IR 05000003/1977003
| ML20042B156 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/13/1977 |
| From: | Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B148 | List: |
| References | |
| 50-003-77-03, 50-247-77-09, 50-247-77-9, 50-286-77-10, 50-3-77-3, NUDOCS 8203250035 | |
| Download: ML20042B156 (24) | |
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Rig I Form 12
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(Rev Feb 77)
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U. S. NUCLEAR REGULATORY COMMISSION potic2 0FFICE OF INSPECTION AND ENFORCEMENT g,
cpanCE L" gegomet *
atutoM 1
REGION I
Unit 1 - 50-3 50-3/77-03, 50-247/77-09 Unit 2 - 50-247 IE Inspection Report No:
50-286/77-10
_ Docket No:
Unit 3 - 50-286 Unit i - OPR-5 Licensee:
Consolidated Edison Company of New York, Inc.
License No:
Unit 2 - DPR-26 Unit 3 - OPR-64-a Irvino Place Priority:
Unit 1 - 0 New York New York 10003 Category:
Unit 2 - C Unit 3 - C Safeguards Location:
Indian Point Nuclear Station (IP), Units 1, 2 and 3 Unit 1 - 615 MWt, PWR (B&W);
Type of Licensee:
Unit 2 - 2758 MWt, PWR (W): Unit 3 - 3025 MWt, PWR (W)
Type of Inspection:
Routine. Unannounced Environmental Dates of Inspection:
April 5-8,11 and 12,1977 Dates of Previous Inspection:
March 28 - Aoril 4,1977 Reporting Inspector:
8-/3*77 R. J. Bor d, Radiation Specialist DATE Accompanying Inspectors:
NONE DATE DATE DATE DATE NONE Other Accompanying Personnel:
DATE
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C/ -> y'/
Reviewed By:
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J. P. Stohr, Chief, Environmental and Special Projects DATE Section, Fuel Facility and Materials Safety Branch 8203250035 770527 PDR ADOCK 05000003
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SUMMARY OF FINDINGS Enforcement Action (Environmental Monitorina)
Violations None Identified.
Infractions 1.
(77-03-01, 77-09-01, 77-10-01) - Failure to have properly approved procedures.
Contrary to Section 5.4.8 of the Environmental Technical Speciff-cation Requirements (ETSR) for Units 1 and 2 and Section 5.4.2 of the ETSR for Unit 3, the. detailed written procedures required for carrying out the activities of the ETSR, including the radiological environmental sampling, analyses and related quality control activi-ties, were not reviewed by the Environmental Protection Committee (EPC), as required.
(Detail 3.c)
2.
(77-03-02, 77-09-02, 77-10-02) - Failure to follow required pro-cedures.
Contrary to Section 5.4.A of the ETSR for Units 1 and 2 and Section 5.4.1 of the ETSR for Unit 3, procedures, including NEM-C-10, Rev.
0, Precipitation and Fallout Collection, Preparation and Counting; NEM-C-04, Rev. O, Collection, Preparation and Counting of Soil Samples; and NEM-A-08, Rev. 2, Environmental Quality Control Pro-gram were not followed or implemented. (Details 4, 5.c and 5.e)
3.
(77-03-03, 77-09-03) - Failure to review changes in procedures prior to implementation.
Contrary to Section 5.4.B of the ETSR for Units 1 and 2, changes in procedures required to implement Sections 4.1.2 and 4.2 of the Environmental Surveillance Programs of the ETSR for Units 1 and 2 were not reviewed and approved by the EPC prior to implementation.
(Details 3.c, 7)
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Deficiencies 1.
(77-10-03) - Failure to review annual environmental operating report.
Contrary to Section 5.1.2.7.j of the ETSR for Unit 3, the EPC did not review the results of the radiological environmental monitoring program in the Annual Environmental Operating Report, Part B for 1976.
(Detail 3.d)
2.
(77-03-04, 77-09-04, 77-10-04) - Failure to report radiological environmental monitoring results in accord with the requirements.
Contrary to Section 5.6.1.1.B of the ETSR, for Units 1 and 2 and to Section 5.6.1.1.B of the ETSR for Unit 3, the results of the radiological monitoring programs were not reported in accord with the format and with the required information/ evaluations for 1975 (Units 1 and 2)
and for 1976 (Units 1 and 2 and Unit 3).
(Detail 3.d)
3.
(77<10-05) - Failure to notify NRC of changes made in Section 5.0 of the ETSR.
Contrary to Section 5.1.1.5 of the ETSR of Unit 3, the NRC was not notified within 30 days of changes in the organization and responsibilities described in Section 5.0 of the ETSR for Unit 3, which were made in January,1977. (Detail 3.a)
4.
(77-10-06) - Failure to document by letter the results of the milch animal census.
Contrary to Section 4.2.1.3 of the ETSR for Unit 3, the results of the field survey and enumeration of the milk animal census conducted during 1976 were not documented by a letter to the plant files and with a copy to the NRC, Office of Nuclear Reactor Regulation.
