
"1 the results of the trend analysis it appeared that the licensee's
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il corrective action had been effective in reducing items of noncom-
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pliance with the exception of the category identified as high radiation area access and control.
Analysis of this category in-
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dicated that the licensee's corrective action did not appear to
be effective.
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The inspector selected at random a few items of noncompliance from
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each category and examined the status during site tours and inter-g views to determine if the licensee's correctiva action was satis-
factorily accomplished. Detailed examination revealed that all r
items had been satisfactorily corrected,with the exception of g
controlling access to a high radiation area.
This item is dis-
cussed in detail 5 of this report.
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I The inspector stated that while the audit program appeared to be
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effective, management's followup corrective action was not completely j
satisfactory.
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5.
Control of High Radiation Area
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As previously described in detail 4, the inspector reviewed the i
licensee's audit program to determine if corrective action for
llh all items of noncompliance had been accomplished or instituted y-on a timely basis.
The inspector selected at random and examined U-areas from the category, High Radiaiion Areas Access and Control.
Corrective action had been completed with the exception of the
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following case:
h on Septeober 21, 1976, the licensee's internal audit identified
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the area around the Refueling Water Storage Tank (RWST), as a high
radiation area which had been established for more than 30 days l
' f and required that the licensee document in the audit report that
.p the area had to be either loc,ked or controlled.
..r On September 29, 1976, the inspector selected the Refueling Water
!3 Storage Tank as an area to examine in detail to determine if the l /
licensee's corrective action had been accomplished.
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The inspector found the entrance to the area unlocked and un-7'
attended. The inspector observed that the area around the tank 3l was posted as a high radiation area.
The health physics supervisor
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p The inspector and the health physics supervisor did not observe e;
any individuals working in the RWST area during this time.
While
.g3 observing the locking mechanism on the door located at the en-7, trance to the RWST area, the inspector noted that the door could not be locked in such a manner as to prevent unauthorized entry
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into the RWST area.
The inspector noted that the finding consti-j tuted noncompliance with 10 CFR 20.203(c)2.
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At approximately 4:30 p.m.
the inspector and a health physics
~4 supervisor went to the RWST area and found the door unlocked and i
unattended.
The inspector expressed his concern with the health
physics supervisor and stated that the Plant Manager would be t
notified as to the status of the RWST area.
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At approximately 5:00 p.m. the inspector, reviewed the matter 4@
with Plant Manager.
The Plant Manager stated that the area
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would be locked or controlled.
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On September 30, 1976 the inspector verified that the RWST area
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was locked and that positive control was being maintained.
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lll On October 12, the inspector returned to the site to again inspect the control of high radiation areas.
The inspection consisted of
.i examining the high radiation areas of Unit 1, 2 and 3 to determine
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that they were locked or positive control was being maintained over each individual entry.
The inspector found no unlocked or
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uncontrolled areas during the inspection.
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During the inspection a licensee representative stated that on n
approximately October 15, 1976 a key control program would be implemented for the control of high radiation areas for Units 1,
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Furthermore, the licensee implemented a program which consists of checks of high radiation area doors to verify that they are locked. The checks are performed by a Nuclear Plant Operator
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two times a shif t and once every two siifts 'by~ the watch ' chemistry techni-
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The inspector was told that these checks are being con-g ducted three shifts per day, seven days a week.
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In addition, licensee representative stated that five vendors had t
been contacted with regard to supplying new gates for the entrances
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The licensee representative further stated
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chat the gates should be installed by the end of the year.
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g On October 19, 1976 the inspector again returned to the site to j
examine high radiatiott area control.
The inspector examined high j#
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radiation areas in Unit.: 1, 2 and 3 and found that 11 areas were locked or controlled.
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M Key control has also been implemented for Units 1, 2 and 3 at
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I this time as a means of controlling access to high radiation
areas. Many of the locks on high radiation area doors have been jh changed and previously issued keys have been returned with the ex-y ception of a few held by individuals on vacation.
A licensee ti representative stated that as the employees return from vacation g
their keys will be collected.
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The inspector reviewed Station Administrative Order (SAO) No. 111,
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Revision 0, "High Radiation Area Access Control," dated October 18, 1976.
The inspector stated that compliance with the SAO would be examined at subsequent inspections and that control of access to
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high radiation areas will continue to be inspected to permit con-1, fidence that licensee's corrective action remains satisfactory.
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6.
Smoking in the Controlled Area
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On September 28, 1976, during an inspection of the Unit 3 Primary
Auxiliary Building, the inspector observed an individual smoking h
in the controlled area on the 73' elevation.
The inspector asked i
,
the licensee representative accompanying him if individuals were i
permitted to smoke in the controlled area.
The licensee repre-
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sentative stated that smoking was not permitted in the controlled
area except for areas that have been approved for smoking.
