IR 05000003/1977007
| ML20042B125 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/16/1977 |
| From: | Gallina C, Knapp P, Neely D, Plumlee K, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B108 | List: |
| References | |
| 50-003-77-07, 50-247-77-19, 50-286-77-19, 50-3-77-7, NUDOCS 8203240591 | |
| Download: ML20042B125 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION I
0FFICE OF INSPECTION AND ENFORCEMENT l
Region I gg as OF,tgon %" pact ** * e co untD " "
Report No. 77-07; 77-19: 77-19 Docket No.50-003; 50-247; 50-286 pacU DPR-5 License No.DPR-26: OPR-64 Priority Category D: C: C
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Licensee:
Consolidated Edison Company of New York, Inc.
4 Irving Place
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New York, New York-10003 Facility Name:
Indian Point Units 1, 2 and 3 Inspection at:
Indian Point Station, Buchanan, New York Inspection conducted: May 9-13,16-20, 24-28, May 31-June 4, 5-10 & July 14-15,1977
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Inspectors: k ( 'Y ler A r
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D. R. Neelf, Radiation Specialist
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C. O. Gall Investi%ation Specialist 7 date signed
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UAAC nu,.1
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lee, Radiation Specialist gat'esig(edy 9- (6 - 7 7,
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L. H. Thonus,]diktion S ecialist
, date signed Approved by W 9 J en
@ - \\ C, ~77 P. h Kna'pp, Chief, Radiat g date signed Support Section Inspection Sunmary:
Inspection on May 9-13, 16-20, 24-28, May 31-June 4, 5-10, and July 14-15, 1977 (Report Nos. 50-03/77-07, 50-247/77-19, 50-286/77-17)
Areas Inspected:
Special, unannounced extended inspection of certain areas of the Unit 1, 2, and 3 radiation protection program; review of the progress the licensee
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has made in improving the radiation protection program for Units 1, 2 and 3; upon arrival, areas where work was being conducted were examined to review radiation safety control procedures and ;,ractices; review of the radiation pro-tection controls established during the recent unscheduled outage involving replace-ment of seals on a Unit 2 Reactor Coolant Pumps, training and qualifications, instruments, exposure control and notification, posting and control, surveys,
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emergency connunications equipment, and procedures were examined.
The inspec-tion involved 203 inspection hours on site by four NRC inspectors.
Resul ts:
Of the ten areas examined, no apparent items of nonconpliance were 8203240591 770817 PDR ADOCK 05000003
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i identified in six areas.
Four apparent items of noncompliance (infraction -
failure to control High Radiation Areas - paragraph 7; infraction - failure to post High Radiation Areas - paragraph 7; infraction - failure to perform surveys -
paragraph 8; infraction - failure to follow procedure - paragraph 9) were identified in four areas.
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DETAILS 1.
Persons Contacted
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Principal Licensee Employees
- Mr. E. McGrath, Manager, Nuclear Power Generation Department Mir. T. Law, Plant Manager Mir. J. P. Bayne, Power Authority State of New York, Manager, IP-3
- Mr. S. F. Wisla, Director, Radiation Safety and Chemistry 7.-
- Mr. G. Beer, Director, Quality Assurance
- Mr. J. Mdkepeace, Director, Technical Engineering
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Mr. M. Shatkouski, Nuclear Training Director Mr. J. Cullen, General Supervisor Health Physics
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Mr. G. Imbimbo, Nuclear Training Specialist Mr. T. Keith, General Watch Foreman Mr. G. Liebler, Radiological Engineer i
Mr. J. Odendahl,
Instrument and Controls Technician i
Mr. D. Sarc, General Watch Foreman
Mr. A. Bobik, General Watch Foreman i
Mr. D. Warren, Security Supervisor
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Mr. J. Perrotta, Supervisor, Health Physics
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The inspectors also interviewed other licensee employees during the course of the inspection.
They included health physics technicians, auxiliary operators, maintenance and repair personnel, and members of the security force.
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i Other Personnel
Mr. M. Hensch, Health Physics Supervisor, NUMANCO
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Mr. J. Bennett, Health Physics Supervisor, NUMANC0 DR R. Ryan, Assistant Radiation Safety Director, NUMANCO The inspectors also interviewed contractor health physics technicians during the courto of the inspection.
2.