(Detail 5.b)
Licensee Action on Previously Identified Enforcement Items (Environmental Monitoring)
The inspector reviewed the licensee's corrective actions as submitted in letters dated May 13, June 11, and December 9,1976 and January 10, 1977
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to the NRC:I office, in response to the items of noncompliance identified i
in NRC:I letter of April 20, 1976 and to Item E (Unit 2) and Item C
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(Unit 3) of the NRC:I letter dated November 16, 1976, and in Inspection 50-3/76-04, 50-247/76-06, 50-286/76-08 and in 50-247/76-26 and 50-286/76-28.
The inspector had no further questions with respect to the above items with the exception of Ita.m A of the NRC:I letter dated April 20, 1976.
This item appears to be recurrent in nature.
(See Enforce-ment Action, Infractions, Item 1,(77-03-01,77-09-01,77-10-01)).
(Details 3.c, 6.b and 7)
Design Changes fMae Identified.
Unusuci Occurrences Anomalous Measurements The inspector reviewed the circumstances and the licensee's evalu-ation of the I-131 concentrations in a sample of aquatic vegetation reported in a letter dated November 17, 1976 to the NRC.
(Detail 5.f)
Fish Imoingement The inspector also reviewed the circumstances and licensee's actions relative to the unusual impingement event during October,1976 and reported to the NRC:I in a letter dated November 15, 1976.
(Detail 7.a)
The inspector had no further questions with regard to these items at this time.
Other Significant Items (Environmental Monitoring)
A.
Current Findings 1.
Unresolved Items a.
77-03-05, 77-09-05, 77-10-07 - Gamma spectral analysis of water samples.
Due to apparent discrepancies revealed in the licensee's gamma spectral analyses of EPA spiked water samples, the results of the 1976-1977 gamma spectral analyses of the environmental water samples are considered unresolved pending resolution of these discrepancies.
(Details 4, 5.c and 5.d)
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b.
77-03-06, 77-09-06, 77-10-08 - Inlet and discharge water sampling.
The adequacy of continuous sample collection methods at the inlet and discharge sampling locations, as used at the time of inspection, are considered unresolved pending the installation of the new sampling unit at the dis-charge and modification of the inlet sampling unit.
(Detail 5 and 6.b)
c.
77-10-09 - Analytical sensitivities for Sr-89, Sr-90 and I-131 in environmental samples.
The adequacy of the analytical sensitivities for Sr-89, Sr-90 and I-131 for environmental samples involving radiochemical separations, is unresolved pending the availability of, and subsequent NRC review of, the necessary analytical data to verify that the minimum required sensitivities for these analyses have been achieved.
(Details 5.b, 5.d and 5.f)
2.
Deviations None Identified.
B.
Status of Previously Reported Unresolved Items 1.
The gamma spectral analyses of air particulate filters since December,1975 for Units 1 and 2 - Inspection 50-3/76-04 and 50-247/76-06, Detail 4.a.
This item is now resolved.
(Detail 5.a)
2.
Water quality analyses for nitrates, bicarbonate, ammonia and carbon (organic and inorganic) listed in Table 4.1-2 for Units 1, 2 and 3 - Inspection 50-3/76-04, 50-247/76-06 and 50-286/
76-08, Detail 9.b.
This item is now resolved.
(Detail 7.b)
3.
Oil spill prevention from transformer and fuel storage areas for Units 1, 2 and 3 - Inspection 50-3/76-04, 50-247/76-06 and 50-286/76-08, Detail 14.
This item is now resolved.
(Detail 8.a)
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Sensitivity of analyses for I-131 in drinking water to meet minimum sensitivity requirements for Unit 3 - Inspection 50-286/76-08, Detail 4.e.
This item is still unresolved and is now combined with other similar items in current Unresolved Item 77-10-09.
(Details 5.b, 5.d and 5.f)
5.
77-03-07, 77-09-07, Compliance with Appendix B, ETSR Section 2.1.3, Maximum Heat Rejection Rate (BTU /hr), for Units 1 and 2 - Inspection 50-3/76-04 and 50-247/76-06, Detail 7 and Inspection 50-3/74-14 and 50-247/74-14.
This item is still unresolved pending the clarification of the Units 1 and 2 ETSR in this area.
(Detail 6.a)
6.
77-03-08, 77-09-08 - Compliance with Appendix B, ETSR Section 5.6.E.2.a. Reporting Requirements for I-131 Concentrations in Air for Units 1 and 2 - Inspection 50-3/76-04 and 50-247/76-06, Detail 4.b and Inspection 50-3/74-14 and 50-247/74-14.
This item is still unresolved pending the clarification of the ETSR for Units 1 and 2 in this area.
(Detail 5.a)
Management Interviews On April 8,1977, following the inspection at the Indian Point site, the inspector met with the following individuals at the Indian Point Nuclear Generating Station, Buchanan, New York:
E. McGrath, Assistant Manager, NPGD, Con Ed T. Law, Plant Manager, con Ed J. Makepeace, Director, Technical Engineering, Con Ed J. Kelly, Radiation and Environmental Services Superintendent, PASNY P. Crinigan, Nuclear Environmental Monitoring Supervisor, con Ed A. Ferraro, Engineer, Con Ed D. SheparJ, Project Biologist, Con Ed On April 12, 1977, at the conclusion of the inspection, the inspector met with the following Con Ed individuals at the corporate offices of Consolidated Edison Company of New York, Incorporated, at 4 Irving Place, New York, New York:
R. VanWyck, Senior H.P. and Corporate Radiation Safety Officer J. Szeligowski, Emissions Licensing Engineer and Secretary of the Environmental Protection Committee (EPC)
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On April 14, 1977, a telephonic discussion was held between Messrs. E.
