IR 05000003/1977014
| ML20050A671 | |
| Person / Time | |
|---|---|
| Site: | Indian Point |
| Issue date: | 10/07/1977 |
| From: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | William Cahill CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| References | |
| NUDOCS 8204020025 | |
| Download: ML20050A671 (2) | |
Text
r.
,
,
. p ** W%g UNITED STATES
'
t f,,
,*
NUCLEAR REGULATORY COMMiss!ON
- ; 1 + [ ;,,$
REGION I
% +*[g v[/ )
'
N0t! 151977 631 PARK AVENUE o, i
,'
J uinc or enussia. PENusvtV ANI A 19406
,
"**
Docket Nos. 50-03 Consolidated Edison Company of New York, Inc.
ATTN: Mr. W. J. Cahill, Jr.
Vice President 4 Irving Place New York, New York 10003 Gentlemen:
Subject:
Combined Inspection 50-03/77-14, 50-247/77-33 and 50-286/77-31 This refers to the inspection conducted by Dr. R. Bores of this office on September 27-29, 1977 and October 12, 1977, at Indian Point Nuclear Generating Units 1, 2 and 3 at. Buchanan, New York and at the corporate offices of the Consolidated Edison Company of New York, Inc., in New York City, of activities authorized by NRC License Nos. DPR-5, DPR-26 and DPR-64 and to the discussions of our findings held by Dr. Bores with Messers. Law, Hartman, Makepeace and others of your staff at the conclusion of the inspection. This also refers to the meeting held at your office on October 12, 1977 and attended by Messrs. Stohr, Streetar and Bores of our office and by you and Messrs. Kessig, Jannarone and others of your s ta ff.
,
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Our inspector also verified the steps you had taken to correct the deviation brought to your attention in a letter dated January 19, 1977.
We have no further questions with this action at this time.
In addition, our inspector verified the steps you had taken to correct the items of noncompliance brought to your attention in a letter dated May 27,1977. We have no further questions regarding the steps you took to correct items C, D and F.
With regard to items E and G, we note that
,
8 0402dOY7ildO7
'~
PDR ADOCK 05000003 G
.
/%
' Consolidated Edison Company of
New York, Inc.
corrective action has been initiated, but has not yet been completed.
These items are considered unresolved pending their completion and review at a subsequent inspection.
With regard to items A and B of the aforementioned letter, we note that these items have recurred as described in Appendix A, items A and B of this letter.
In your response to this letter, please give this matter your particular attention.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full ccmpliance with NRC requirements as set forth in the Notice of Violation, enclosed herewith as Appendix A.
These items of noncompliance have been categorized into the levels as described in our correspondence to you dated December 31, 1974.
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within twenty (20)
days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliances and (3) the date when full compliance will be achieved.
In addition to the need for corrective action regarding these specific items of noncomp_liance, we are concerned about the imple-mentation of your management control systems that permitted them to occur.
Consequently, in your reply, you should describe in particular, those actions taken or planned.to improve the effectiveness of your management control systems.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy _of this letter and the enclosures will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the infonnation, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Comission as listed in subparagraph (b)(4) of Section 2.790.
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in
-
this regard within the specified period, the report will be placed in the Public Document Room.
.
a
.
' Consolidated Edison Company of
'
e New York, Inc.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
,
Boyce H. Grier Director Enclosures:
1.
Appendix A, Notice of Violation 2.
Office of Inspection and Enforcement Combined Inspection Report Numbers 50-03/77-14; 50-247/77-33; 50-286/77-31 cc w/encls:
L. O. Brooks, Project Manager, IP Nuclear (con Ed)
E. R. McGrath, Manager, Nuclear Power Generation Department (Con Ed)
T. Law, Plant Manager (Con Ed)
J. M. Makepeace, Director, Technical Engineering (Con Ed)
L. M. Trosten, Esquire (Representing PASNY)
-
George T. Berry, General Manage ~r and Chief Engineer (PASNY)
L. R. Bennett, General Counsel-(PASNY)
Rear Admiral i J. Early, Assi5 tant Chief Engineer - Projects (PASNY)
Manager - Nuclur Operations (PASNY)
J. P. Bayne, Resident Manager (PASNY)
J. D. Block, Esquire, Executive Vice President - Administration E. J. Sack, Esquire A. Z. Roisman, Counsel for Citizens Committee for Protection of the Environment (Without Report)
.