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
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Company of New York, Inc., Indian Point Station Upgrading Program i
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
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to implement the program according to the schedule shown in the plan.
Details of this meeting are documented in Reports 50-03/76-16, 50-247/76-36, and 50-286/76-36.
Review of the progress of this program is documented in Reports 50-03/77-04, 50-247/77-11 and 50-286/77-12.
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During the course of the inshection the inspectors reviewed licensee implementation of new and revised procedures.
The licensee implemented two groups of new and revised procedures, the first group by May 15,
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1977 and the second by July 1,1977 and is currently maintaining progress in accord with a revised schedule for procedures to be implemented by November 1, 1977.
3.
Training and Qualification The inspectors reviewed training records and quali.fications of 16 con-
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tractor personnel performing Health Physics and Decontamination functions.
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All the personnel appeared to have adequate qualifica.tions and the training records for 8 individuals were complete at the Nuclear Training Center.
The records for the other 8 individuals were at the Radiation Safety Office in preparation for transfer to the Nuclear Training
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Center.
A licensee representative stated that training of these 8 individuals was proceeding and that they were performing work functions only in those areas where they had been trained.
The inspectors did not find any of the individuals performing work functions in areas which they were not trained.
No items of noncompliance were identified in this area.
4.
Instruments and Equipment l
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The inspectors performed a check of ten instruments in use in the l
controlled area including portable survey instruments, area radiation j
aonitors and friskers used to check for personnel contamination. All l
instruments were checked for operability and calibration, the friskers
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and area radiation monitors were checked for alarm settings. These instruments appeared to be in calibration and functioning properly.
The licensee is currently upgrading his instrumentation and is in the process of obtaining over 75 new instruments including continuous iodine and particulate air monitors, portable survey meters, friskers, alpha counters, personal air samplers, and scintillation detectors.
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Unit 2 and 3 Technical Specifications 6.11 and Unit 1 Techincal 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.
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Health Physics Procedure No.13, " Calibration of Health Physics Monitoring Instruments," dated June 27, 1975, requires that each
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instrument be calibrated at least every 100 days.
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On June 2,1977, an inspector performed a check of all survey
instrumentation utilized as part of the licensee's Emergency Plan.
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An examination of this equipment was performed in the Emergency Kits located in the Unit 1 and 2 Control Room, the Unit 3 Control Room and the Emergency Control Center located at the Westchester Service Center.
The check indicated that eight survey instruments were out of calibration as follows:
Location Instrument Calibrated Calibration Due Unit 2 Control Room Rad 0wl 1-27-77 5-10-77 Emergency Kit Unit 3 Control Room Rad Owl 1-27-77 5-10-77 Emergency Kit Emergency Control Center G-M Survey 2-1-77 5-10-77 Instruments (3)
Emergency Control Center CDV-175 2-1-77 5-10-77 Emergency Contrcl Center Cutie Pie 2-1-77 5-10-77 Emergency Control Center Fassport 420 2-1-77 5-10-77 Neutron Monitor Failure to calibrate the above instrumentation represents an item of noncompliance with respect to Unit 1 Technical Specification 3.2.6 and Unit 2 and 3 Technical Specification 6.11.
(50-003/77-07-02; 50-247/77-19-04; 50-286/77-19-02, another exanple of non-compliance with technical specifications is found in paragraph 9).
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but that the replacement had been overlooked.
The inspector veri-fied that properly calibrated equipment was subsequently placed in the required kits.
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5.
Exposure Control, Notification and Reports 10 CFR 20.102 requires licensees to obtain exposure histories and calculate allowable exposure on form NRC-4 before permitting exposures in excess of the limits specified in paragraph (a) of 10 CFR 20.101.
Form NRC-4's were examined for six individuals, no discrepancies were noted.
10 CFR 20.401 requires that licensees maintain records showing the radiation exposures of all individuals for whom personnel monitoring is required under 10 CFR 30.20Eron Form NRC-5 or equivalent.
Form NRC-5's were examined for six individuals, no discrepancies were noted.
10 CFR 20.409 and 10 CFR 19.13 require the licensee to
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notify individuals of their exposure within 90 days of termination of employment on work assignment.
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Licensee records for 12 individuals were examined to determine that the licensee had sent the required exposure information.
No discrep-ancies were noted.
An individual was contacted who verified he had received.a report.
