IR 05000003/1977004
| ML20041G554 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/21/1977 |
| From: | Clemons P, Knapp P, Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041G550 | List: |
| References | |
| 50-003-77-04, 50-247-77-11, 50-247-77-12, 50-286-77-12, 50-3-77-4, NUDOCS 8203220516 | |
| Download: ML20041G554 (13) | |
Text
l' '. NUCLEAR REGULATORY COMMISSI
-
0F. ACE OF INSPECTION AND ENFORCEMENT Nonce 77-04 Region I j ja 2 9 Bli J
77-11 MW not ogTAINED PROPRINAW
-
Report No.
77-12 M*cg ECORDisNCE WITH ;0 CFR 2 50-03 Docket No.
50-247 D
su-"
C Licens.e No, b6 Priority Category c
--
DPR-64 Licensee:
Consolidated Edison Comoany of New York, Inc.
4 Irvino Place New York, New York 10003 Facility Name:
Indian Point 1, 2, and 3 Inspection at:
Buchanan, New York Ins nducted: Apr 21-24, April 27-29, and May 2-4, 197.7 Ins V _,
eA M
b '1I - 7 7
'-
ia.
U. R. Nee
, Radiation '5peci ist date signed Arub. L s-am c
F. Clemons,]diation Specia 1st date signed IcfMk_
6-2P77 F.w. Ana p p, LiiT xadia on bupport date signed Sctip,FFSMS
'M O
b~
@
Approved by:
&
P. A Knapp, Cnief, Rad \\ation Support date signed Section, FF&MS Branch Inspection Summary:
Inspection on Aoril 21-24, April 27-29, and May 2-4, 1977 (Recort Nos. 50-03/
77-04, 50-247/77-11, 50-286/77-12)
Areas Inspected:
Special, unannounced inspection of the radiation program during the scheduled Unit 2 steam generator inspection; licensee action on previous inspection findings; review of the progress the licensee has made in improving their radiation protection program for Units 1, 2, and 3.
(During general tours of work sites, radiation protection and control measures were examined.) The inspection involved 110 inspector hours onsite by three NRC insoectors.
Results:
Of the three areas inspected, no apparent items of noncompliance were identified in two areas; three apparent items of noncompliance (Infraction - failure to perform necessary radiation surveys - Paragraph 4; Infraction - failure to perform necessary air surveys - Paragraph 4; Infraction - failure to adhere to radiation protection procedures - Paragraph 4) were identified in one area.
Region I Form 12 (Rev. April 77)
8203220516 770629
-
PDR ADOCK 05000003 r-q)
.
._
_-_ _
.
s
.
.
DETAILS 1.
Persons Contacted Principal Licensee Emoloyees
- 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. J. Makepeace, Director, Technical Engineering
- Mr. B. Maroney, Chief Operations Engineer Mr. J. Cullen, Director, Health Physics Mr. G. Liebler, Radiological Engineer Mr. G. Imbimbo, Health Physics Supervisor Mr. J. Perrotta, Health Physics Supervisor Mr. P. Gaudio, Health Physics Supervisor
- Mr. T. Law, Plant Manager, Nuclear Power Generation Department
- Mr. B. Byster, QA Engineer Mr. S. Cantone, Power Authority State of New York, fianager IP-3 Mr. T. Walsh, Supervisor, Instrument and Controls Mr. J. Samrai, Supervisor, Instrument and Controls The inspector also interviewed 15 other licensee employees during the course of the inspection.
They included health physics technicians, instrument and control technicians, reactor and auxiliary operators, and members of the security force.
_
- denotes those present at the exit interview.
l Other Personnel
Mr. L. Reynolds, Manager, Nuclear Plant Services Mr. M. Hensch, Field Supervisor, NUMANC0 l
Mr. E. Couch, Supervisor, Nuclear Plant Services Mr. C. Powers, Supervisor, Nuclear Plant Services The inspector also interviewed 13 contractor health physics technicians during the course of the inspection.
l l
.
-
.
.
2.
