IR 05000003/1977001
| ML20050A724 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/29/1977 |
| From: | Knapp P, Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A717 | List: |
| References | |
| 50-003-77-01, 50-247-77-02, 50-247-77-2, 50-286-77-03, 50-286-77-3, 50-3-77-1, NUDOCS 8204020158 | |
| Download: ML20050A724 (17) | |
Text
00-2%g IZtI Form 12
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(Jcc 75) (Rcv)
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U. S. NUCLEAR REGULATORY CC1C3ISSION OFFICE OF INSPECTION AND ENFORCDfENT
REGION I
50-03 50-03/77-01 50-247 50-247/77-02 IE Inspection Report No:
50-286/77-03 Docket No: 50-286 DPR-5
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Licensee:
Consolidated Edison Comeanv of New Ynric. Tnc.
License No:
DPR-26 DPR-64 4 Irving Place Priority:
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. Category:
C Safeguards
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(Indian Point Units 1, 2, and 3)
Group:
Location:
Buchanan, New York PWR, 615 MWt (B&W), PWR, 2758 Mit (W),
Type of Licensee:
PWR, 3025 MWt (W)
Type of Inspection:
Special, Unannounced February 2-4 and 16-18,1977 Dates of Inspection:
December 28, 1976 Dates of Previous Inspection:
Reporting Inspector:
[ Inko
_7[A9 /'1/7
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WATE
'O.R.Neely,MadiationSpecialist Accompanying Inspectors:
None DATE DATE i
DATE Other Accompanying Personnel:
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l Reviewed By:
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DATE P. 8. Knapp, Chief, Radiation Support Section,
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Fuel Facility and Materials Safety Branch 8204020150 770331 PDR ADOCK 05000003 PDR G
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SUMMARY OF FINDINGS Enforcement Action
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A.
Violations 13-None.
B.
Infractions
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None.
C.
Deficiencies
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77-02-01 and 77-03-01 - Training and Qualification Records.
Contrary to Unit 2 and Unit 3 Technical Specifications 6.10.2, g, training and qualification records were not maintained for all of the staff health physics technicians who received initial training in 1972 and retraining in 1975 and 1976.
(Details,4)
Licensee Action on Previously Identified Enforcement Action Not inspected.
Design Changes Not inspected.
Licensee Events Not inspected.
Other Significein Findings A.
Current Findings 1.
Acceptable Areas No inadequacies were identified during inspection of the follow-ing areas:
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Temporary procedure " Transfer of Liquid Radioactive Waste a.
from Unit No. 3 to Unit No. 1."
b.
Posting of high radiation areas and radiation areas.
2.
Unresolved Items The following items will require additional information from
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the licensee in order to evaluate compliance with requirements:
77-02-02 and 77-03-02 - Development and documentation of a health physics retraining program by September 1,1977.
(De-tails,5)
3.
Items Requiring Further Review
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a.
77-02-03 and 77-03-03 - Audits of performance, training and qualifications performed by the Nuclear Facilities Safety Committee.
(Details,7)
i b.
77-01-01, 77-02-04, and 77-03-04 - Upgrading program:
training of a11 health physics technicians.
(Details,6.d)
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c.
77-01-02, 77-02-05, and 77-03-05 - Upgrading program:
general training for all employees.
(Details, 6 e)
d.
77-01-03, 77-02-06, and 77-03-06 - Revision of Station Administrative Order No.105 and Health Physics Procedure No. 5.
( Detail s, 6.1)
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e.
77-01-04, 77-02-07, and 77-03-07 - Revision of Station Administrative Order No. 111.
(Detail s, 6.g)
f.
77-01-05, 77-02-08, and 77-03-08 - Revision of Station Administrative Order No.120.
(Details, 6.1)
77-01-06, 77-02-09, and 77-03-09 - Installation of self-closing gates.
(Details,6.f)
h.
77-01-07, 77-02-10, and 77-03-10 - Revise and improve proc edures.
(Details,6.c)
1.