The licensee is not currently utilizing protection factors for the l
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No items of noncompliance were noted in this area.
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Posting, Labeling, and Control 10 CFR 20.203(c)(2) requires that high radiation areas established for more than 30 days, be equipped with control devices to reduce the level of radiation upon entry into the area, or be equipped with control devices to energize conspicuous visible or audible alarm signals upon entry into the area, or be maintained locked except during periods when access is required, with positive control I
over each individual entry:
10 CFR 20.203(c)(4) provides that in the case of a high radiation area established for a period of 30 days or less direct surveillance to prevent unauthorized entry may l
be substituted for the control required by 10 CFR 20.203(c)(2).
On May 16,1977, an inspector performed a tour of the Primary Auxiliary Building accompanied by the General Watch Foreman and a Health Physics
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Technician.
At the 68 foot elevation the inspector noted that a
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temporary High Radiation Area had been established near piping associated with the Containment Spray pumps.
In lieu of locking the area, a
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security guard had been assigned to maintain direct surveillance over
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the entrance to the area.
The inspector observed that the guard was asleep, leaving the area open to unauthorized entry.
The security guard was awakened by Consolidated Edison personnel.
- Confirmatory surveys taken by the inspector indicated that radi-ation levels were such that a major portion of the body could be exposed to 170 to 200 mrem /hr in the area.
This finding.consti-tutes an item of noncompliance with respect to 10 CFR 20.203(c)(2)
and 10 CFR 20.203(c) (4).
(50-247/77-19-01)
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10 CFR 20.203(c)(1) requires that each High Radiation Area be con-spicuously posted with a sign or signs Bearing the radiation symbol
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and the words: Caution - High Radiation Area.
On May 16,1977, during a tour of the Unit 2 Primary Auxiliary Building an inspector examined an area between the Fuel Storage Building and the Primary Auxiliary Building.
From his position in the passageway between the Primary Auxiliary Building and the Fuel Storage Building the inspector observed a chain link fence on the far side of the area which was placarded.
A doorway adjacent to
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The door was unlocked and it contained notices that it was alarmed.
The inspector perforned a survey of the area which indicated that a High Radiation Area existed in a portion of the area adjacent to
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the Fuel Storage Building. Radiation levels were such that a majcr i
portion of the body could be exposed to in excess of 120 mR/hr.
Individuals entering the area through the aforementioned alarmed I
door would not know that they were entering a High Radiation Area in that the door was not posted.
Regarding control of the High Radiation Area the licensee stated that a Health Physics Technician in the area provided direct surveillance of the door.
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A Health Physics supervisor accompanying the inspector stated that the radiation was due to a drum of highly radioactive waste which had been stored too near the wall of the Fuel Storage Building and that it was being moved in order to reduce levels in the area.
With respect to lack of posting, the licensee stated that the area had been posted as a High Radiation Area but the placard had apparently been removed by cleanup crews who were cleaning the area of outage-related debris.
The inspector informed the licensee that failure to properly post the area constituted an item of noncompliance with respect to 10 CFR20.203(c)(1).
(50-247/77-19-03)
The licensee stated that subsequent relocation of the drum in question had lowered radiation levels below 100 mrem /hr thus removing the need for posting as a High Radiation Area.
This was confirmed by the inspector.
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Surveys I
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10 CFR 20,201(b) requires each licensee to make or cause to be made such surveys as may be necessary to comply with the regulatory requirements specified in 10 CFR Part 20.
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10 CFR 101 limits the exposure of individuals in restricted areas.
Posted dose rates from the most recent survey taken in the waste
" mixing / storage area at 0730 on May 14 indicated radiation levels of
300 mrem /hr.
On May 16 the inspector perfonned a confirmatory
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survey and found several areas where general radiation levels ranged from 500 to 600 mrem /hr.
A Health Physicist accompanying the inspector modified the posting before leaving the area.
The licensee stated that drununing operation had been perfonned on May 14 and 15,1977, and that the latest transfer operations had occurred on May 15,1977.
The inspector stated that. anyone entering the area would not know the actual radiation fields existing and could experience a substan-tial exposure due to the lack of accurate surveys.
The inspector further stated that failure to perform adequate surveys constituted an item of noncompliance with respect to 10 CFR 20.201(b).