Licensee Action on Previous Insoection Findings (Closed) Noncompliance (247/76-08-02):
Incore thimble withdrawal procedure 2/3 EM-RV12.4 did not contain appropriate cautionary notes.
The inspector found that the procedure now contains the necessary cautionary notes as required by Unit 2 Technical Specifi-cation 6.8.1 and ANSI N18.7-1972 referenced therein.
(Closed) Noncompliance (003/76-12-01):
Egress from high radiation a reas.
The inspector reviewed the licensee's corrective action in regard to this item and found the corrective action to be satis-factory.
The licensee's corrective action consisted of removing the KIRK interlock system from the Purification Outlet Filter Roon door so as to prevent a situation where an individual could be prevented from leaving a high radiation area.
(Closed) Noncompliance (003-76-05, Paragraph 9; 247/76-08-03; 247/76-14-01; 247/76-23-01; 247/76-25-01):
Control of high radia-
.
tion areas.
The licensee's corrective action in regard to this item consisted of the following:
a.
The existing high radiation area gates in Units 2 and 3 were replaced with self-closing type gates.
,
b.
Station Administrative Order (SAO) No.111, "High Radiation Area Access Control," dated March 21, 1977, was revised and initiated upon installation of all of the self-closing gates.
The procedure covers:
(1) the issuance and control of all keys to high radiation areas; (2) the surveillance by Nuclear Plant Operators once per shift and Chemical Technicians once
per day to assure that the doors to high radiation areas are locked; and, (3) that the control of keys will be audited on a monthly basis by the Chief Operating Engineer, Weekly audits of high radiation area doors are also performed c.
by a member of the radiation protection staff,
"
d.
The licensee instituted the policy of establishing a control point at the entrance to the Vapor Containment.
The control point serves as a means of controlling unauthorized access to a high radiation area.
>
.
me-*
.
A-m
I S
-
,
.
The inspector verified that the audits for the control of high radiation areas were being done and in addition, verified that the monthly audit of the high radiation area keys was being performed as required by SAO-lll.
While touring the controlled areas of Units 1, 2, and 3, the inspector found that no high radiation area doors were unlocked.
,
(Closed) Noncompliance (247/76-14-04):
Control of personnel whole body exposures by restricting access to controlled area in accord with Station Administrative Order (SAO) No.120, Revision 3.
The inspector found that the procedure has been revised and plant per-sonnel have been reinstructed to adhere to the provisions of the procedure.
3.
Upgrading Program for Radiation Protection In response to a letter dated November 18, 1976, from James P.
O'Reilly, Director, Region I Office of Inspection and Enforcement, to W. J. Cahill, Jr., Vice President, Consolidated Edison Company of New York, Inc., the licensee developed a document entitled
" Consolidated Edison Company of New York, Inc., Indian Point Station Upgrading Program for Radiation Protection." This docu-ment was reviewed by NRC representatives on December 20, 1976, and was discussed with the licensee during a management meeting con-ducted on December 21, 1976.
During the meeting licensee repre-sentatives stated that they intended to implement the program according to the schedule shown in the plan.
Details of this meetirg 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 in the following Table:
.
e o
go
-___.___
._
.
_ _ _ _ _ _ _ _ _
___
_ - _ _ _ _
TABLE Progress Made in Improving the Radiation Protection Program
'
Area of Radiation Protection Program Requiring Improvement *
Status 1.
Training of all health physics technicians.
(Reference Completed Inspection Report Nos. 77-01-01, 77-02-04, and 77-03-04)
,
2.
General training for all employees.
(Reference Inspection Completed
,
Report Nos. 77-01-02, 77-02-05, and 77-03-05)
'
3.
Revision of Station Administrative Order No.135 and Completed llealth Physics Procedure No. 5 (Reference Inspection
.
Report Nos. 77-01-03, 77-02-06, and 77-03-06)
4.
Revision of Station Administrative Order No.111.
(Ref-Completed erence Inspection Report Nos. 77-01-04, 77-02-07, and 77-03-07).
m 5.
Revision of Station Administrative Order No.120.
