ML20050A268
| ML20050A268 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/29/1977 |
| From: | Knapp P, Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A264 | List: |
| References | |
| 50-003-77-01, 50-247-77-02, 50-247-77-2, 50-286-77-03, 50-286-77-3, 50-3-77-1, NUDOCS 8203310657 | |
| Download: ML20050A268 (16) | |
See also: IR 05000003/1977001
Text
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IE:I Form 12
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(Jan 75) (Rev)
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U. S. NUCLEAR REGUIATORY CCSCIISSION
OFFICE OF INSPECTION AND ENFORCDfE!TI
REGION I
50-03/77-01
50-03
50-247/77-02
50-247
IE Inspection Report No:
50-286/77-03
Docket No: 50-286
OPR-5
Licensee:
Consolidated Edison Comoany of New Ynri. inc-
License No:
DPR-64
4 Irving Place
Priority:
--
D
C
. Category:
C
Safeguards
(Indian Point Units 1, 2, and 3)
Group:
--
Location:
Buchanan, New York
PWR, 615 MWt (B &W) , PWR, 27 58 MWt (W) ,
Type of Lic.ensee:
PWR, 3025 MWt (W)
--
Type of Inspection:
Special, Unannounced
Dates of Inspection:
February 2-4 and 16-18, 1977
December 28, 1976
Dates of Previcus Inspection:
[ [ 9 7te d e
.7/A9/tJr)
Reporting Inspector:
/
WATE
'D. R. Neely, dadiation Specialist
Accompanying Inspectors:
None
DATE
DATE
DATE
Other Accompanying Personnel:
DATE
Reviewed By:
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c
.3
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P. 8. Knapp, Chief, Radiation Support Section,
Fuel Facility and Materials Safety Branch
8203310657 770331
PDR ADOCK 05000003
G
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SUMMARY OF FINDINGS
Enforcement Action
,
A.
Violations
None.
B.
Infractions
None.
C.
Deficiencies
.
77-02-01 and 77-03-01 - Training and Qualification Records.
Contrary to Unit 2 and Unit 3 Technical Specifications 6.10.2, g,
training and qualification records were not maintained for all of
the staff health physics technicians who received initial training
in 1972 and retraining in 1975 and 1976.
(Details,4)
Licensee Action on Previously Identified Enforcement Action
Not inspected.
Design Changes
Not inspected.
Licensee Events
Not inspected.
Other Significant Findings
A.
Current Findings
1.
Acceptable Areas
No inadequacies were identified during inspection of the follow-
ing areas:
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Temporary procedure " Transfer of Liquid Radioactive Waste
a.
from Unit No. 3 to Unit No.1."
Posting of high radiation areas and radiation areas.
b.
2.
Unresolved Items
The following itsns will require additional information from
the licensee in order to evaluate compliance with requirements:
Development and documentation of a
77-02-02 and 77-03-02 -
(De-
health physics retraining program by September 1,1977.
tails, 5)
3.
Items Requiring Further Review
Audits of performance, training
77-02-03 and 77-03-03 -
and qualifications performed by the Nuclear Facilities
a.
Safety Committee.
(Details,7)
b.
77-01-01, 77-02-04, and 77-03-04 - Upgrading program:
training of all health physics technicians.
( Detail s , 6.d)
77-01-02, 77-02-05, and 77-03-05 - Upgrading program:
general training for all employees.
(Details,6.e)
c.
77-01-03, 77-02-06, and 77-03-06 - Revision of Station
d.
Administrative Order No.105 and Health Physics Procedure
No. 5.
(Details , 6.1)
77-01-04, 77-02-07, and 77-03-07 - Revision of Station
e.
Administrative Order No.111.
(Detail s, 6.g)
f.
77-01-05, 77-02-08, and 77-03-08 - Revision of Station
Administrative Order No.120.
(Details,6.1)
77-01-06, 77-02-09, and 77-03-09 - Installation of self-
l
g.
closing gates.
(Details,6.f)
h.
77-01-07, 77-02-10, and 77-03-10 - Revise and improve
procedures.
(Details,6.c)
1.
77-01-08, 77-02-11, and 77-03-11 - Review qualifications
of health physics supervisors and technicians.
(Details,
6.b)
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77-01-09, 77-02-12, and 77-03-12 - Evaluation of Contin-
uous Air Monitors.