(50-003/77-07-01; 50-247/77-14-02; 50-286/77-19-01 another example of this item of noncompliance is noted below)
10 CFR 20.105 limits levels of radiation in unrestricted area such tnat an individual, if continuously oresent, could not receive 2 millirems in a,ny one hour or 100 millirems in any seven consecutive days.
Surveys adequate to assure compliance with the above require-l ment were not taken on May 16, 1977.
While inspecting the Unit 1 fuel handling building an inspector
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noticed several large crates of solid radioactive waste stacked i
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near a plywood partition. The licensee stated that a construction area was on the other side of the partition.
The inspector and two licensee personnel exited the controlled area and surveyed the construction area on the other side of the partition.
General area
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dose rates were such that a major portion of the body could be exposed to from 3 to 7 mrem /hr. The inspector stated that failure to evaluate for the presence of dose rates in the unrestricted area constituted noncompliance with 10 CFR 20.201(b) consequently allowing radiation levels in an unrestricted area in excess of the limits of 10 CFR 20.105.
This was identified as a second example of the item of noncompliance noted earlier in this paragraph.
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The licensee notified his security force that no construction workers were to be a.llowed into the aforementioned area until radiation levels had been reduced.
Appropriate posting was per-formed imediately.
The inspector confirmed that the crates stacked in the Unit 1 Fuel Handling Building were moved away from the partition which reduced measured radiation levels in the unre-stricted area below the limits specified in 10 CFR 20.105.
Further investigation by the inspector indicated that the levels potentially existed for up to six days, but that T$e actual number of construc-
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tion workers exposed during this time could not be determined.
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This instance is recurrent in that a similar item of noncorpliance found during an inspection conducted in December 1975.
A drum of radioactive material had been placed near a boundary separating (
controlled and uncontrolled areas. The radiation field from this
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drum extended into the uncontrolled area.
Surveys were not taken at the time the drum was placed in the area to evaluate the poten-
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tial for exposure to individuals in the unrestricted area.
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Procedures
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Unit 2 and 3 Technical Specifications 6.11 and Unit 1 Technical l
Specification 3.2.6 require that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR
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20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
The Revised Control Area Sign-In Procedure, effective November 11, 1975, requires that certain types of inform tion, including name and RWP number be entered on the sign-in sheet by individuals
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entering the controlled area.
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Contrary to the above requirements on June 8,1977, an individual was found in the Laundry Lobby / Change Area, which is inside the Controlled Area who had not signed in on the sheets provided in the security room. The individual left the area before the inspector or licensee could question him.
The above represents noncompliance with regard to procedures developed pursuant to Unit 1 Technical Specification 3.2.6 and Unit 2 and 3 Technical Specifications 6.11.
(This item of noncompliance was cited earlier in paragraph 4).
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10.
Radiation Controls Established for Outage The inspectors examined the control point at the Unit 2 Vapor Con-tainnent for adequacy.
The control point appeared properly estab-lished and equipped and adequate to prevent the spread of contam-ination. The personnel manning the control point were questioned regarding entry requirements, access lists and RWP's and they were knowledgeable. Work inside the Vapor Containment was reviewed and
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personnel were observed to be following RWP's and precautions.
The inspectors also reviewed the licensee's plans for future work on
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the Main Coolant Pump during 'the outage.
The licensee had contacted other utilities who had perforned main coolant pump removal to ascertain potential problems and radiation levels encountered.
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licensee's plans include: having all personnel near the pump on air supplied hoods when the seal is broken; transporting the pump in a shielded configuration which limits dose rates to approximately 100 mrem /hr; decontaminating the pump prior to disassembly; and performing a thyroid count on personnel potentially exposed to airborne activity.
The licensee's preplannir.g appeared to be adequate.
No items of noncompliance were identified in this area.
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Exit Interview i
Two inspectors met with licensee representatives (denoted in Para-l graph 1) at the conclusion of the inspection on July 15, 1977.
The inspector summarized the scope and findings of the inspection.
Management representatives expressed their concern and stated that i
steps would be promptly taken to correct all identified items.
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Connonications
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i The inspector reviewed the licensee's plans for coping with the potential strike scheduled for July 15, 1977, insofar as these plans related to emergency communications.
The inspector checked the availability and operability of the licensee's walkie-talkie,
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radios (fixed and mobile) and emergency telephone services (off-site and on-site).
No problems were identified in these areas.
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