Kessig, Assistant Vice President - Operations; E. McGrath; and T. Law of Con Ed and Messrs. Stohr, Streeter and Bores of this office.
On April 18, 1977, a telephonic discussion was held between Mr. E.
McGrath of Con Ed, and Mr. Streeter of this office.
During these meetings / telephone discussions, the following items were discussed:
A.
General The inspector discussed the scope of the inspection and stated that it included the operational environmental monitoring programs for all three units, as well as, the provisions for monitoring the chemical and thermal discharges from the site.
B.
Items of Noncompliance The inspector discussed each of tre items of noncompliance listed under Enforcement Action in the S'UMMARY OF FINDINGS.
In response to these items and in the subsequent telephone discussions, the licensee m:de the following commitments:
1.
Effective immediately, a.
All changes to ETSR required procedures will be reviewed by the EPC prior to implementation.
b.
There will be additional management involvement in the radiological environmental laboratory activities, in-cluding quality control and data review.
c.
There will be improvement in the company-wide coordina-tion in carrying out the ETSR.
d.
The EPC will perform timely reviews of items of non-compliance, routine reports and unusual environmental events.
2.
Beginning May 1, 1977, all environmental radiological sample analyses will be performed by Teledyne Isotopes.
Prior-to re-suming in-house analyses of these samples, Con Ed will have reestablished the quality of these analyses and have the necessary approved procedures, personnel and proficiency for performing the required analyse X
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3.
By May 15, 1977, a.
The EPC and the NFSC, as appropriate, will have reviewed and approved the radioanalytical procedures to be em-played in the radiological environmental analyses by Teledyne Isotopes.
b.
The EPC and the NFSC, as appropriate, will have completed the review and approval of the radiological sampling pro-cedures employed by Con Ed and the Con Ed procedures. to ensure the quality of the radicanalytical results.
c.
Controlled copies of reviewed, approved procedures will be issued to the appropriate work locations.
4.
By May 31, 1977, the NFSC audit of the radiological environ-mental monitoring program will have been completed.
5.
By June 30, 1977, all procedures required by the ETSR will be verified to have a current review in accordance with the ETSR.
In addition, the documentation of the reviews will include a master procedures list which will indicate for each procedure, the current review status and any revisions.
C.
Previously Identified Items of Noncomoliance The inspector stated that he reviewed the licensee's corrective actions taken with respect to items of noncompliance identified in previous inspections of these areas in Inspection 50-3/76-04, 50-247/76-06, 50-286/76-08 and in 50-247/76-26 and 50-286/76-28 (fish impingement). The inspector stated that with the exception of the item relative to the review and approval of procedures, the in-spector had no further questions in these matters.
The referenced item appears to be a recurrent item of noncompliance.
(See Infrac-tions, Item 1 (77-03-01, 77-03-01, 77-10-01))
D.
Unresolved Items The inspector discussed with the licensee each of the Unresolved Items listed under that heading in the SUMMARY OF FINDINGS.
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1.
Analytical Sensitivities for Sr-89, Sr-90, and I-131 in Environmental Samples The inspector stated that without the analytical data necessary to compute the reported analytical results, the inspector could not verify compliance with the minimum sensitivity requirements for Sr-89, Sr-90 and I-131 for those environ-mental samples requiring radiochemical separations as part of the analyses, including milk, water, aquatic organisms, etc.
The inspector also noted that the licensee was reanalyzing a number of samples for Sr-89 because the initial analytical results did not meet the minimum required analytical sensi-tivity.
The inspector stated that this area was considered unresolved for the 1976-1977 environmental samples requiring radiochemical separation, pending the availability of the necessary data in order to verify that the required minimum sensitivities have been met.
The inspector stated that the analysis of drinking water of I-131 was left unresolved in Inspection 50-286/ 76-08; is still unresolved; and is now included with this item). (77-10-09) (Details 5.b, 5.d and 5.f)
2.
Gamma Spectral Analysis of Water Samples The inspector stated that his review of the licensee's gamma spectral analyses of " spiked" water samples indicated dis-crepancies between the measured values and the reported "true" values. The inspector stated that until these apparent discrepancies are resolved, the adequacy of,the gama spectral analyses of Con Ed environmental water samples for 1976-1977 is considered unresolved. (77-03-05. 77-09-05, 77-10-07) (Details 4, 5.c and 5.d)
3.
Inlet and Discharge Water Sampling The inspector stated that the method of continuously sampling the Indian Point circulating water inlet and discharge points raised questions as to the representativeness of the samples.
The licensee stated that the discharge sampler will be re-placed before the end of the year with a completely redesigned
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sampling system and that the inlet sampler will be modified to insure representative sampling.
The inspector stated that these areas would be considered unresolved pending completion of these modifications to the samplin systems.
(77-03-06, 77-09-06, 77-10-08) (Detail 5 and 6.b The licensee stated that the necessary actions would be taken to resolve the above items.
4.
Maximum Heat Rejection Rate The inspector stated that the ambiguity in the Units 1 and 2 ETSR relative to the calculation of the maximum heat rejection (BTU /hr) for each unit remains.
