ML20042B151
| ML20042B151 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/27/1977 |
| From: | 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 8203250029 | |
| Download: ML20042B151 (3) | |
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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, 50-286 Based on the results of an NRC inspection conducted on April 5-8,11 and 12, 1977, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your NRC Facility License Nos. OPR-5, DPR-26 and DPR-64, as indicated below.
Items A through C are categorized as Infractions, Items D through G as Deficiencies.
A.
Section 5.4.8 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 Environ-mental Protection Committee (EPC) and, if they affect plant oper-ations, approved by the plant manager.
Contrary to these requirements, as of Apri'1.12,1977, required procedures, including all those for the nuclear environmental sampling, analyses, related quality control activities, and contractor implemented radioanalytical procedures were not reviewed and Epproved by the EPC.
This is a recurrent item.
i 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 April 12, 1977, procedures, including NEM-C-10, Rev. O, 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 Program; were not followed and/or implemented.
i 8203250029 770527 PDR ADOCK 05000 0
s Appendix A 2
C.
Section 5.4.8 of the ETSR for Units 1 and 2 requires, in part, that all procedures and changes to those procedures, as they pertain to the ETSR be reviewed and approved by the EPC prior to implementa-tion.
Contrary to this requirement, as of April 12, 1977, contractor procedures required to implement Sections 4.1.2 and 4.2, Environ-mental Surveillance Programs, of the ETSR were not reviewed and approved by the EPC prior to their implementation.
D.
Section 5.1.2.7.j of the ETSR for Unit 3 requires that the EPC re-view the results of the environmental monitoring program in each Annual Environmental Operating Report required by Section 5.6.1.1 of the ETSP..
Contrary to this requirement, the EPC did not review the results of the radiological monitoring program for 1976 in the Annual Environ-mental Operating Report, Section 5.6.1.1.B.
E.
Section 5.6.1.1.B of the ETSR for Units 1 and 2, and Section 5.6.1.1.8 of the ETSR for Unit 3 require, in part, that the Annual Environ-mental Operating Report, Part B:
Radiological, includes summaries, interpretations and statistical evaluation of the results, includ-ing a comparison with preoperational studies, operational controls (as appropriate), previous environmental reports and an assessment of observed plant impacts on the environment.
The radiological sample data are to be summarized on an annual basis following the format of Table 5-1 of the ETSR.
Contrary to these requirements, the 1975 and 1976 Annual Environmental Operating Reports, Part B, were not summarized on an annual basis; were not in the format of ETSR Table 5-1; and did not include interpretations nor statistical evaluations of the results, including comparisons with preoperational studies, operational controls and previous reports.
F.
Section 5.1.1.5 of the ETSR for Unit 3, requires that any change in the organization and responsibilities described in Section 5.0 of the ETSR be reported within 30 days to the Director of the Office of Nuclear Reactor Regulation.
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a Appendix A 3
Contrary to this requirement, as of April 12, 1977, changes made in January,1977, to the organization and responsibilities described in Section 5.0 of the ETSR were not reported to the NRC Office of Nuclear Reactor Regulation as of the time of inspection.
G.
Section 4.2.1.3 of the ETSR for Unit 3 requires, in part, that the results of the field survey and enumeration of the milch animals census be documented by a letter to the plant files and a copy sent to the Director of Office'of Nuclear Reactor Regulation.
Contrary to this requirement, as of April 12, 1977, the results of the 1976 milch animal census were not documented by letter to the plant files with a copy to the NRC Office of Nuclear Reactor Regulation.
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