(Reference Completed Inspection Report Nos. 77-01-05, 77-02-08, and 77-03-08).
'
6.
Installation of self-closing gates.
(Reference Inspection Completed Report Nos. 77-01-06, 77-02-09, and 77-03-09)
7.
Revise and improve procedures (Reference Inspection Report Nos.
In progress. A con-
'
77-01-07, 77-02-10, and 77-03-10)
tract has been awarded to a consultant to develop ~130 health physics procedures.
By
-
November 1, 1977, all procedures deemed neces-sary for full operation of a radiation protec-tion program will be implemented.
- Inspection Report No. 77-01 concerns Indian Point 1, Docket No. 50-03, 77-02 concerns Indian Point 2 Docket No. 50-247, and 77-03 concerns Indian Point 3, Docket No. 50-286.
.
O
__
_
- _ _ _ _.
_ _ -.
TABLE (continued)
.
Progress Made in Improving the Radiation Protection Program Area of Radiation Protection Program Requiring Improvement *
Status 8.
Evaluation of continuous air monitors.
(Reference Inspection Evaluation is under Report Nos. 77-01-09, 77-02-12, and 77-03-12)
re'i?w.
,
9.
Positive control.of contractor exposure (Reference Inspection Procedure cor.plete'd (ReportNos. 77-01-10, 77-02-13, and 77-03-13)
10.
Unauthorized use of film badges.
Completed.
,
~.
.
to
- Inspection Report No. 77-01 concerns Indian Point 1. Docket No. 50-03; 77-02 concerns Indian Point 2, Docket No. 50-247, and 77-03 concerns Indian Point 3. Docket No. 50-286.
-
}
-
.
l o'
e O
.
,
.
,
4.
Plant Tour The inspector toured various areas of Units '1, 2, and 3 controlled areas to observe operations and activities in progress, to inspect the general state of cleanliness and adherence to 10 CFR 20 regula-tions and radiation protection procedures.
The inspector found two items of noncompliance in the areas of surveys.
10 CFR 20.201(b) requires that each licensee make or cause to be mads such surveys as may be necessary to comply with the regulatory requirements specified in 10 CFR Part 20.
One of the requirements is 10 CFR 20.203(c)(1) which states that each high radiation area must be conspicuously posted with the radiation symbol and the words, " Caution, High Radiation Area," and another requirement,10 CFR 20.203(c)(2)(iii) requires that each entrance or access point to a high radiation area be maintained locked except during periods when access to the area is required, with positive control over each individual entry.
On April 21, 1977, surveys adequate to assure compliance with the above requirements were not made when unidentified radiation levels-as high as 150 mrem /hr. were found by the inspector to exist outside the fenced area of the Unit 1 Evaporator Bottoms Drumming Station.
The measurements made by the inspector were verified by a cognizant licensee representative.
The licensee representative took corrective action by having the waste drums removed from the area so as to reduce the level of radiation outside the fenced area.
Prior to i
completion of the inspection, the licensee had placed lead shielding along the fenced area.and installed a gamma alarm on the fence.
The inspector noted that failure to survey as necessary to assare
.
compliance with the posting requirements of 10 CFR 20.203(c)(c) and
' '
to the control requirements of 10 CFR 20.203(c)(2)(iii) constituted noncompliance with 10 CFR 20.201(b).
One other requirement,10 CFR 20.103(a)(3) " Exposure of individuals
to concentrations of radioactive materials in air in restricted areas," requires that the licensee use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
!
O e
.
'
.
.
Surveys adequate to assure compliance with the above were not made
.
on April 21, 1977, in the Unit 2 Refueling Cavity where a worker was performing decontamination of the floor surface.
The inspector observed that the air sampler installed to collect air samples during the decontamination operation was locatad at least 10 feet above the Refueling Cavity floor and approximataly 20 feet to one side of the worker.
Contamination survey records maintained by the licensee showed that loose surface contamication levels of 72,000 to 8,000,000 disintegrations per minute /100 square centimeters were present on surfaces in the Reactor Cavity.