The inspector stated that this area will continue to be an unresolved item t.atil the ETSR are clarified, probably when the Unit 3 ETSR are made the site ETSR.
(77-03-07, 77-09-07) (Detail 6.a)
5.
Reporting Reouirements for I-131 Concentrations in Air The inspector stated that the ambiguity in the Units 1 and 2 ETSR relative to the reporting concentrations of I-131 in air continues to exist.
The inspector stated that this item remains unresolved pending the clarification of the ETSR, probably when the Unit 3 ETSR are made the site ETSR.
(77-03-08, 77-09-08) (Detail 5.a)
E.
Previously Reported Unresolved Items The inspector discussed each of the Previously Reported Unresolved Items listed under the heading in the SUMMARY OF FINDINGS.
The in-spector stated that Items 1 thru 3 are now resolved.
Items 4 thru 6 are discussed above.
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DETAILS 1.
Individuals Contacted Consolidated Edison Company of New York (Con Ed)
E. Kessig. Assistant Vice President - Operations E. McGrath, Assistant Manager, Nuclear Power Generation Department T. Law, Plant Manager, IP B. Moroney, Chief Operations Engineer, IP R. VanWyck, Senior H.P. and Corporate Radiation Safety Officer, IP J. Makepeace, Director, Technical Engineering, IP S. Wisla, Director of Chemistry and Radiation Safety, IP J. Higgins, Chemistry Supervisor, IP P. Crinigan, Nuclear Environmental Monitoring (NEM) Supervisor, IP A. Ferraro, Engineer, IP R. Tuttle, Manager, Biological Studies, IF D. Shepard, Project Biologist, IP L. Roberts, Nuclear Plant Operator (NPO), IP C. Limoges, Reactor Engineer, IP C. Mackay, Watch Supervisor, IP R. Swern, Senior NEM Technician, IP R. Schacklinscky, NEM Technician, IP G. Muller, NEM Technician, IP H. Bremer, Chief Emissions Control Section J. Szeligowski, Secretary of EPC, Emissions Control Engineer W. Bennett, Secretary of Nuclear Facility Safety Committee (NFSC)
N. Hartman, Consultant, Quality Standards and Reliability (QS&R)
D. Romaine, Senior Engineer, Emissions Control Section L. Cohen, Senior Engineer, Emissions Control Section K. Burke, Engineer, Emissions Control Section D. Doll, Assistant Engineer, Emissions Control Section Power Authority of the State of New York (PASNY)
P. Bayne, Site Manager, IP J. Kelly, Radiation and Environmental Services Superintendent, IP 2.
General The inspection consisted of a review of the operational environ-i mental monitoring programs at the Indian Point Nuclear Generating Station (IP) site at Buchanan, New York, encompassing both the
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radiological and nonradiological aspects of these programs.
The licensee's cperational environmental monitoring requirements for Units 1 and 2 are specified in Appendix B to the Facility Operating License DPR-26. Environmental Technical Specification Requirements (ETSR) for Units 1 and 2.
The licensee's operational environmental monitoring requirements for Unit 3 are specified in Appendix B to Facility Operating License DPR-64. ETSR for Unit 3.
Areas included in this inspection were a selective examination of air sampling, precipitation collection, water sampling and gamma dosimetry stations; selective impingement and ecological studies; meteorological monitoring; chemical and thermal monitoring of dis-charges; selective sampling and analytical procedures; representa-tive program results; the activities of the Environmental Pro-tection Committee (EPC); selected current Radiation Work Permits; interviews with personnel and observations by the inspector.
In addition, the Annual Environmental Operating Report, Part A -
Nonradiological and Part B - Radiological - for January 1,1976 thru December 31, 1976, were reviewed.
3.
Management Controls a.
Organization and Resoonsibilities The inspector reviewed the organization and administrative structure of Con Ed responsible for implementing and controlling the IP environmental monitoring programs.
Several changes have been made since the last inspection of this area.
Mr. R.
Tuttle is now the Con Ed Project Manager, Biological Studies at IP.
In January,1977, the position, Manager of Nuclear Services, was eliminated.
The nuclear environmental moni-toring (NEM) program is supervised by Mr. P. Crinigan (through April 15,1977, at which time he planned to leave Con Ed).
The inspector noted that the licensee was actively recruiting an NEM Supervisor replacement, as well as, an NEN foreman.
The licensee stated that offers on the former position were expected to be made prior to the end of April,1977.
Mr. Crinigan reports directly to Mr. VanWyck, now Senior Health Physicist and Corporate Radiation Safety Officer, who reports directly to Mr. Kessig, Assistant Vice President -
Operations. The latter -hanges result in changes in organi-zation and responsibilities described in Section 5.0 of the ETSR for Unit 3.
Section 5.1.1.5 of the ETSR for Unit 3 requires that any changes in the organization and responsi-bilities be reported to the NRC, Office of Nuclear Reactor Regulation (NRR) within 30 days of this change.
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The inspector determined that this notification to NRR had not been made as of the time of inspection.
The inspector stated that this failure to provide the required notification was in noncompliance with the requirements.
(77-10-05)
The inspector noted that the licensee had prepared an ETSR change request pertaining to this area and expected to submit it to the NRC within a week.
b.