V bec w/enclsr
,
IE Mail & Files (For Appropriate Distribution)
Central Files Public Doctsoent Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Infonnation Center (NSIC)
,
Technical Infornation Center (TIC)
REG:I Reading Room Region Directors (III, IV) (Report Only)
State of New York
A. Z. Roisman, Counsel for Citizens Comittee for
'
Protection of the Environment
1
,
..
.
_
_
__.-
.
.
APPENDIX A
.
NOTICE OF VIOLATION Consolidated Edison Company of New York, Inc.
.'
4 Irving Place New York, New York 10003 Docket Nos. 50-3, 50-247 and 50-286 Based on the results of an NRC inspection conducted on September 27-29, 1977, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your Facility License Nos. DPR-5, DPR-26 and DPR-64, as indicated below.
Items A and B are categorized as Infractions; Item C as a Deficiency.
A.
Section 5.4.B of the Environmental Technical Specification Require-ments (ETSR) for Units 1 and 2, and Section 5.4.2 of the ETSR for Unit 3 require in part, that all detailed, written procedures, as they pertain to these ETSR, be reviewed and approved by the Envir-onmental Protection Committee (EPC) and, if they affect plant oper-
,
ations, approved by the plant manager.
Contrary to these requirements, as of September 29, 1977, required procedures, including those for the analysis of air particulates, clams / crabs, fish and soil for Sr-89 and Sr-90 and for the gross beta analysis of aquatic vegetation, clams / crabs and fish were not reviewed and approved by the EPC.
B.
Section 5.4.A of the ETSR for Units 1 and 2, and Section 5.4.1 of the ETSR for Unit 3 require, in part, that the detailed written procedures required for carrying out the ETSR be followed.
Contrary to these requirements, as of September 29, 1977, Procedure NEM-AD-08, Revision 3, Quality Control Program, had not been followed nor implemented, nor had its predecessor, NEM-A-08, Revision 2
,
Environmental Quality Control Program been implemented.
i C.
Section 4.2.1.1 and Tables 4.2-1. and 4.2-3 of the ETSR for Unit 3 require, in part, that environmental media be sampled and analyzed at specified locations, frequencies and by specified analyses meet-ing specified minimum sensitivities.
Contrary to these requirements, the specified I-131 analyses for Hudson River aquatic vegetation and for lake aquatic vegetation did not meet the specified minimum sensitivity level of 0.05 pCi/g of wet vegetation.
The reported sensitivity levels since January, 1976 varied from 0.09 - 0.4 pCi/g and larger.
.
-
-
-
.-
-
-.
c
,
.
U.S. NUCLEAR REGULATORY COMP JON OFFfCE OF TNSPECT10N AND ENFORCEMENT 77-14 Region I 77-33 j NoDCE j
g Report No. 77-31 b'
amor m 50-3 cwutAnct m AcconoAnct witH 10 CfW 2hu Docket No. 50-247 50-286 D
DPR-5 C
License No.
DPR-26 Priority Category C
--
Licensee:
Consolidated Edison Company of New York, Inc.
4 Irving Place New York, New York 10003 Facility Name:
Indian Point Nuclear Generating Units 1, 2 and 3 Inspection at:
Indian Point Nuclear Generating Station, Buchanan, N.Y. and at the Corporate.0ffices of Consolidated Edison Company of New York, Inc.
Inspection conducted: September 27-29 and October 12, 1977 Inspectors:
//' 0 9' 7 7
~ '.
. Bo ~ s, Rad stion Specialist date signed R
['
2 nd&
//-o 9 -17
{'g. P. Stohr, Chi 6f, E&SP Section J
date signed bgr 2,g77only)_
j f, g9_,,
,
.
,
Approved by:
)
// ""
D. P. Stohr, Ch(ef, EaSP 5ection date signed FF&MS Branch Inspection Summary:
,
Inspection on September 27-29 and October 12, 1977 (Consolidated Report Nos.
50-3/77-14; 50-247/77-33; and 50-286/77-31)
Areas Inspected:
Special, unannounced inspection of the environmental protection program (operational phase) on September 27-29, 1977 and NRC meeting with licensee management on October 12, 1977.