(Details, 6.j)
k.
77-01-10, 77-02-13, and 77-03-13 - Positive control of
contractor exposures.
(Detail s , 6.m)
1.
77-01-11, 77-02-14, and 77-03-14 - Evalua' tion of Dosimetry.
(Details, 6.o)
m.
77-01-12, 77-02-15, and 77-03-15 - Unauthorized Use of
Film Badges.
(Details, 6.p)
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4.
Deviations
None.
B.
Status of Previously Identified Unresolved Items
Not inspected.
Manaaement Interviews
Management interviews were conducted at Buchanan, New York (site) on
February 4 and February 18, 1977.
A.
Persons Present
The following licensee personnel were in attendance on February 4,
1977:
Mr. W. E. Caldwell, Senior Vice President, Power Supply
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. N. Hartman, QS&R Consul tant
The following licensee personnel were in attendance on February 18,
1 977:
Mr. E. McGrath, Manager, Nuclear Power Generation Department (Designee)
Mr. J. Makepeace, Director, Technical Engineering
Mr. B. Maroney, Chief Operations Engineer
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
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Mr. R. Hayman, Manager, QA&M&R
Mr. S. Wisla, Director, Chemistry and Radiation Safety
Mr. J. Bayne, Power Authority State of New York, Manager, IP-3
Mr. E. Tagliamonte, Operations Engineer, Unit 3
Mr. L. Kawula, Test and Performance Engineer
Mr. W. Carson, Test Engineer
B.
Items Discussed
1.
Purpose of the Inspection
The inspector stated that the purpose of the inspection was to
verify that the licensee had implemented the " Consolidated
Edison Company of New York, Inc. , Indian Point Station Upgrad-
ing Program for Radiation Protection," according to the schedule
shown in the plan and to review the progress the licensee has
made in improving their Radiation Protection Program.
In addi-
tion, the inspector stated that the purpose of the inspection
was to perform a routine inspection of the Unit 3 health physics
program.
2.
Acceptable Areas
The items discussed are as identified under "Other Significant
Findings" section of this report.
3.
Items of Noncompliance
The items discussed are as identified under the " Enforcement
Action" section of this report.
.
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DETAILS
1.
Persons Contacted
Mr. E. Kessig, Acting Manager, Nuclear Power Generation Department
Mr. E. McGrath, Manager, Nuclear Power Generation Department (Designee)
Mr. J. Makepeace, Director, Technical Engineering
Mr. R. Hayman, Manager QA M&R
Mr. M. Shatkouski, Nuclear Training Director
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. J. Odendahl, Senior Electrical Technician, Radiation Safety
-
Mr. H. McKay, Watch Supervisor, Unit 3
Mr. R. Orzo, Watch Supervisor, Unit 2
Mr. T. Yentz, Health Physics Instructor, NUS Corporation
.
Mr. R. Long, Maintenance Engineer
Mr. E. Murri, Staff Health Physicist, NUS Corporation
Mr. S. Lavie, Assistant Health Physicist, NUS Corporation
Mr. R. Ea; lick, Health Physics Supervisor, NUMANCO
Mr. G. Clifton, Health Physics Technician, NUMANCO
Mr. M. Shusterman, Q&SR
2.
Scope of the Inspection
The scope of the inspection consisted of reviewing the progress
made by the licensee in implementing the upgrading program to improve
the Radiation Protection Program.
During the inspection, the inspector
observed retraining being conducted for health physics technicians
and general employees, reviewed procedures, interviewed plant per-
sonnel, and toured the controlled areas of Units 1, 2, and 3.
3.
Plant Records
Not applicable.
4
Training and Qualification Records
Unit 2 and 3 Technical Specifications 6.10.2, g, require that records
of training and qualification for current members ot the plant staff
be maintained for the duration of the Facility Operating License.
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Contrary to the above, training and qualification records were
not maintained for all of the health physics technicians who
received initial training in 1972 and retraining in 1975 and 1976.
.
A licensee representative stated to the inspector that 9 health
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physics technicians received initial training in 1972 but that he
could only locate training records for four of the technicians.
He
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further stated that the health physics technicians received some
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retraining during 1975 and 1976 and that some of this training had
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been documented.