Licensee Audits The inspector reviewed the licensee's ETSR and the Charter of the EPC and determined that the licensee had provisions for audits of the environmental prograns, for recording the results of audits, for reporting program deficiencies to appropriate management, and for assuring that ?crrective and followup actions are taken.
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The inspector reviewed the results of the QS&R audit conducted in the area of nonradiological effluent records and required reports.
The inspector noted that one item was identified re-lative to the reporting of sampling and analyses times in the 1975 Annual Environmental Operating Report, Part A.
This item had been corrected and the inspector had no further questions in this area.
The inspector also reviewed the results of an audit performed of the contractor, Texas Instruments, by Con Ed Biology Depart-ment personnel.
No deficiencies were identified in this area.
The inspector determined through discussions with the licensee and by review of the records that no in-depth audit of the nuclear environmental monitoring program had been conducted since 1975. The licensee stated that such an audit was scheduled for the Fourth Quarter,1977 by the QS&R, but now has been rescheduled as the next audit ersa.
The inspector had no further questions in this area at this time, c.
Review of Procedures Section 5.4.2 of the ETSR for Unit 3 and Section 5.4.8 of the ETSR for Units 1 and 2 requires, in part, that all procedures as they pertain to the ETSR be reviewed by the EPC.
The inspector determined that the licensee had obtained, reviewed and approved the procedures listed in Item A of the NRC:I
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letter of w 1 20,1976 as stated in the licensee's letters a
of May 13 and June 11, 1976.
The inspector also determined through discussions with the licensee and by review of the minutes of the EPC meetings since mid-1975, that procedures required for the implementation of the nuclear environmental monitoring program were not reviewed by the EPC.
These procedures include those for radiological environmental sampling, sample preparation, and for assuring the quality of radicanalytical performance.
In addition, Section 5.1.2.7.d of the ETSR for Unit 3 requires that the EPC review all procedures required for the implement-ation of the ETSR for Unit 3 be reviewed semiannually.
The inspector could not determine, with a few exceptions, which of the procedures had been reviewed within the previous semi-annual interval.
This was due to the lack of specific identifying information in the EPC meeting minutes and the lack of a master procedure list, from which the status of a specific procedure could be determined.
The inspector stated that the failure to have the EPC review the required procedures as required by Section 5.4.2 of the ETSR for Unit 3 and Section 5.4.B of the ETSR for Units 1 and 2 was an item of noncompli-ance.
The inspector stated that this item was of a recurrent nature since the last inspection of this area (Inspection 50-3/76-04,50-247/76-06,50-286/76-08).
(77-03-01, 77-09-01, 77-10-01)
The licensee stated that the failure of the EPC to review the nuclear environmental monitoring (NEM) procedures was due to the assumption that the NFSC had this review and approval responsibility.
The inspector determined that while the NFSC had reviewed the NEM procedures in the past, the present NFSC Charter does not include this area.
Consequently, neither the NFSC nor the EPC have reviewed these procedures within the past year.
The inspector noted that the licensee was preparing a change to Section 5 of the ETSR to split the radiological program responsibilities from the EPC and give them to the NFSC.
The lic.ensee anticipated that this change would be submitted to the NRC within a month.
Section 5.4.B of the ETSR for Unit 1 and 2 requires, in part, that the EPC review and approve changes in procedures prior to their implementation.
The inspector determined through the
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review of the EPC meeting minutes and correspondence that the review of changes of some of the procedures were not reviewed by the EPC prior to their implementation.
Specifically, procedures utilized by Texas Instruments Inc. (TI) to conduct the biological studies as required by the ETSR of all three units were reviewed and approved as the TI 1976 Draft Pro-cedures.
Subsequently, TI furnished the 1976 Final Procedures as those actually used in 1976 and is now using TI 1977 Draft Procedures.
Inspection of the EPC minutes and records indicated that neither of the latter versions of these procedures were reviewed and approved by the EPC.
The inspector statri that this was in noncompliance with the requirements. (7711-03, 77-09-03)
The inspector noted that a controlled copy system for approved procedures was not utilized; making it d;fficult fcr the line organization to determine which are the current, approved pro-cedures.
d.
Review of Annual Environmental Operating Reports Section 5.1.2.7.j of the ETSR for Unit 3 requires that the EPC review the results of the environmental monitoring program in each Annual Environmental Operating Report.
The inspector determined through the review of the EPC meeting minutes and records and through discussions with the licensee that the results of the radiological environmental monitoring program were not reviewed by the EPC in the Annual Environmental Operating Report, Part B for 1975, nor 1976.
The inspector stated that this was in noncompliance with the requirements.
(77-10-03)
The inspector reviewed the licensee's Annual Environmental Operating Report, Part A and B for 1976.
The inspector deter-mined that Part 8 of this report was not written in accord with the requirements of Section 5.6.1.1.8 of the ETSR for Units 1 and 2, nor with Section 5.6.1.1.B of the ETSR for Unit 3.
The report did not contain the results of the radiological environmental samples summarized on an annual basis in the format of Table 5-1; include interpretations and statistical evaluations of the results during the report. period; and include comparisons with preoperational studies, operational controls and previous environmental reports.
The inspector stated that this was an item of noncompliance.
(77-03-04,77-09-04,77-10-04)
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The inspector determined that the results of Part A of t.le Annual Environmental Reports had been reviewed by the EPC, but only after the reports had been submitted to the NRC. The inspector noted that the ETSR did not specifically require this review prior to submission.