The inspection was limited to the followup of pre-viously identified enforcement and unresolved items and to areas relating to these items, including management controls for these programs; implementation of environ-mental monitoring programs - radiological; and licensee's program for emergency plan training.
The inspection involved 31 onsite inspector-hours by three NRC in-spectors.
Results:
Of the three areas inspected, no items of noncompliance were identified in Three apparent items of noncompliance (Infraction - failure to have re-one area.
viewed and approved procedures - Detail 3.c; Infraction - failure to follow proced-ures - Detail 3.c; Deficiency - failure to meet analytical sensitivity requirements for I-131 in vegetation - Detail 4) were identified in two areas.
Region I Form 12 (Rev. April 77)
s%33Jh
.
~
DETAILS 1.
Individuals Contacted Consolidated Edison Comoany of New York, Inc. (Con Ed)
- W. Cahill, Jr., Vice President - Licensing
- E. Kessig, Assistant Vice President, Power Generation Operations
- J. Jannarone, Vice President-Environmental Affairs; Chairman of Environmental Protection Committee
- E. Sack, Law Department E. Kelleher, Director of Biology Department
- A. Cheifetz, Sr. Engineer, Environmental, Nuclear and Gas F. Norris, Alternate Secretary of the Environmental Protection Committee (EPC)
J. Szeligowski, Past Secretary of EPC, Emissions Control Engineer
- N. Hartman, Consultant, Quality Standards and Reliability (QS&R)
- M. Byster, Engineer, Quality Assurance and Reliability (OA&R)
- T. Law, Plant Manager, Indian Point Generating Units (IP)
- J. Makepeace, Director, Technical Engineering, IP M. Shatkouski, Training Director, IP G. Liebler, Sr. Engineet, Radiation Safety, IP
.
- L. Volpe, Supervisor, Nuclear Environmental Monitoring (NEM), IP R. Schacklinscky, NEM Technician, IP R. Tuttle, Manager, Biological Studies, IP D. Shepard, Project Biologist, IP J. Higgins, Chemistry Supervisor, IP Power Authority of the State of New York (PASNY)
- J. Blake, Director - Environmental Prograns
- S. Farber, Radiological Engineer
- J. Kilduff, Assistant to Resident Manager, IP-3 J. Kelly, Radiological and Environmental Services Superintendent, IP-3
,
Texas Instruments, Inc.
G. Roth, Documentation Group Leader, IP The inspector also interviewed several other individuals of the Con Ed and PASNY staffs.
)
'
- denotes those present at the exit interview on September 29, 1977.
- denotes those present at management meeting on October 12, 1977.
i
..
.
.
2.
Licensee Action on Previous Insoection Findings (0 pen) Noncompliance (77-03-01; 77-09-01; 77-10-01):
Failure to have properly approved procedures.
The inspector determined through the review of selected procedures, the EPC meeting minutes and discussions with the licensee, that the procedures identified during the previous inspection of this area had been reviewed and approved.
The inspector determined, however, that a group of NEM procedures had not been obtained by the licensee and, therefore, not reviewed and approved.
This item is, therefore a recurrent item of noncompliance.
(77-14-01; 77-33-01; 77-31-01)
(Detail 3.c)
(0 pen) Noncompliance (77-03-02; 77-09-02; 77-10-02):
Failure to follow procedures.
The inspector determined through discussions with the licensee, review of program results and selective review of the procedures, that the procedures for the collection, prepara-tion and counting of precipitation and fallout and for soil have been modified to reflect the changes implemented as a result the
contracting of analyses formerly performed by Con Ed to Teledyne
't Isotopes, Inc. in Westwood, New Jersey.
The inspector had no further questions in the.above areas.
With respect to ti,e Environ-mental Quality Control Program, Procedure NEM-A-08, Revision 2, the inspector determined that the above procedure was revised and approved on May 9, 1977 (NEM-AD-08, Revision 3) and required, in part, specified audits of the NEM program and that quality control samples, spikes, etc. to be analyzed routinely to assure the quality of the analytical results.
The inspector determined that as of the time of the inspection, this procedure nor its predecessor (NEM-A-08, Revision 2) had been implemented, such that this remains an uncorrected item of noncompliance.