77-01-08, 77-02-11, and 77-03-11 - Review qualifications of health physics supervisors and technicians.
(Details, 6.b)
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77-01-09, 77-02-12, and 77-03-12 - Evaluation of Contin-uous Air Monitors.
(Details, 6.j)
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77-01-10, 77-02-13, and 77-03-13 - Positive control of contractor exposures.
(Detail s, 6.m)
1.
77-01-11, 77-02-14, and 77-03-14 - Evaluation of Dosimetry.
(Details, 6.o)
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77-01-12, 77-02-15, and 77-03-15 - Unauthorized Use of Film Badges.
(Details, 6.p)
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4.
Deviations None.
B.
Otatus of Previously Identified Unresolved Items Not inspected.
Management Interviews Management interviews were conducted at Buchanan, New York (site) on February 4 and February 18, 1 977.
A.
Persons Present The following licensee personnel were in attendance on February 4, 1 977:
Mr. W. E. Caldwell, Senior Vice President, Power Supply Mr. E. F. Kessig, Acting Manager, Nuclear Power Generation Department Mr. E. McGrath, Manager, Nuclear Power Generation Department (Designee)
Mr. J. P. Bayne, Power Authority State of New York, Manager, IP-3 Mr. S. F. Wisla, Director, Radiation Safety Mr. M. F. Shatkouski, Nuclear Training Director Mr. J. J. Kelly, Director, Chemistry Mr. N. Hartman, QS&R Consultant The following licensee personnel were in atten' dance on February 18, 1977:
Mr. E. McGrath, Manager, Nuclear Power Generation Department (Designee)
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Mr. J. Makepeace, Director, Technical Engineering Mr. B. Maroney, Chief Operations Engineer
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Mr. R. Hays'en, Manager, QA&M&R Mr. S. Wisla, Director, Chemistry and Radiation Safety Mr. J. Bayne, Power Authority State of New York, Manager, IP-3 Mr. E. Tagliamonte, Operations Engineer, Unit 3
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Mr. L. Kawula, Test and Performance Engineer Mr. W. Carson, Test Engineer B.
Items Discussed 1.
Purpose of the Inspection The inspector stated that the purpose of the inspection was to verify that the licensee had implemented the " Consolidated Edison Company of New York, Inc., Indian Point Station Upgrad-ing Program for Radiation Protection," according to the schedule shown in the plan and to review the progress the licensee has In addf-made in improving their Radiation Protection Program.
tion, the inspector stated that the purpose of the inspection was to perform a routine inspection of the Unit 3 health physics program.
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2.
Acceptable Areas The items discussed are as identified under "Other Significant Findings" section of this report.
3.
Items of Noncompliance The items discussed are as identified under the " Enforcement Action" section of this report.
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DETAILS l
1.
Persons Contacted Mr. E. Kessig, Acting Manager, Nuclear Power Generatica Department Mr. E. McGrath, Manager, Nuclear Power Generation Department (Designee)
Mr. J. Makepeace, Director, Technical Engineering
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Mr. R. Hayman, Manager QA M&R Mr. M. Shatkouski, Nuclear Training Director Mr. J. Cullen, Director Health Physics
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Mr. G. Liebler, Radiological Engineer Mr. G. Imbimbo, Health Physics Supervisor Mr. J. Perrotta, Health Physics Supervisor Mr. P. Gaudio, Health Physics Supervisor
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Mr. J. Odendahl, Senior Electrical Technician, Radiation Safety Mr. H. McKay, Watch Supervisor, Unit 3 Mr. R. Orzo, Watch Supervisor, Unit 2 Mr. T. Yentz, Health Physics Instructor, NUS Corporation Mr. R. Long, Maintenance Engineer Mr. E. Murri, Staff Health Physicist, NUS Corporation Mr. S. Lavie, Assistant Health Physicist, NUS Corporation Mr. R. Easlick, Health Physics Supervisor, NUMANCO Mr. G. Clifton, Health Physics Technician, NUMANCO Mr. M. Shusterman, Q&SR 2.