The inspector noted that the worker was wearing a full facepiece mask with supplied air.
Surveys adequate to assure compliance with 10 CFR 20.103(a)(3) were not made on April 27, 1977, when an individual was observed handling contaminated protective clothing in the Unit 1, 2, and 3 laundry /
change room.
The inspector observed the individual cemoving the contaminated protective clothing from one 55 gallon :ontainer with a wooden pole, passing the clothing in front of his face and tossing the clothing into another 55 gallon container.
The inspector noticed that the location of the air sampler in the laundry / change room was at a distance of at least five feet from the individual and the sample inlet was facing in the opposite direction.
The inspector noted that the air sample being taken was not representative of the air breather by the individual.
The inspector measured radiation levels as high as 2 mrem /hr. on the protective clothing.
It was stated to the inspector that personnel were not required to wear respiratory protection during handling of contaminated protective clothing.
It was further stated to the inspector by a licensee representative that the used protective clothing is not routinely monitored for contamination.
Surveys adequate to assure compliance with 10 CFR 20.103(a)(3) were not made on April 28, 1977, in the Unit 1 Drumming Station where workers were preparing waste drums for shipment.
The inspector noticed that the air sampler used to monitor this operation was located on the other side of a high concrete wall adjacent to the area where the workers were working and that it was not located in i
such a manner that the air sample collected would be representative of the air breathed by the workers.
The loose contamination levels on the floor surface in the room ranged from 8,000 to 15,000 dis-integrations per minute /100 square centimeters as recorded by the licensee on April 28, 1977.
I
.
_
.
e-
-
y-
-
- - - -
.
O 9'
The inspector stated that failure to perform adequate air surveys constituted noncompliance with 10 CFR 20.201(b).
Unit 2 and 3 Technical Specification 6.11 and Unit 1 Technical Specification 3.2.6 require that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
A procedure entitled, " Instruction to Personnel at the VC Control Point," was developed pursuant to the above requirement.
Section
~
II.A of the procedure states, " Ascertain that the individual knows his RWP number and that a copy is retained at the VC Control Point.
An individual shall not be allowed access until a copy is obtained."
Contrary to the above, on April 21, 1977, as many as 92 entries were permitted into the Unit 2 Vapor Containment (VC) by individuals who reported that they were working under a Radiation Work Permit (RWP) that had expired according to the VC control point copy.
The inspector noted that the copy of the RWP at the VC Control Point had expired on April 20, 1977.
A licensee representative investi-gated the matter and found that the original copy of the RWP which was maintained at the health physics office had been reauthorized on April 21, 1977, and that the information did not get transferred to the control point copy.
The inspector stated failure of the individual of the control point to assure that a valid RWP was in effect at the control point prior to permitting entry constituted an item of noncompliance with Unit 2 Technical Specification 6.11.
Health Physics Procedure No.13, " Calibration of Health Physics Monitoring Instruments," dated June 27, 1975, requires that each instrument be calibrated at least evcry 100 days.
The precedure specifies that the direct reading dosimeters are instruments.
Contrary to this requirement, the inspector found two direct reading dosimeters in a sample from the container from which ir.dividuals obtain dosimeters upon entry of the controlled area in the security room which had not been calibrated at the required frequency.
The dosimeters are listed below; No. 105920 (200 mR range) no record of calibration.
--
No. 23584 (500 mR range )last calibrated June,1976.
--
.
m e
.
.
\\
.
The inspector noted that a sample of 17 dosimeters had been se-lected from the box of dosimeters in the security room.
A procedure entitled, " Steam Generator Primary Channel Head Work,"
was developed pursuant to Unit 2 Technical Specification 6.11.
Section 4.10 of the procedere specifies that continuous air monitors are to be used for immediate evacuation purposes.
Step 1 in Appendix A of the procedure s7ecifies that if the Continuous Air Monitor on the job shows an approximate 15,000 counts per minute rise, immediate evacuation on the channel head area is required.