(77-14-02; 77-33-02; 77-31-02)
(Detail 3.c)
(Closed)
Noncompliance (77-03-03; 77-09-03):
Failure to review changes in procedures prior to implementation.
The inspector determined through discussions with the licensee and contractor personnel, selective reviews of procedure changes and review of the EPC meeting minutes, that changes are now reviewed prior to imple-mentation in accord with Section 5.4.B of the ETSR for Units 1 and 2.-
The inspector had no further questions in this area at this time.
.
-,
e
-
-
-
,
,
.
(Closed) Noncompliance (77-10-03):
Failure to review annual environmental operating report.
The inspector determined through the review of the EPC meeting minutes and discussions with the licensee that the 1976 annual environmental operating reports were reviewed by the EPC, as required.
The inspector also noted that provisions were made in the charter of the EPC to encourage and accommodate early review of these reports.
The inspector had no further questions in this area at this time.
(0 pen) Noncompliance (77-03-04; 77-09-04; 77-10-04):
Failure to report radiological environmental monitoring results in accord with the requirements.
The inspector determined through discussions with the licensee that the licensee has contracted the writing of the 1977 Annual Environmental Opertting Report, Part B to a vendor.
The inspector also determined that the licensee was in the process of supplying the vendor with prior data for the required compar-isons.
The licensee also stated that a supplemental report containing missing data from the 1976 report would be submitted by November 1,1977.
The inspector stated that while corrective action has been initiated, this item would be considered unre-solved, pending the submission of the supplemental report and its subsequent review; along with the review of the 1977 report under the contractual arrangement.
(Detail 3.d)
-
(77-14-03; 77-33-03; 77-31-03)
-
(Closed) Noncompliance (77-10-05):
Failure to notify NRC of changes in Section 5.0 of the ETSR.
The inspector determined through discussions with the licensee and the review of letters submitted to the NRC, that the NRC has been informed of the current e
organization and responsibilities and any changes that had been made to Section 5.0 of the ETSR. The inspector had no further questions in this matter.
(0 pen) Noncompliance (77-10-06):
Failure to document by letter the results of the milch animal census.
The inspector determined through discussions with the licensee and the review of the letter submitted to the NRC dated August 1,1977, that-the data submitted was not complete, in that it contained the enumeration of the farms rather than the enumeration of the milch animals.
The licen-(
see stated that the latter data would be submitted by November 1, 1977. The inspector stated that this item would be considered unresolved, pending the receipt and subsequent review of the supple-
'
mental data.
(77-31-04)
(Detail 4)
!
i l
.
- _ _ _
_ _ _ _ _ _.
.
/'
.
.
(Closed)
Deviation (76-14-04; 76-32-04; 76-32-04):
Emergency Plan training program not adequately documented in the form of lesson outlines and schedules.
The inspector determined through dis-cussions with the licensee and the review of the Indian Point Station Training Manual, Section 14, Emergency Plan, that the Emergency Plan training program was now documented in the form of lesson outlines and schedules.
The inspector stated that this item is considered closed.
(Detail 5)
(0 pen)
Unresolved Item (77-03-05; 77-09-05; 77-10-07):
Ganna spectral analysis of water samples.
The inspector determined through discussions with the licensee and review of the contractor reports and procedures, that (1) since May 1.1977 all water sam-ples were analyzed by a contractor, such that no new samples were added to the " unresolved category" and (2) action has not yet been taken to resolve the discrepancies in the gamma spectral analyses for the 1976 and 1977 water samples until May 1,1977.
This item continues to be unresolved.
(77-14-04; 77-33-04; 77-31-05)
(Detail 4)
(Closed)
Unresolved Item (77-03-06; 77-09-06; 77-10-08):
Inlet and disenarge water sampling.
The inspector determined through discussions with the licensee and his observations of the water samplers, that the continuous water samplers at the inlet and dis-charge sampling locations had been modified such that the water sampled for radiological analysis was now more representative of the total water flow at these locations.
The inspector had no further questions in this area at this time.
(0 pen)
Unresolved Item (77-10-09):
Analytical sensitivities for Sr-89, Sr-90 and I-131 in environmental samples.
The inspector determined through discussions with the licensee that action had not yet been taken to obtain the necessary analytical data to ver-ify that the minimum required sensitivities for Sr-89, Sr-90 and I-131 have been achieved.