Scope of the Inspection The scope of the inspection consisted of reviewing the progress made by the licensee in implementing the upgrading program to improve the Radiation Protection Program.
During the inspection, the inspector observ edsretraining being conducted for health physics technicians and general employees, reviewed procedures, interviewed plant per-sonnel, and toured the controlled areas of Units 1, 2, and 3.
3.
Plant Records
Not applicable.
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Training and Qualification Records Unit 2 and 3 Technical Specifications 6.10.2, g, require that records of training and qualification for current members of the plant staff be maintained for the duration of the Facility Operating License.
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Contrary to the above, training and qualification records were not maintained for all of the health physics technicians who received initial training in 1972 and retraining in 1975 and 1976.
A licensee representative stated to the inspector that 9 health physics technicians received initial training in 1972 but that heHe could only locate training records for four of the technicians.
further stated that the health physics technicians received some retraining during 1975 and 1976 and that some of this training had
~5L been documented. The inspector reviewed the retraining records and noted that the records were in insufficient detail to permit one to ascertain the extent of the retraining and that the records did not show that all of the health physics technicians then employed had received any retraining.
The inspector noted that the licensee's failure to maintain train-ing records constituted noncompliance with Unit 2 and 3 Technical Specifications 6.10.2, g.
(77-02-01 and 77-03-01)
5.
Health Physics Technician Retraining / Replacement Training Technical Specification 6.4.1 requires, in part, a retraining and replacement training program for the facility staff which meets or exceeds the requirements end recommendations of Section 5.5 of ANSI 18.1-1971.
Both the Technical Specifications and ANSI 18.1-
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1971 apply to health physics technicians (i.e., radiation protection specialists.) At the time of the inspection, the inspector deter-mined that a formally documented retraining program did not exist for health physics technicians and the licensee's retraining efforts had been limited, informal, and insufficiently documented.
However, the licensee's replacement training, was conducted under the guidance of procedure RS-AD-11-1, " Training 'of Technicians," which was developed to assure that health physics technicians are trained in their assigned duties before initial assignment.
This lack.of a formally documented and implemented retraining pro-gram for health physics technicians had been identtfied by the licensee during the implementation of his upgrading plan for the radiation protection program.
The licensee stated that the admin-
istrative controls for the retraining program'will be developed by September 1,1977, and will be incorporated into the station train-ing manual.
The program will be administered by the Nuclear Training (
Director and will be conducted in annual cycles with the first cycle l
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to be completed by March 31, 1978. The subject matter to be covered in an annual cycle will be determined each year and will include, but will not be limited to, preplanned lectures to snpha-f size areas of, weakness indicated by examination and quiz results.
The program content will be supplemented by additional areas of instruction such as; changes in station administrative controls and detailed plant procedures affecting the conduct of the radia-tion protection program, changes in 10 CFR 20, instructions in g3 the operation of new monitoring and measuring equipment, and radiation protection related technical specifications and license i
c hanges. A licensee representative stated that his approach to the retraining program would be similar to the approach required for licensed operators by 10 CFR 55, Appendix A.
The licensee plans to include provisions for replacement training in the formal retraining program discussed above to be developed by September 1, 1977.
The subject matter of the replacement training program will meet or exceed the present provisions of RS-AD-11-1 and the program will supercede RS-AD-11-1.
The licensee stated that training of health physics technicians in operation and layout of plant systems would not commence until the end of calendar year 1977.
The inspector stated that if techni-cians are allowed to issue Radiation Work Permits (RWP) and deter-mine monitoring and resurvey needs, systems training is necessary to assure that the technicians have adequate knowledge of the operation and physical routing of systems designed to handle radio-active material to enable the technicians to make intelligent decisions on monitoring and resurvey needs and on required pro-cedures and equipment to assure radiation safety.
The licensee stated that the Watch Supervisors (senior licensed operators) who have detailed knowledge of plant systems will continue to concur in the issuance of RWP's until health physics technicians have been satisfactorily trained in plant systems.