The inspector reviewed the retraining records and
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noted that the records were in insufficient detail to permit one to
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ascertain the extent of the retrainir.g and that the records did not
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show that all of the health physics technicians then employed had
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received any retraining.
The inspector noted that the licensee's failure to maintain train-
!
ing records constituted noncompliance with Unit 2 and 3 Technical
l
Specifications 6.10.2, g.
(77-02-01 and 77-03-01)
5.
Health Physics Technician Retraining / Replacement Training
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Technical Specification 6.4.1 requires, in part, a retraining and
replacement training program for the facility staff which meets or
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exceeds the requirements and recommendations of Section 5.5 of
Both the Technical Specifications and ANSI 18.1-
,
1971 apply to health physics technicians (i.e. , radiation protection
specialists.) At the time of the inspection, the inspector deter-
mined that a fonnally documented retraining program did not exist
for health physics technicians and the licensee's retraining efforts
had been limited, informal, and insufficntly documented.
However,
the 1icensee's replacement training was conducted under the guidance
of procedure RS-AD-11-1, " Training of Technicians," which was
developed to assure that health physics tecNicians are trained
in their assigned duties before initial assignment.
,
This lack of a formally documented and implemented retraining pro-
gram for health physics technicians had been identified by the
licensee during the implementation of his upgrading plan for the
radiation pro'.ection program.
The licensee stated that the admin-
,
istrative cortrols for the retraining program will be developed by
.
September 1,1977, and will be incorporated into the station train-
ing manual.
The program will be administered by the Nuclear Training
Director and will be conducted in annual cycles with the first cycle
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to be completed by March 31, 1978.
The subject matter to be
covered in an annual cycle will be determined each year and will
include, but will not be limited to, preplanned lectures to empha-
size areas of, weakness indicated by examination and quiz results.
The program content will te supplemented by additional areas of
instruction such as; changes in station administrative controls
and detailed plant procedures affecting the conduct of the radia-
tion protection program, changes in 10 CFR 20, instructions in
the operation of new monitoring and measuring equipment, and
radiation protection related technical specifications and license
c hanges. A licensee representative stated that his approach to the
retraining program would be similar to the approach required for
licensed operators by 10 CFR 55, Appendix A.
The licensee plans to include provisions for replacement training
in the formal retraining program discussed above to be developed by
September 1,1977.
The subject matter of the replacement training
program will meet or exceed the present provisions of RS-AD-11-1
and the program will supercede RS-AD-11-1.
The licensee stated that training of health physics technicians in
operation and layout of plant systems would not commence until the
end of calendar year 1977.
The inspector stated that if techni-
cians are allowed to issue Radiation Work Permits (RWP) and deter-
mine monitoring and resurvey needs, systems training is necessary
to assure that the technicians have adequate knowledge of the
operation and physical routing of systems designed to handle radio-
active material to enable the technicians to make intelligent
decisions on monitoring and resurvey needs and on required pro-
cedures and equipment to assure radiation safety.
The licensee
stated that the Watch Supervisors (senior licensed operators) who
have detailed knowledge of plant systems will continue to concur in
the issuance of RWP's until health physics technicians have been
satisfactorily trained in plant systems.
This is an Unresolved Iten pending the licensee's development and
documentation of a health physics technician training program by
September 1,1977, and the inspector's review of the program con-
tent.
(77-02-02 and 77-03-02)
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6.
Upgrading Program for Radiation Protection
In response to a letter dated November 18, 1976, from J. 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 document was reviewed by
NRC representatives on December 20, 1976, and was discussed with
the licensee during a management raaeting conducted on December 21,
1976.
During the meeting licensee representatives stated that they
intended to implement the program according to the schedule shown
in the plan.
Details of this meeting 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 tne 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 below:
a.
Plant Facilities
,
The licensee has issued a purchase order for a prefabricated
-
office for the health physics supervisors.
Delivery is
expected the week of February 7,1977.
The existing counting _rocm
has been modified to become part of the controlled area but
s
until such time as the supervisor's office is completed the
current counting room will still be used as part of the
uncontrolled area.
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b.