The inspector stated that this item re-mains unresolved.
(77-31-06)
(Detail 4)
3.
Management Controls a.
Changes The inspector discussed with the licensee any changes that were made in the organization with respect to assignment of responsibilities or management changes with respect to the environmental programs at the Indian Point site.
The follow-ing changes were implemented since the presious inspection in this area (Report 50-3/77-03; 50-247/77-09; 50-286/77-10).
_
-
.-
.
---
--
-
.
-
-_ -
.. -
.-
-
e
.
.
,
.
-
(1) Mr. t. Volpe has replaced Mr. P. Crinigan as supervisor of the Nuclear Environmental Monitoring (NEM) program.
(2) The Supervisor - NEM now reports to Dr. A. Cheifetz, Senior Engr. and Corporate Radiation Safety Officer, who in turn reports to Mr. E. Kessig, Ass't V. Pres. for Power Generation Operations, through the Division Chemist, the Chief Chemical Engineer, and the Mgr. Operations Services Dept. Formerly, the Supervisor-NEM reported to Mr. R. Van Wyck, Senior Health Physist and Corporate Radiation Safety Officer, who reported directly to Mr.
Kessig as Ass't V. President for Power Generation.
(3) Mr. E. Kelleher has replaced Mr. G. Cowherd as Director, Department of Biology, con Ed.
(4)
Since May 1, 1977 all environmental samples requiring radiological analyses have been analyzed by Teledyne Isotopes, Inc., Westwood, New Jersey.
Prior to this time, samples analyzed for H-3, gross beta activity or gamma-emitting nuclides had been analyzed at the Indian Point site by the NEM group.
(5)
Selected samples of environmental media are no longer split and submi_tted to Eberline-Southeast Facility for evaluation of the quality of analytical performance of the other radiological analytical laboratories.
The inspector determined through discussions with the licensee and the review of the results of these changes that these changes did not result in a decrease in the level of manage-ment controls from the previous program.
b.
Licensee Audits The inspector reviewed the results of the QSR-401 Audit 77-El conducted on May 23-31, 1977 of the NEM program. The inspector determined that any item requiring correction or resolution was documented in the report to Con Ed management.
Each of the identified items were addressed by con Ed and action was initiated to resolve these items.
The inspector had no further questions in the above area at this time.
,
.
..
..
.
,
'
.
!
.
C.
Procedures The inspector reviewed salected procedures required by the ETSR, reviewed the minutes of the Environmental Protection Committee (EPC) at which the various procedures were review-ed and approved, and discussed these procedures with the licensee.
The inspector determined that the procedures identified dur-ing the last inspection as not reviewed and approved by the EPC, as required, had subsequently, received these actions.
Procedures specifically involved, included those procedures required to implement Sections 4.1.2 and 4.2, Environmental Surveillance Programs of the ETSR; the NEM procedures required to conduct the radiological environmental sampling of media; and selected radio-analytical procedures for environmental media.
The inspector had no further questions in the above areas; however, the inspector identified a number of radioanalyses which are required by. the ETSR for which the licensee did not have copies of the employed procedures, nor were they reviewed and approved by the EPC, as required.
The specific procedures identified, included those for the analyses of Sr-89 and Sr-90 in air particulates, clams / crabs, fish and soil and for the analyses of gross beta activity in aquatic vegetation, clams /
crabs and fish.
The inspector stated that this item was in noncompliance with Section 5.4.B of the ETSR for Units 1 and 2 and Section 5.4.2 of the ETSR for Unit 2, which requires that the detailed procedures required for conducting the activities of the ETSR be reviewed and approved by the EPC.
(77-14-01; 77-33-01; 77-31-01)
The inspector also determined through discussions with the licensee and the review of selected radiological environmen-tal media sampling procedures and available records that these procedures had been revised to reflect the activities conducted, and had been reviewed, approved and implen,ented.
One exception identified was Procedure NEM-AD-08. Rev. 3 " Quality Control Program," approved on May 9,1977, superseding Procedure NEM-A-08, Revision 2.
While the above procedure had been properly reviewed and approved, it had not been implemented.