4.
Licensee Program for Quality Control of Analytical Measurements The inspector reviewed the licensee's program for assuring the quality of analytical measurements.
The inspector reviewed the licensee's records of instrument functional checks and background data.
The licensee continues to send milk samples to both Eberline Instrument Corporation and to Teledyne Isotopes for I-131, gamma spectral, Sr-89 and Sr-90 analyses.
Gamma spectral analyses of milk samples and also performed in-house.
The licensee also analyzes EPA supplied " spike" samples and compares these values with those measured by the contractor, Teledyne Isotopes.
The inspector noted that the licensee's gamma spectral analytical results for the EPA water " spike" samples often varied considerably from the EPA stated
"true" value and from the contractor's measurement.
The licensee suspects that the source of this discrepancy is the method of sample preparation used in-house, but has not yet resolved this problem.
The inspector stated that because of this observed discrepancy in the gamma analyses of water " spikes", the adequacy of the in-house gamma spectral analyses of all the required water samples since the beginning of 1976 is considered unresolved pend-ing satisfactory resolution of this discrepancy.
(77-03-05,77-09-
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05, 77-10-07) (See also Details 5.c and 5.d)
The inspector examined the Procedure NEM-A-08, Rev. 2, relative to the environmental quality control program, and determined that it
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contained criteria for accepting measurement results and followup action regarding routine sampling.
The procedure also included provisions for instrument functional checks and required that samples of media be split on a routine specified frequency for i
quality checks of both in-house and contractor performance.
The inspector determined that this portion of the procedure had not been implemented.
The inspector stated that this failure to follow procedures was in noncomoliance with Section 5.4.A of the ETSR for Units 1 and 2 and Sectie. 5.4.1 of the ETSR for Unit 3.
(See also Details 5.c and 5.e) (77-03-02, 77-09-02, 77-10-02)
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4 The inspector determined through the review of the available records and discussions with the licensee that the results of milk sample analyses (I-131, Sr-89, Sr-90 and gamma spectral analyses)
perfonned by two separate contractors and in-house (gamma analyses only) were not intercompared on a routine basis.
The inspector discussed this type of comparison in maintaining an ongoing per-spective of the quality of analyses.
5.
Imolementation of the Environmental Monitoring Program - Radiological Immediately, upon arriving at the Indian Point site, the inspector examined several selected air sampling, precipitation collection and gamma dosimetry stations.
The following day the inspector accompanied the Con Ed personnel on part of their routine sample collection route and observed the collection of intake and dis-charge water samples and the collection / exchange of several air particulate filters and charcoal cartridges.
The inspector ob-served the air sampler checks during collection and observed that each of the gas volume meters were in current calibration.
The inspector had no further questions in this area.
With regard to the intake and discharge water sampling, however, the inspector observed that the required continuous composite water samplers had a flow rate such that the two-gallon compositing container would begin to overflow within an estimated one-half to one hour of changing.
The licensee changed these containers daily for making the weekly composites.
Since the containers filled within a short time compared to the collection period, the in-spector stated that the representativeness of these samples over the collection period was questionable.
The licensee adjusted the sampler to a reduced flow during the inspection / sample collection.
The licensee stated that the discharge sampler was being replaced with a more satisfactory composite for the radiological, as well as, the required chemical analysis sampling.
The inspector re-viewed the engineering design of the proposed sampler, which the licensee stated would be installed and operable in 1977.
The inspector stated that the adequacy of the present intake and dis-charge water sampling would be considered unresolved pending completion of the proposed modifications to the sampling systems.
(See also Detail 6.b) (77-03-06, 77-09-06, 77-10-08)
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a.
Air Monitoring The inspector reviewed the results of the air particulate and airborne iodine sampling program since December,1975.
The inspector determined that the required air samples were collected and analyzed as required.
The inspector stated that the unresolved item reported in Inspection 50-3/76-04, 50-247/76-06, and 50-286/76-08, Detail 4.a. relative to the gamma spectral analyses of particulate filters, is now resolved.
The inspector's review of the air monitoring data also indi-cated that I-131 had been reported as being measured in air on a number of occasions.
The inspector noted that the reported
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levels were just above the licensee's reported lower limit of
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detection (LLD).
This data was discussed with the licensee with respect to the minimal I-131 airborne releases at Indian Point and the anticipated levels of I-131 in air from those releases.
The inspector noted that quality control data was not available for this area.
(See Detail 4 for related area).
The inspectcr also reviewed the unresolved item identified in Inspection 50-3/74-14, 50-247/74-14, 50-286/74-19 related to the reporting requirement in Section 5.6.2.2.b of the ETSR for Units 1 and 2 for I-131 concentrations in excess of 0.011
pci/m. The inspector stated that this item is still unre-solved pending clarification of the ambiguity between the required LLD and reporting level.
The inspector noted that this clarification will probably occur with the application of the ETSR for Unit 3 to the Indian Point site in the near future.
(77-03-08,77-09-08)
b.
Milk The inspector reviewed the results of the milk sampling and analyses and determined that the required analyses were per-formed.
The inspector reviewed copies of the analytical procedures utilized b Eberline Instruments)y the contractors (Teledyne Isotopes and and noted that they were not approved by the EPC.