Organization
The licensee has reorganized the Radiation Safety Sub-Section
as shown below:
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PLANT MANAGER
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Director
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Chemistry & Radiation
Safety
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Senior
)
s
En ineer
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General
Chemistry
Health Physics Supervisor
Supervisor
I
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Supervisor
Supervisor
Supervisor
Supervisor
Chemi stry
Records
Unit 1
Unit 2
Unit 3
Technicians
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Rad - 'Ja sta
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Records
Health Physics
- Clerk
Technicians
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(2)
(15)
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There are presently two health physics supervisors, instead
of the four specified in the organization.
The licensee is
presently interviewing candidates for the two health physics
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supervisor vacancies.
Until the two additional health physics
supervisors are hired and trained, the licensee is utilizing
the services of a health physics supervisor who was transferred;
to the training section. There are presently nine health physict
technicians, instead of the fifteen specified in the organiza- *
tion. The licensee is presently interviewing candidates to
fill the six remaining vacancies. The licensee has supplemented
the Radiation Safety staff with six contractor supplied health
physics technicians until such time as the vacancies 'are filled
r
and the new technicians have had adequate training.
The in-
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spector reviewed the resumes of all of the contractor supplied
health physics technicians, interviewed several of them, and
I
determined that these individuals were qualified to perform
the duties of health physics technicians.
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The inspector reviewed the qualifications of the current members
of the plant staff which appeared to meet the requirements of
However
it will be necessary for the inspector
to question personnel regarding their assigned duties to further
determine if they are qualified.
This item requires further review and will be completed at a
subsequent inspection.
(77-01 08, 77-02-11, and 77-03-11)
c.
Review and Improvement of procedures
A consultant has been employed by the licensee and is presently
on site reviewing all of the Radiation Safety procedures, inter-
viewing plant personnel, observing the work done by health
ohysics technicians in the controlled area, and inspecting the
plant facilities.
A representative of the consulting firm
stated to the inspector that their review of the procedures
and initial formulation of recommendations to improve the
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Radiation Safety Program is expected to be completed February
20, 1977.
He further stated that it would take approximately
three weeks to complete the review at their home office and to
prepare the formal report for the licensee.
This would make
the report available to the licensee approximately March 13,
1977.
A licensee representative stated that upon receiving
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the formal report from their consultant it would take approx-
imately four weeks for them to perform the necessary reviews
to determine what procedures have to be changed and what
additional procedures are needed.
The inspector stated that this item will be reviewed at a
subsequent inspection.
(77-01-07, 77-02-10, and 77-03-10)
,
d.
Basic Health physics Technician Training
The licensee began retraining the health physics technicians
in basic health physics on February 16, 1977.
During the
course of inspection, the inspector observed the training
being conducted to verify that the material covered was the
same as that outlined in the upgraoing program plan. The
inspector noted that the training appeared to be adequate and
asked a licensee representative how the technician's partici-
pation would be evaluated.
A licensee representative stated
that the technicians would be given exams at the completion
of their training and if any significant questions were missed
or if an individual failed the exam, the individual would be
retrained in those specific areas.
The licensee representa-
tive stated that the current retraining program would be
completed by March 11, 1977.
The inspector stated that the retraining being given to the
health physics technicians appeared to be adequate and infor-
mative.
The inspector further stated that the results of the exams
and the records of the retraining would be reviewed at a sub-
sequent inspection.
(77-01-01, 77-02-04, and 77-03-04)
e.
Basic Radiation Protection General Training for Employees
The general training of all employees commenced on December
29, 1976, and was determined by the inspector to be adequate
and that the subject matter presented during the training
session was in accord with the outline in the upgrading pro-
gram plan.
A licensee representative stated the training pro-
gram for all of the plant employees was expected to be completed
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The inspector stated that the procedure would be reviewed
at a subsequent inspection.
(77-01-04, 77-02-07, and 77-03-
07)
h.
Instrumentation Needs
The inspector reviewed the instrumentation needs the licensee
has determined necessary to further improve their Radiation
The licen3ee representative stated that
Protection Program.
the list of instruments needed was submitted to the Acting
Manager, Nuclear Power Generation for review and that purchase
orders have been approved for some of the equipment.-
The inspector noted that the licensee's instrument needs appeared
to be adequate and had no further questions at this time.
1.
Revision to Station Administrative Order No. 120
.
A draft revision of Station Administrative Order (SAO) No.
120 has been prepared by the licensee and is being reviewed
for final approval.
The inspector noted that SA0120 would be reviewed at a subse-
quent inspection.