It should be noted that its predecessor, NEM-A-08, Revision 2 had not
.
o
,
,
.
been implementad either and was so identified during the last inspection of this area (77-03-02; 77-09-02; 77-10-02).
The inspector stated that this item appears to be uncorrected and is in noncompliance with Section 5.4. A of the ETSR for Units 1 and 2 and Section 5.4.1 of the ETSR for Unit 3 (77-14-02; 77-33-02; 77-31-02).
The inspector discussed with the licensee and contractor per-sonnel the existing control system as used by the licensee to assure proper distribution of approved procedures and proced-ure changes, the timely implementation of those changes and appro-priate checks to assure that the implemented procedures had received the required approvals prior to implementation.
The licensee stated that this area is currently being reviewed and some improvements will be made in this area.
The inspector also discussed with the licensee the use of a
" master list" or " master copy file" of procedures which require review and approval by the EPC. The licensee stated that such a file is currently being developed and should be completed by December 15,1977. _The inspector had no further questions in this area at this time.
The licensee stated that by November 1,1977, a computer pro-gram package would be developed and implemented to aid in the control of the Nuclear Environmental Monitoring program.
The package would be used as a surveillance tool to assure that all of the required sampling and analyses were performed within the scheduled / required performance windows and would be used to' " flag" the licensee of anomalcus/ atypical measure-ment results and of analytical results which do not meet the required sensitivity levels.
The inspector had no further questions in this area at this time.
.
d.
Reports The inspector determined through discussions with the licensee and through the review of the EPC meeting minutes, that the 1976 Annual Environmental Operating Reports, Parts A and B, have been reviewed as required by the ETSR. The inspector also determined that the language of the EPC Charter had been modif-ied to encourage and accommodate the review of future reports prior to their submittal to the NRC.
The inspector had no further questions in this area.
,
- - -
-
-
_ _ -.
...
.-
_
_ _ _ _ _ _ _
-
.
.
..
,
-
.
'
.
no subsequent ganna analyses fall into the unresolved category.
,
With respect to the resolution of apparent gamma analysis spectral
'
'
discrepancies of water samples from January 1976 through April 1977, the licensee stated that a) spiked water samples would be
,
analyzed for gamna emitters using a Marinelli breaker and then evaporated and analyzed via the in-house procedures utilized be-tween January 1976 and April 1977 and b) the analytical results of i
those analyses performed prior to May 1977 will be compared with those analyzed by the contractor subsequent to May 1,1977.
The
'
licensee stated that this action would be completed by April 1,
1978. This item remains unresolved (77-14-04; 77-33-04; 77-31-05).
The inspector examined selected environmental radioanalytical re-
'
sults since January, 1976 and discussed with the licensee the con-trols and reviews performed on the data and analyses.
The inspector determined that since January 1976 the Minimum Detectable Level (MDL)
had not been achieved for I-131 analysis of Hudson River aquatic vegetation nor for lake aquatic vegetation.
Section 4.2.1.1 and Table 4.2-1 and 4.2-3 of the ETSR for Unit 3 require,in part, that I-131 in these media be analyzed with a MDL of 0.05 pCi/g. The data reviewed indicated the-MDLs achieved were 0.09 - 0.4 pCi/g
'
or larger. The inspector stated that this was an item of noncompli-ance (77-31-07).
The inspector also determined through discussions with the licensee
-
that action had not yet been taken to resolve item 77-10-09. The inspector stated that additional analytical data, including chemi-cal yields, background count rates, counter efficiencies, sample count rates, etc. were necessary to determine whether MDLs for Sr-89, Sr-90 and I-131 in environmental media had been achieved.
The licensee stated that this data would be obtained from the contractor and would be reviewed by the licensee and available for
inspection by January 1,1978. The inspector stated that this item remains unresc1ved pending the review of the data by the NRC (77-31-06).
-
I
,
.. ___
,
-
., - -, _ _ _ _ - -.
_
.
_
... --
.
l
.
-
s
,
-
.
5.
Emergency Planning The inspector reviewed Section 14, Emergency Plan, of the Indian Point Station Training Manual and determined that the Emergency Plan training program was now documented in terms of lesson out-lines and schedules to correct the previously identified deviation (76-14-04; 76-32-04; 76-32-04). The inspector discussed specific training items with the licensee.