This is an Unresolved Item pending the licensee's development and documentation of a health physics technician training program by September 1,1977, and the inspector's review of the program con-tent.
(77-02-02 and 77-03-02)
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Upgrading Program for Radiation Protection f
In response to a letter dated November 18, 1976, from J. P. O' Reilly, Director, Region I Office of Inspection and Enforcement, to W. J.
Cahill, Jr., Vice President, Consolidated Edison Company of New
.SE York, Inc., the licensee developed a document entitled " Consolidated Edison Company of New York, Inc., Indian Point Station Upgrading Program for Radiation Protection."
This document was reviewed by NRC representatives on December 20, 1976, and was discussed with the licensee during a management meeting conducted on December 21, 1976.
During the meeting licensee representatives stated that they intended to implement the program according to the schedule shown in the plan.
Details of this meeting are documented in Reports 50-03/77-16, 50-247/76-36, and 50-286/76-36.
During the course of this inspection, the inspector reviewed the areas covered by the upgrading program to determine if the licensee was implementing the program according to the schedule shown in the plan. As part of this review the inspector examined progress the licensee has made in improving the Radiation Protection Program.
Details showing the licensee's progress in the areas covered by the upgrading program are listed below:
a.
Plant Facilities The licensee has issued a purchase order for a prefabricated office for the health physics supervisors.
Delivery is expected the week of February 7,1977.
The existing counting room has been modified to become part of the controlled area but until such time as the supervisor's office is completed the current counting room will still be used as part of the uncontrolled area.
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Organization The licensee has reorganized the Radiation Safety Sub-Section as shown below:
PLANT MANAGER p
Director Chemistry & Radiation
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Safety
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Senior Engineer (2)
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General Chemistry Health Physics Supervisor Supervisor i
Supervisor Supervisor Supervisor Supervisor Chemistry Records Unit 1 Unit 2 Unit 3 Technicians and (11)
Rad Waste Records Health Physics Clerk Technicians
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(2)
(15)
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There are presently two health physics supervisors, instead of the four specified in the organization.
The licensee is presently interviewing candidates for the two health physics supervisor vacancies.
Until the two additional health physics supervisors are hired and trained, the licensee is utilizing the services of a health physics supervisor who was transferred to the training section. There are presently nine health physics
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,EE technicians, instead of the fifteen specified in the organiza-tion. The licensee is presently interviewing candidates to fill the six remaining vacancies. The licensee has supplemented the Radiation Safety staff with six contractor supplied health physics technicians until such time as the vacancies'are filled The in-and the new technicians have had adequate training.
spector reviewed the resumes of all of the contractor supplied health physics technicians, interviewed several of them, and determined that these individuals were qualified to perform the duties of health' physics technicians.
The inspector reviewed the qualifications of the current members of the plant staff which appeared to meet the requirements of ANSI 18.1-1971.
However, it will be necessary for the inspector to question personnel regarding their assigned duties to further determine if they-are qualified.
This item requires further review and will be completed at a subsequent inspection.
(77-01-08, 77-02-11, and 77-03-11)
c.
Review and Improvenent of Procedures A consultant has been employed by the licensee and is presently on site reviewing all of the Radiation Safety procedure ~s, inter-viewing plant personnel, observing the work done by health physics technicians in the controlled area, and inspecting the plant facilities.
A representative of.the consulting firm stated to the inspector that their review of the procedures and initial formulation of recommendations to improve the Radiation Safety Program is expected to be completed February 20, 1977.
He further stated that it would take approximately
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three weeks to complete the review at their home office and to
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prepare the formal report for the licensee. This would make the report available to the licensee approximately March 13, 1977.
A licensee representative stated that upon receiving
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the formal report from their consultant it would take approx-imately four weeks for them to perform the necessary reviews
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to determine what procedures have to be changed and what additional procedures are needed.