(77-01-05, 77-02-08, and 77-03-08)
j.
Evaluate Use of Continuous Air Monitors (CAM)
A licensee representative stated to the inspector that the
evaluation of the use of CAM's is approximately 50% complete.
The inspector stated that this item will be reviewed at a sub-
sequent inspection.
(77-01-09, 77-02-12, and 77-03-12)
Positive Control at the Vapor Containment (VC)
k.
The licensee has implemented specific written instructions
for individuals assigned to control access to VC.
A licensee
representative stated that these instructions will be incor-
porated into existing containment and egress procedures.
During the course of the inspecticn, Unit 2 was shut down for
a " mini" outage and a control point had been established out-
side the Unit 2 VC.
The inspector went to the control point
and verified that the written instructions aid exist, were
being adhered to, and that positive control was maintained.
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The inspector noted that the licensee's method of maintaining
positive control for each individual entry into the Unit 2
VC appeared to be adequate and had no further questions at
this time.
Revision of Station Administrative Order No.105
1.
Licensee representatives stated that Station Administrative
Order (SAO) No.105, " Work Permits" would be approved and
implemented by the scheduled April 15, 1977, outage and that
all Radiation Work Permits and Radiation Exposure Authorizations
outstanding under the existing SAO will be collected and ter-
minated and that only RWP's issued under the provisiens of the
revised SAO 105 will be valid and in use.
The inspector stated that this item will require further review
and will be inspected at a subsequent inspection.
(77- 01-03 ,
77-02-06, and 77-03-06)
Positive Control of Contractor Exposures
m.
The licensee developed a procedure for the control of contractor
exposures and implemented the procedure but has found the pro-
The licen-
cedure not to be as effective as he wants it to be.
see is revising the procedure to further strengthen control
over contractor personnel .
The inspector stated that the revised procedure would be
reviewed at a subsequent inspection.
(77-01-10, 77-02-13,
and 77-03-13)
Evaluation of Plant Air for Determination of MPC
n.
The licensee has received the analysis of an actual plant air
This analgsis
sample taken during recent steam generator work.
0
showed that alpha activity and isotopes such as Sr89 and Sr
A licensee representative stated that they
were not present.
will periodically sample the plant air when primary systems
are opened for repair or inspection and that they will submit
the samples for similar analysis.
The inspector had no further questions regarding this item.
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o.
Evaluation of Dosimetry
The licensee's evaluation is in progress.
This item will
require further review by the inspector at a subsequent
inspection.
(77-01-11, 77-02-14, and 77-03-14)
p.
Unauthorized Use of Film Badges
Modifications to the security room are in progress.
The
inspector will review this item at a subsequent inspection.
(77-01-12, 77-02-15, and 77-03-15)
,
q.
Multiple Use of Protective Clothing
The licensee has discontinued the reuse of protective clothing.
This item is closed.
r.
Spread of Centamination
During the course of inspection of the Unit 2 and 3 controlled
area, the inspector observed that contaminated areas were
properly barricaded and posted and that the housekeeping was
good.
The inspector noted that additional survey instruments
were located at the entrance to the Unit 2 Vapar Containment
and personnel were instructed te survey more thoroughly.
s.
Definition of Parameters for Survey Evaluations and Establish-
ment of Clearly Defined Areas for Surveys
An indepth analysis by a consultant is in progress.
The recom-
mendations from this analysis will be documented in the same
report that is discussed in detail 6.c.
t.
Corporate Inspection Program for Posting of High Radiation
Areas and Radiation Areas
This inspection was in progress.
The inspector has no questions
about the program at this time.
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7.
Audits of Performance, Training, and Qualifications Performed by
the Nuclear Facilities Safety Connittee (NFSC)
During the course of the inspection, the inspector reviewed an audit
report dated December 14, 1976, that the NFSC had written to docu-
ment their findings of an audit of the Indian Point Station Facility
conducted during October, November, and December,1976.
The purpose of the audit was to determine the adequacy of station
conformance to requirements in the area of Training and Performance
of Indian Point personnel.
,
The report revealed several areas needing corrective action by the
licensee.
At the time of the inspection the licensee could not
provide the inspector with a copy of records of corrective action.
The inspector stated that this item will be reviewed at a subsequent
inspection.
(77 02-03 and 77-03-03)
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