ML20042B147
| ML20042B147 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/27/1977 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | William Cahill CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| Shared Package | |
| ML20042B148 | List: |
| References | |
| NUDOCS 8203250025 | |
| Download: ML20042B147 (5) | |
See also: IR 05000003/1977003
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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631 PARK AVENUE
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MAY 2 71977
Docket Nos. 50-03
50-247
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Consolidated Edison Company
of New York, Inc.
ATTN: Mr. W. J. Cahill, Jr.
Vice President
4 Irving Place
Gentlemen:
Subject:
In gaction 50-3/77-03, 50-247/77-09 and 50-286/77-10
This 'efers to the inspection conducted by Dr. R. Bores of this' office
on Apr:1 5-8,11 and 12,1977, at Indian Point Nuclear Station: Buchanan,
New York and at the Consolidated Edison Company of New York cot grate
office of actidties authorized by NRC License Nos. DPR-5, DPR-26 and
DPR-64 and to the discussions of our findings held by Dr. Bores with
Messrs. McGrath Law, VanWyck and other members of your staff at the
conclusion of the inspection, and to subsequent telephone discussions
between Messrs. Stohr, Streeter and Bores, of this office, and Messrs.
Kessig, McGrath and Law, of your staff, on April 14, 1977, and between
Mr. S*reeter and Mr. McGrath on April 18, 1977.
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 Items
of Noncompliance brought to your attention in a letter dated November
16, 1976, Item E (Unit 2) and Item C (Unit 3).
We have no further
questions regarding your 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
April 20,1976. We have no further questions regarding the steps you
took to correct Items B and C.
With regard to Item A, however, we note
that this item is recurrent as described in Appendix A to this letter.
In your response to this letter, please give this matter your particular
attention.
8203250025 770527
PDR ADOCK 05000003
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Consolidated Edison Company of
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New York, Inc.
Based on the results of this inspection, it appears tha: certain of your
activities were not conducted in full compliance 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 noncompliance; and (3) the date when full compliance
will be achieved.
In addition to the corrective actions regarding the
specific items of noncompliance, we are concerned about the coordination
within your company, at both the corporate and site levels, of your
management controls to assure that all of the environmental technical
specification requirements are satisfied.
Consequently, in your response
to this letter, you should describe those actions taken or planned to
improve the effectiveness of your management control systems.
Based on the above referenced telephone discussions, we understand that:
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 radio-
logical environmental laboratory activities, including quality
control and data review.
c.
There will be improvement in the company-wide coordination in
carrying out the ETSR.
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2.
Beginning May 1,1977 all environmental radiological sample analyses
will be performed by an outside contractor.
Prior to resuming in-
house analyses of these samples, Con Ed will have re-established
the quality of these analyses and have the necessary approved
procedures, personnel and proficiency for performing the required
analyses.
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Consolidated ' Edison Company of
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New York, Inc.
3.
By May 15,1977,
a.
The EPC and the NFSC, as appropriate, will ha"e reviewed and
approved the radioanalytical procedures to be employed in the
radiological environmental analyset by the contracted laboratory.
b.
The EPC and the NFSC, as appropriate, will have completed the
review and approval of the radiological sampling procedures
employed by Con Ed and the Con Ed procedures to ensure the
quality of the radioanalytical 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 radic'ogical environmental
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.
With regard to your request in a letter to this office dated November
17, 1976, for clarification of the reporting requirement fbr anomalous
radioactivity measurements in environmental media, Section 5.6.2.2.a of
the ETSR for Unit 3, for which no defined control stat on exists; the
following reporting criteria are acceptable, as discussed with your
staff during the inspection.
1.
The report level may be based on historical levels of radioactivity
in each medium at each location, such that a report is required if
the radioactivity exceeds 10 times the normal level in the medium;
or
2.
The report level may be based on the radioactivity level in a
medium exceeding 10 times that of a " control" location sample,
where the " control" location is recognized as not being completely
outside the influence of the plant, but is the most remote of the
sampling stations in terms of plant influence.
In this regard,
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consideration might be giver .o establishing a sampling location
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more remote than are the present upstream locations from Indian
Point Station.
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Your choice of reporting criteria should be defined in a procedure for
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future consistency in this area.
This will be reviewed during a sub-
sequent inspection.
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Consolidated Edison Company of
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New York, Inc.
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 information, 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 Commission 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.
Should you have any questions concerning this inspection, or if our
understandings concerning your committ - ..s documented above are not
correct, we will be pleased to discuss them with you.
Sincerely,
g f,O' h,i_ b_ =
J es P. O'Reilly
Di
ctor
Enclosures:
1.
Appendix A, Notice of Violation
2.
Office of Inspection and Enforcement Inspection
Report Numbers 50-03/77-03, 50-247/77-09 and 50-286/77-10
cc w encls:
L. 0. Brooks, Project Manager, IP Nuclear
Leonard M. Trosten, Esquire (Representing Con Ed)
E. Kessig, Acting Manager, Nuclear Power Generation Department
T. Law.
Plant Manager
J. M. Makepeace, Director, Technical Engineering
George T. Berry, General Manager and Chief Engineer (PASNY)
Z. E. Chilazi, Manager of Projects, Thermal Power Generation (PASNY)
A. Z. Roisman, Counsel for Citizens Committee for Protection
of the Environment (Without Report)
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Consolidated Edison Company of
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New Yort. Inc.
bec w/encls:
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IE Mail & Files (For Appmpriata Distribution)
Central Files
PublicDocuentRoom(PDR)
Local Public Doc ment Room (LPDR) (MSIC)
Nuclear Safety Information Center
Technical Information Center (TIC)
REG:I Reading Room
itagion Directors (III, IV)(Report Only)
Stata of New York
A. Z. Roisman, Counsel for Citizens Comittee
for Protection of the Environment
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