(See Detail 3.c)
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The inspector's review of the results indicated that on occasion, the Sr-89 results did not meet the required LLD.
i The inspector noted, however, that the licensee had already requested that the contractor reanalyze these samples, but that these results were not yet available.
The inspector noted that while the strontium and iodine chemical yields were given (most of the time); the additional analytical data, such as count-rate, background rate, efficiency, etc., were not provided such that the inspector could verify that the ana-lyses of I-131, Sr-89 and Sr-90 met the required minimum LLD.
The inspector stated that this area would be considered unresolved pending the availability of this data for 1976-1977 and its subsequent review.
(See also Details 5.d and 5.f)
(77-10-09)
The inspector also reviewed the results of the milch animal
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census required by Section 4.2.1.3 of the ETSR for Unit 3 and discussed the techniques employed in making the census.
The inspector noted that the census had been p4.Jormed in accord with the requirements, but that the results and enumeration of j
the survey had not been documented in a letter to the plant
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files with a copy to NRC, Office of Nuclear Reactor Regula-tion, as required. The inspector noted that this item had been identified by the licensee, but corrective action had not been taken.
The inspector stated that this failure to document the results of the survey as required was an item of noncompliance.
(77-10-06)
c.
Precioitation The inspector reviewed the results of the precipitation moni-toring program since the beginning of 1976 and noted that the required analyses, including the gamma spectral analyses, had been performed by the licensee.
The inspector stated that due to the uncertainties noted in the gamma analyses of " spiked" water samples, the adequacy of these analyses is left unre-solved.
(See Details 4 and 5.d) (77-03-05, 77-09-05, 77-10-07)
The inspector also determined through the review of the pro-cedures, discussions with the licensee and available work sheets, that Procedure NEM-C-10, Rev. O, Precipitation and i
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Fallout Collection, Preparation and Counting, was not adhered to in accord with the requirements of Section 5.4.A of the ETSR for Units 1 and 2 and Section 5.4.1 for Unit 3.
The inspector stated that this was an item of noncompliance.
(See also Details 4 and 5.e) (77-03-02, 77-09-02, 77-10-02)
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d.
Other Water The inspector reviewed the results of the other required environmental water analyses (Hudson River, drinking water, lake water and well water) since January,1976, and determined that the required sampling and analyses were performed.
The inspector stated that the unavailability of the necessary analytical data for these water samples made it impossible to verify compliance with the required LLD for Sr-90 and that for I-131.in' drinking water.
The inspector stated that this item is considered unresolved pending the availability of this data.
(See also Details 5.b and 5.f) (77-10-09)
The inspector also stated that due to the discrepancies in the gamma spectral analyses of water samples, the gamma analyses of Hudson River water, drinking water, lake water and well water since January 1976, are considered unresoived pending the satisfactory resolution of the above discrepancies.
(See also Details 4 and 5.c) (77-03-05, 77-09-05, 77-10-07)
e.
Soil The inspector reviewed the results of the soil sampling and analyses performed since January,1976.
The inspector deter-mined that the analytical requirements of the Units 1 and 2 ETSR had been met. (Sampling of soil for the Unit 3 ETSR has not yet been required, nor performed.)
The inspector determined through the review of the work sheets and Procedure NEM-C-04, Rev. O, Collection, Preparation and Counting of Soil Samples, and through discussions with per-sonnel that the above procedure was not followed in the pre-paration and analyses of soil samples.
The inspector stated that this was in noncompliance with Section 5.4.A of the ETSR for Units 1 and 2. (See also Details 4 and 5.c) (77-03-02, 77-09-02)
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Other Media The inspector reviewed results of the sampling and analyses of other media from the available records and the annual reports.
Media roviewed included:
sediment, clams / crabs, fish, vege-tation and also included the review of the direct gama measurements.
The inspector noted that the fish and crabs /
clams are required to be analyzed for Sr-90 at least once per year. The inspector stated that because of the unavailability of the necessary analytical data for these media, the verifi-cation of the required minimum LLDs for Sr-90 could not be made.
This is considered unresolved pending the availability and review of this data since January,19/6.
(See also Details 5.b and 5.d) (77-10-09)
The inspector reviewed the circumstances surrounding ani the licensee's evaluation of the measured I-131 concentrations in aquatic vegetation, as reported by a letter dated November 17, 1976 to the NRC:I Office.
The inspector also reviewed the licensee's records of I-131 releases in the liquid effluent prior to the sampling date; the licensee's followup action; and the potential dose implications.
The inspector stated that he had no further questions in this.itter at this time.
6.
Nonradioactive Effluent Release Rates and Limits a.
Thermal Releases The inspector reviewed selected records of thermal discharges since January,1976 for Indian Point Station and observed no instances of noncompliance with the requirements.
The inspec-tor also reviewed the unresolved item reported in Inspection 50-3/74-14, 50-247/74-14 and 50-286/74-19 relative to the maximum heat rejection rate from each Unit, as specified in Section 2.1.3 of the ETSR for Units 1 and 2.
The inspector stated that this item was still unresolved pending the clarifi-cation of the requirements as specified in Sections 2.1.3 and 3.1.3 of that ETSR.
(77-03-07,77-09-07)
The inspector also reviewed the records / logs of water height differences between the discharge canal and the river level.