The licensee representative further stated that the individual was
smoking in an area that had not been approved.
The licensee k
representative took immediate action to correct this matter.
l]1 During the exit interview it was stated to the inspector that
,
further management action had.been taken with regard to the in-
,j dividual involved.
In addition, a memo had been issued to all plant personnel reinstructing them in the fact that smoking was y
not permitted in the controlled areas.
The inspector had no fuVther questions concerning this matter.
,j 7.
Radiation Protection Procedures M
.
i The inspector reviewed the licensee's corrective action in regard i
to individuals adhering to the requirements of radiation protec-
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l-tion procedures.
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f Station Administrative Order (SAO)'No. 105, Revision 3, " Work E
Permits," dated March 1, 1975, was revised on August 24, 1976.
ej It will be reviewed at a future inspection.
C Operations and healt.h physics personnel authorized to issue
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l Radiation Work Permits, Radiation Exposure Authorizations and Work Permits were specifically reinstructed in the requirements 4.-
y of SAO 105.
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The subject of adhering to the requirements of Radiation Work
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y Permits and the importance of communications with health physir.s 2;.
and operations was emphasized in meetings held with plant per-i sonnel.
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The Plant Engineer held meetings with maintenance personnel and
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discussed the following:
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Details in regard to the thimble withdrawal incident.
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Importance of adhering to the requirements of Radiation
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Work Permits (RWP) and Radiation Expesure Authorizations
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Interfaces with RWP's and REA's.
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Adherence to instructions and posted in signs.
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The Plant Engineer's "Open Door" policy with regard to y
safety items.
O In addition, the Plant Engineer' issued a memo on April 14, 1976, titled " Radiation Safety" and discussed it with the maintenance y
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personnel.
The memo emphasized the fact that radiation safety
- .i was everyone's responsibility.
The inspector reviewed the licensee's corrective action in regard
to adhering to the requirements of procedures in the following i
cases:
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l 1 Revised Controlled Area Sign-In Procedure, effective Novem-f ber 11, 1975.
General Administrative Directive RS-GAD-2, Revision 1, " Radio-logical Health and Safety Procedures," dated February 24, 1975.
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It was stated to the inspector that plant personnel had been g
reinstructed to adhere to the requirements of the above proce-g-
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dures and as part of the Annual Retraining Program these pro-
'l cedures would be reviewed.
The licensee representative stated J
that the training program is expected to begin during the first
part of November 1976 and that tha outline for the retraining
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had not been prepared.
The inspector stated that the outline
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would be reviewed when it is completed and that several of the
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retraining sessions would be reviewed at subsequent inspections.
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Whole Body Exposures
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The licensee's corrective action in regaid to the whole body t'
exposure of 10.06 rem to a nuclear plant operator on April 15, s.j_
1976, consisted of:
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Completing a detailed design review by September 1, 1976.
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Conducting an evaluation of personnel monitoring devices
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become available.
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The design review was performed as part of the effort to prevent
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unnecessary or inadvertent exposure of plant personnel due to unexpected high radiation fields.
The review was conducted to
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identify areas of potential hazard.
Such locations included areas containing certain waste processing and chemical control equipment (e.g., Demineralizers and Ion Exchangers) and waste f<
The review also dealt with the disposition of i
storage areas.
materials and equipment which had been activated by neutron flux
irradiation during normal reactor operation.
Such equipment
[i included reactor internals, Rod Control Cluster assemblies,
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speciman samples, incore instrumentation and fuel assemblies.
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Other areas of the plant, which were reviewed, appeared not to
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have the potential for the unanticipated creation of a sudden (
significant increase in radiation levels.
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'N In a memo dated September 29, 1976 and titled, " Design Review j
of Indian Point Unit No. 2 Nuclear System," the licensee docu-mented this review.
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the des'ign review which
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The inspector examined the results u
,k appeared to be adequate and had no further questions.
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h The inspector discussed the licensee's progress in evaluating
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personnel radiation exposure devices that had been ordered for d
evaluation.
A licensee representative stated that several de-
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vices were being evaluated but noted that sufficient test data i
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had not yet been accumulated.
The inspector stated that the results of the evaluations would be reviewed at a subsequent
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inspection.
lQ ITosting of Radiation Areas /High Radiation Areas
..The inspector reviewed the results of the internal audits con-
" ilucted during the period April 13, 1976 through September 29,
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1976 in regard to posting of areas.
The audit results revealed that the licensee's corrective action in regard to posting radia-tion areas and high radiation areas has been intensified as described in detail 4.
The inspector selected several areas at random and examined the status of the posting during site tours
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and observed that the areas appeared to be posted as required by 10 CFR 20.
The inspector stated that the licensee's corrective action appeared to be satisfactory and had no further questions.
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