In this regard, the licensee stated that the Training Manual would be modified to reflect that the First Aid Teams would receive technical qualification training via the Red Cross Multi-Media and CPR Training and that the fire fighting teams members would receive initial formal technical qualification training with an established technical fire fighting program.
In addition, the licensee stated that the local service support training section would be modified to include Peekskill Memorial Hospital. The inspector stated that with these modifica-tions, this item is considered closed.
6.
Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items,
-
items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are discussed in Details 3.d and 4.
7.
Exit Interview and Management Meeting On September 29, 1977, at the conclusion of the inspection, the inspector met with the licensee representatives indicated in Detail 1.
The scope and findings of this inspection, including each of the unresolved items and items of noncompliance were discussed.
On October 12, 1977, Messrs. Stohr, Streeter and Bores of the NRC:I staff met with the licensee management representatives denoted in Detail 1.
The purpose of this meeting was to discuss with the licen-see management the NRC's concern. that proper management attention and controls be focused on the implementation of the licensee's environmental monitoring programs.
.
. - -
.
-
-
l
_ ___-
. _ _ _ _ _
e
'
,
.
.
!
-
j
.
At this meeting the results of the inspection were discussed along with previously identified problems relative to these programs and progress to date in correcting / resolving them.
In addition, to reaffirming the dates at which time specific actions would be completed as given in Details 3 and 4, the licensee stated that by December 15, 1977 the Environmental Protection Committee will have developed a master list of all procedures required by the ETSR, will have determined that the Master List is complete by matching the ETSR with the corresponding procedure; and have developed, reviewed and approved any procedures which were found to be lacking from the Master List. The licensee further stated that the Master List would be utilized to ascertain the current review status of the required procedures per the ETSR.
~
-
.
.
i l
l u
_
.1
._
e s
- sd asc'u UNITED STATES
'
g
/
~
k, NUCLEAR REGULATORY COMMISslON iy
)
..,.7% "v'e~ue XBLE COP.Y
,
s,;.
,f
,~........... ~~ m.~,......
.....
..
Docket Nos. 50-03 OCT 7 1977 (2 -7477
'50-286
.
'
Consolidated Edison Company of New York, Inc.
ATTN: Mr. W. J. Cahill, Jr.
Vice President
~,
-
4 Irving Place
.
New York, New York 10003 Gentlemen:
Subject: Management Meeting This letter confirms the management meeting requested by us which will be held in your corporate office on October 12, 1977, at 9:00 a.m.
Topics to be addressed are items of concern related to the environmental monitoring program which were~ identified during our inspection (Combined Inspection 50-03/77-14, 50-247/77-33, and 50-286/77-31) of that area on September 27-29, 1977. Arran'gements for this meeting were discussed on October 5,1977, in a telephone conversation between Mr. E. F. Kessig of your organi::ation a,nd Mr. J. F. Streeter of my staff.
No reply to this letter is necessary; however, should you have any questions concdrning this meeting, we will be pleased to discuss them with you.
Sincerely,
/
-
,
_
El c.
. Brunner, Chief R r.ctor Operations and Nuclear Support Branch
.
l
.
"
~
.
..
_-
.
-
OCT 71977
-
l Consolidated Edison Company of
New York, Inc.
cc:
L. O. Brooks, Project Manager, IP Nuclear (Con Ed)
E. R. McGrath, Manager, Nuclear Power Generation Depart:::ent (Con Ed)
T. Law, Plant Manager, (Con Ed)
J. M. Makepeace, Director, Technical Engineering (Con Ed)
George T. Berry, General Manager and Chief Engineer (PASilY)
L. R. Bennett, General Counsel (PASNY)
Rear Admiral P. J. Early, Assistant Chief Engineer - Projects (PASilY)
Manager - ?!uclear Operations (PASNY)
J. P. Bayne, Resident Manager (PASHY)
,
J. D. Block, Esquire, Executive Vice President - Administration E. J. Sack, Esquire A. Z. Roisman, Counsel for Citizens Comittee for Protection of the Environment bec:
IE Mail & Files (For Appropriate Distribution)
Central Files
-
Public Document Room (PDR)
'
Local Public Document Room (LPDR)
Nuclear Safety Infonnation Center'(NSIC)
Technical Information Center (TIC)
.
REG:I Reading Room State of New York
.