The inspector stated that this item will be reviewed at a subsequent inspection.
(77-01-07, 77-02-10, and 77-03-10)
d.
Basic Health Physics Technician Training The licensee began retraining the health physics technicians in basic health physics on February 16, 1977.
During the course of inspection, the inspector observed the training being conducted to verify that the material covered was the same as that outlined in the upgrading program plan.
The inspector noted that the training appeared to be adequate and asked a licensee representative how the technician's partici-pation would be evaluated.
A licensee representative stated that the technicians would be given exams at the completion of their training and if any significant questions were missed or if an individual failed the exam, the individual would be retrained in those specific areas.
The licensee representa-tive stated that_the current retraining program would be completed by March 11, 1977.
The inspector stated that the retraining being given to the health physics technicians appeared to be adequate and infor-mative.
The inspector further stated that the results of the exams and the records of the retraining would be reviewed at a sub-sequent inspection.
(77-01-01, 77-02-04, and 77-03-04)
Basic Radiation Protection General Training for Employees e.
The general training of all employees commenced on December
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29, 1976, and was determined by the inspector to be adequate and that the subject matter presented during the training session was in accord with the outline in the upgrading pro-gram plan. A licensee representative stated the training pro-
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gram for all of the plant employees was expected to be completed l
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by March 10, 1977.
He further stated that employees from Consolidated Edison's Van Ness office would receive training on March 14,15, and 16,1977, in preparation for the upcoming outage. The licensee representative stated that exams are given to all employees required to participate in the training and that the results of exams are being evaluated.
The inspector stated records of this training and examination
results would be reviewed at a subsequent inspection.
(77-01-02, 77-02-05, and 77-03-05)
f.
Installation of Self-closing Gates During the course of the inspection of the Unit 3 controlled area, the inspector observed that the licensee had installed self-closing gates at the entrances to all of the high radia-tion areas and also at the entrances to other areas which did not require locking because of the absence of high radiation l evel s.
The inspector noted that the gates had been installed in such a manner that unauthorized individuals were not able l
to enter these areas without a key. A licensee representative stated that all of the self-closing gates required for Unit 3 l
were installed and that similar gates were now being installed in Unit 2.
He further stated that due to contractor delays and the licensee's insistance that the gates be installed properly, the scheduled date for completion as shown 'in the
upgrading plan had not been met.
The licensee representative stated that they expected to have all of the gates installed by February 20, 1977.
The inspector stated that he would review the installation i
of the self-closing gates at a subsequent inspection.
(77-01-06, 77-02-09, and 77-03-09)
Revision of Station Administrative Order No.111 g.
The licensee has revised Station Administrative Order No.111,
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"High Radiation Area Access Control," which will be implemented
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when all of the self-closing gates are installed.
The inspector discussed the contents of the procedure with a licensee repre-i sentative and noted that the procedure had not received final review and approval by the Manager, Nuclear Power Generation
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Department.
The licensee representative stated that as a result of discussions with the inspector concerning the pro-cedures some minor changes would be made to the procedure before it is approved and implemented.
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The inspector stated that the procedure would be reviewed at a subsequent inspection.
(77-01-04, 77-02-07, and 77-03-i 07)
h.
Instrumentation Needs The inspector reviewed the instrumentation needs the licensee has determined necessary to further improve their Radiation 7.,
Protection Program.
The licensee representative stated that the list of instruments needed was submitted to the Acting Manager, Nuclear Power Generation for review and that purchase orders have been approved for some of the equipment.-
The inspector noted that the licensee's instrument needs appeared to be adequate and had no further questions at this time.
1.
Revision to Station Administrative Order No.120 A draft revision of Station Administrative Order (SAO) No.
120 has been prepared by the licensee and is being reviewed for final approval.
The inspector noted that SA0120 would be reviewed at a subse-quent inspection. ~ (77-01-05, 77-02-08, and 77-03-08)
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Evaluate Use of Continuous Air Monitors (CAM)
A licensee representative stated to the inspector that the evaluation of the use of CAM's is approximately 50" complete.