The inspector noted that these levels were recorded at least once during each shift.
The inspector observed that the
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water-level marker posts were covered with debris at the time of inspection, but noted that the licensee utilized an auto-matic level sensing / recording / alarming system to assure that the required discharge water velocity / levels were maintained.
The inspector noted that the automatic level recorder system was inoperable at the time of inspection, but that the total station power output was less than 50%, such that the level measurements were not required by the ETSR.
The inspector noted that the licensee took immediate action to have the instrument repaired and was prepared to use an alternate method to measure the water levels. The inspector had no further questions in this area at this time.
b.
Chemical Releases The inspector reviewed the records of chemical releases at Indian Point Station since January,1976, and discussed the analytical methods, procedures and results with the licensee.
The parameters reviewed included pH, lithium hydroxide, specific conductance, suspended solids, dissolved oxygen and chlorine.
The inspector determined that chlorine had not been-used in the circulating water system at IP since September 18, 1975. The inspector noted no instances of noncompliance with the requirements.
The inspector also reviewed the licensee's corrective actions as stated in a letter dated May 13, 1976, to the NRC relative to the item of noncompliance identified in the NRC:I letter of April 20, 1976, regarding the monitoring of the pH of dis-charges.
The inspector stated that he had no further ques-tions regarding this item.
The inspector also reviewed the engineering design and dis-cussed with the licensee the modification / installation of the discharge canal sampling station.
The inspector had no further questions regarding the chemical sampling and analyses of the IP discharges, since the current ETSR requires only grab sampling in the discharge canal.
(See also Detail 5)
7.
Ecological Surveillance Programs The inspector reviewed with the licensee the ongoing ecological studies / special studies being conducted at the Indian Point site.
The licensee stated that beginning in 1977, Lawler, Matusky and
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Skelley Engineers (LMS) was subcontracted by New York University (NYU) to perform the ichthyoplankton analyses for the entrainment program.
NYU, under the supervision of Dr. J. M. O'Connor con-tinues to perform the macro-and micro-zooplankton viability studies.
Texas Instruments continues to perform the impingement ano fisheries studies at IP.
The inspector reviewed selected biological / ecological procedures and discussed them with the licensee.
The inspector determined through discussions with the line organization responsible for implementing the ETSR in this area that the line organization was not aware of which procedures had received the required EPC seni-annual review, since a controlled copy system was not utilized.
The inspector noted that the Texas Instruments 1976 Draft Pro-cedures had been reviewed, but that the 1976 Final Procedures were submitted.as the procedures used during 1976, and Texas Instruments was now employing the 1977 Draft Procedures. The inspector deter-mined that neither of the latter two drafts had been reviewed by the EPC.
The inspector stated that this was in noncompliance with Section 5.4.8 of the ETSR for Unit 1 and 2, which requires EPC review of procedures prior to their implementation.
(See also Detail 3.c) (77-03-03, 77-09-03)
a.
Impingement Monitoring The inspector reviewed with licensee personnel the impingement monitoring program since January,1976 and also reviewed the circumstances and corrective actions relative to the fish impingement event which occurred in October, 1976 and was reported to the NRC in a letter dated November 15, 1976. The inspector had no further questions in this matter at this time.
The inspector also reviewed the licensee's corrective actions
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as stated by the licensee in letters dated May 13 and December 9,1976, and January 10, 1977, to the NRC in response to items of noncompliance identified in the NRC:I letter of April 20, 1976 and November 16, 1976, relative to fish impingement.
The inspector determined that the actions were taken as stated.
With regard to the proposed change to the ETSR to be taken to clarify the requirements in this area, the licensee stated that this change was being prepared in final for signature for submittal to the NRC.
The inspector stated that he had no further questions in this area at this tim.
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b.
Water Quality Parameters The inspector also discussed with the licensee the unresolved item reported in Inspection 50-3/76-04, 50-247/76-06 and 50-
286/76-08, relative to the measurement of certain water quality parameters listed in Table 4.1-2 of the ETSR of all three units.
The inspector stated that since this table was not specifically tied into a specification, the monitoring of those parameters was not enforceable.
The inspector stated
that in discussions with NRR, NRR had indicated that Table 4.1-2 would be included in a specification when the ETSR are applied to the total site.
The inspector stated that this
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item was now considered resolved.
8.
Other Areas a.
Oil Spill Prevention The inspector toured the site areas, reviewed the construction design and drawings, reviewed the oil spill prevention plans, and discussed these areas with the licensee.
The inspector stated that the unresolved item related to the oil spill pre-vention from transformer and fuel storage areas, as reported in Inspection 50-3/76-04, 50-247/76-06 and 50-286/76-08 were now considered resolved.
b.
Meteorolocy The inspector examined the meteorological instrumentation in use and as required by the ETSR.
The inspector noted that all of the instruments appeared to be functioning properly at the time of inspection.
The inspector also determined that the required instrument checks and calibrations are performed in accord with detailed, approved procedures.
The inspector had no further questions in this area.
9.
Radiation Work Permits
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The inspector examined the current administrative procedures
governing Radiation Work Permits and discussed them with the licensee.
The inspector also reviewed the current outstanding Radiation Work Pennits on April 6 and April 7 and observed that they were written in accordance with the procedure.
The inspector observed no inadequacies in this area nor during his tour of the
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