Contrary to this requirement, cn April 24, 1977, the inspector found that a Continuous Air Monitor (CAM) was not used to monitor a Steam Generator Channel head er.try moments before he examined the CAM in that the CAM was found to be inoperable because the air flow through the filter was almost nonexistant and not sufficient to evaluate the presence of airborne radioactive material where personnel had been working.
It was later stated to the inspector that the suction inlet on the CAM had become plugged which restricted flow through the filter.
General Administrative Directive RS-GAD-2, Revision 1, " Radio-logical Health and Safety Procedures," dated February 24, 1975, developed pursuant to Unit 2 Technical Specification 6.11 and Unit 1 Technical Specification 3.2.6, requires that areas be roped off
'
'-
and contamination control instituted when removable contamination exceeds 1000 disintegrations per minute /100 square centimeters.
Contrary to Technical Specification 6.11, on April 24, 1977, rope barriers on the 96' elevation of the Unit 2 Vapor Containment, used to designate a control point for a contaminated work area in which contamination levels exceeded 1000 disintegrations per minute /100 square centimeters due to work on a reactor coolant pump, were found lying on the floor.
In addition, the step off pad at the entrance to the area was torn in such a manner that instructions
printed on it were not legible nor was it recognizable as a contam-ination control device.
,
Contrary to Unit 1 Technical Specification 3.2.6, on April 27, 1977, the stepoff pad at the entrance to the Unit 1 Drumming Station, an area within which contamination levels exceeded 1000 disintegrations per minute /100 square centimeters, was torn in such a way that it was not legible nor could it be recognized as a
.
e I
..
.
.
1 contamination control device.
A licensee representative stated i
that the stepoff pad apparently became torn during the transfer of 55 gallon waste drums into the drumming area.
The inspector noted that if the stepoff pads are torn up frequently it appeared that a
,
'
more permanent type of stepoff pad should be installed at the entrance,to the Drumming Station.
Station Administrative Directive RS-GAD-2, Revision 1, dated February 24, 1975, developed pursuant to Unit 1 Technical Specifi-cation 3.2.6, requires that protective clothing be worn by all personnel entering the controlled area as protection against skin contamination.
Section 3.3.4.1 of the procedure lists the pro-tective apparel necessary to perform work in the controlled area.
Section 3.3.4.1 of the procedure specifically requires gloves for
. work in low and medium contamination areas.
Contrary to the above, on April 28, 1977, an individual was observed working in the Unit 1 Drumming Station, a contaminated area, with-out the required protective clothing (gloves).
The inspector ob-served a health physics technician steady a 55 gallon waste drum with his bare hand while surveying the drum. When asked what the contamination levels were on the outer surface of the drum, the health physics technician stated he did not know.
'
A procedure entitled, " Instructions for Security Room Guard,"
developed pursuant to Unit 1 Technical Specification 3.2.6 and Units 2 and 3 Technical Specification 6.11 specifies that the security room guard; "(1) distribute film badges as requested by plant personnel, support groups, and contractors.
Film badges shall not be given to anyone other than the individual to whom the badge is issued.
If necessary request identification, (2) assure that all personnel exiting the controlled area have signed out p roperly. "
Contrary to the above requirements, on April 28, 1977, the security room guard, responsible for issuing film badges to all personnel entering the controlled area, issued film badges to three con-tractor individuals who, he stated he did not recognize, without requiring any identification to verify that the film badges issued to the individuals were their assigned badges.
He further stated that there were so many contr. actor personnel entering the controlled area that it was impossible to know the identity of each individual.
.
.
-
p
- -
-
0, 12 '
Contrary to the above requirement, during the period April 29-May 2,1977, there were 57 instances when individuals exited from the controlled area and were not required to sign out.
Listed below are the specific number of instances for each day when individuals did not sign out.
April 29, 1977 - 30 individuals June 1,1977 - 10 individuals June 2,1977 - 17 individuals
.
5.
Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on May 3,1977.
The inspector summarized the scope and findings of the inspection.
Management representatives expressed their concern and stated that steps would be promptly taken to correct all identified items.
.
e
- M o
e
-
h e
e r-
.