The inspector stated that this item will be reviewed at a sub-
sequent inspection.
(77-01-09, 77-02-12, and 77-03-12)
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Positive Control at the Vapor Containment (VC)
The licensee has implemented specific written instructions for individuals assigned to control access to VC.
A licensee representative stated that these instructions will be incor-porated into existing contaimnent and egress procedures.
During the course of the inspection, Unit 2 was shut down for a " mini" outage and a control point had been established out-side the Unit 2 VC.
The inspector went to the control point and verified that the written instructions did exist, were being adhered to, and that positive control was maintained.
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The inspector noted that the licensee's method of maintaining positive control for each individual entry into the Unit 2 VC appeared to be adequate and had no further questions at this time.
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Revision of Station Administrative Order No.105 Licensee representatives stated that Station Administrative Order (SAO) No.105, " Work Permits" would be approved and n.
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implemented by the scheduled April 15, 1977, outage and that all Radiation Work Permits and Radiation Exposure Authorizations outstanding under the existing SAO will be collected and ter-minated and that only RWP's issued under the provisions of the revised SAO 105 will be valid and in use.
The inspector stated that this item will require further review and will be inspected at a subsequent inspection.
(77- 01- 03,
77-02-06, and 77-03-06)
m.
Positive Control of Contractor Exposures The licensee developed a procedure for the control of contractor exposures and implemented the procedure but has found the pro-cedure not to be as effective as he wants it to be.
The licen-see is revising the procedure to further strengthen control over contractor personnel.
The inspector stated that the revised procedure would be reviewed at a subsequent inspection.
(77-01-10, 77-02-13, and 77-03-13)
Evaluation of Plant Air for Determination of MPC n.
The licensee has received the analysis of an actual plant air sample taken during recent steam generator work.
This analysis showed that alpha activity and isotopes such as Sr 9 and Sr90
were not present.
A licensee representative stated that they will periodically sample the plant air when primary systems are opened for repair or inspection and that they will submit the samples for similar analysis.
The inspector had no further questions regarding this item.
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Evaluation of Dosimetry The licensee's evaluation is in progress.
This item will require further review by the inspector at a subsequent inspection.
(77-01-11, 77-02-14, and 77-03-14)
p.
Unauthorized Use of Film Badges
Modifications to the security rocia are in progress.
The inspector will review this item at a subsequent inspection.
(77-01-12, 77-02-15, and 77-03-15)
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Multiple Use of Protective Clothing The licensee has discontinued the3 reuse of protective clothing.
This item is closed.
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Spread of Contamination During the course of inspection of the Unit 2 and 3 controlled area, the inspector observed that contaminated areas were properly barricaded and posted and that the housekeeping was good.
The inspector noted that additional survey instruments were located at the entrance to the Unit 2 Vapor Containment and personnel were instructed to survey more thoroughly.
Definition of Parameters for Survey Evaluations and Establish-s.
ment of Clearly Defined Areas for Surveys An indepth analysis by a consultant is in progress.
The recom-mendations from this analysis will be documented in the same report that is discusse.d in detail 6.c.
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Corporate Inspection Program for Posting of High Radiation Areas and Radiation Areas This inspection was in progress.
The inspector has no questions about the program at this time.
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Audits of Performance, Training, and Qualifications Performed by 7.
the Nuclear Facilities Safety Committee (NFSC)
During the course of the inspection, the inspector reviewed an audit report dated December 14, 1976, that the NFSC had written to docu-ment their findings of an audit of the Indian Point Station Facility conducted during October, November, and December,1976.
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The purpose of the audit was to determine the adequacy of station conformance to requirements in the area of Training and Performance of Indian Point personnel.
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The report revealed several areas needing corrective action by the licensee.
At the time of the inspection the licensee could not provide the inspector with a copy of records of corrective action.
The inspector stated that this item will be reviewed at a subsequent inspection.
(77 02-03 and 77-03-03)
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