ML20050C104
| ML20050C104 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/09/1976 |
| From: | Hauspurg A CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20050C088 | List: |
| References | |
| 60813, NUDOCS 8204080140 | |
| Download: ML20050C104 (27) | |
Text
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Arthur Houspurg
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Consolidated Edison Company of New York. Inc.
4 Irving P1 ace. New York. N Y 10003 Telephone (212) 460 3726 July 9, 1976 RE:
License Nos. DPR-5 (Unit 1)
DPR-2 6 (Unit 2)
Inspection Nos. 76-05 (Unit 1) 76-08 (Unit 2)
Docket Nos.50-003 (Unit 1) 50-247 (Unit 2)
Dr. Ernst Volgenau, Director Office of Insp9ction and Enforcemefit U.S. Nuclear Reciulatory Commission Washington, D.C.
20555
Dear Sir:
This refers to your letter of June 21, 1976 and constitutes con Edison's reply to Appendix A of that letter (Notice of Violation) pursuant to 10 CFR 2.201.
Our answer, in accordance with 10 CFR 2.205, to Appendix B to that letter (Notice of Proposed Imposition of Civil Penalties) is being provided sepa-rately as requested.
On April 29, 1976 Con Edison reported to you on the incident which permitted an employee to receive a radiation dose in excess of the quarterly limits on April 5,-1976.
Our company acknowledges its responsibility to have and fully implement 'a health physics APPEf4 DIX II 6 6813 8204000140 760621
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.o program for the protection of workers a,t our nuclear facilities.
We believe our previous good record in this regard reflects our determination to maintain proper health physics controls.
The subject exposure occurred during the refueling outage at Indian Point 2.
So far during this outage, there have been more than 50,000 individual entries into our radiation control area, and only this one individual's radiation exposure exceeded th,e Nuclear Regulatory Commission (NRC) quarterly limit.
In no case has the limit on annual accumulated occupational dose been exceeded.
In fact, the limit on annual accumulated occupational dose prescribed by the AEC or NRC has never been exceeded at the Indian Point plants in the 14 years of nuclear power plant operations.
As a result gof the April incident, we have instituted actions designed to prevent a similar occurrence.
Several of the corrective r
measures have been discussed in correspondence with NRC since April, 1976.
Pursuant to 10 CFR 2.201, our reply to the specific items of apparent non-compliance is presented below:
l Item 1.
"10 CFR 20.101(b) permits, in certain prescribed and restrictive circumstances, a whole body radiation exposure of an individual in a restricted area to no l
more than 3 rems per calendar quarter.
Contrary to the above, on April 5, 1976, an individual in the Reactor Vessel Sump Room, a restricted area, APPENDIX II
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received a whole body radiation exposure of 10.06 rems.
This violation constituted an occurrence related to health ~and safety.
(Civil Penalty = $4,000)"
Response
Details of this exposure incident, were related_in our letty. to you dated April 29, 197'6 a copy of which is attached hereto as Exhibit A.
Actions taken to prevent recurrence of this incident included immediate corrective action consisting of locking the access hatch to the Reactor Vessel Sump area, posting a warning sign at this entrance, partially reinserting the thimbles into the reactor vessel thereby lowering the radiation level on the first platform beneath the reactor vessel from about 600 R/hr to about 50 R/hr and placing a gamma monitor and alarm in the area to alert individuals to any increase in radiation fields above the posted levels.
Further, both the Nuclear Power Generation Department and our engineering organization undertook a review to determine if there are any other locations where the radiation levels can be significantly increased as a result of a planned or routine action at a remote location.
On the basis of this review, it has been determined that no other areas exist where the radiation levels can be ~significantly increased as a result of such operations at a APPENDIX II l
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- s remote location ~.
Our engineering organization is continuing to perform detailed design reviews of both Indian Point Units 2 and 3
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to further assure that such locations do not exist.
In addition, subsequent to transmittal of the aforementioned letter, a program was initiated and is continuing, to evaluate l
different types of personnel monitoring devices such as alarming dosimeters, " chirpers", etc. to determine if such devices could be effectively used at our facility by personnel who are required to enter many areas within the plant subject to changing radiation conditions.
Investigation of this exposure incident revealed that an inadequacy in the Maintenance Procedure for withdrawing tl$e t
in-core detector thimbles from the reactor vessel was the major cause.
This is discussed in detail in our response to Item 2 below.
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Item 2.
" 10 CFR 20.2Ol(b) requires that each licensee make or cau'se to be made such surveys as may be necessary to
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comply with the regulatory requirements specified in 10 CFR Part 20.
Also, Technical Specification 6.8.1 requires that written procedures and administrative policies shall be established, implemented and main-tained that meet or exceed the requirements and recom-mendations of Section 5.1 and 5.3 of ANSI N18.7 - 1972.
Contrary to the above, surveys adequate to as sure com-pliance with the posting and control requirements of 10 CFR 20.203 (c) (1) and to CFR 20.203 (c) (2) and to assure compliance with the radiation exposure limits of 10 CFR 20.101 were not made in that on April 5, 19,76, unidentified radiation le.vols as high as 666 R/hr existed in areas accessible to perronnel in the Reactor Vessel Sump Room.
Further, Section 5.3.2.5 of AUSI N18.7 - 1972 requires that operating and maintenance procedures contain precautions to alert the individual performing the task to those situations in which important measures should be taken early to protect personnel, including cautionary notes applicable to specific etcpc to be included in the main ho+f of a procedure.
Such precautionary notes were not included in Maintenance Procedure No. 2/3 CM-RVl/2.4 entitled
' Removal of Reactor Vessel Upper Internals and Closure S
Head.'
Had such notes been included to alert main-tenance personnel that hazardcus radiation levels would exist in withdrawing the incere thi=bles, the excessive exposure described in Item 1 above might have been avoided.
In addition, although step 14 of Maintenance Procedure 2/3 CM-RV1/2.4 required a radiation survey,
~it was not timely in that such a survey should have been made at the beginning of and during withdrawal of the incore thimbles rather than after withdrawing the thimbles.
t This violation contributed to an occurrence related to health and safety.
(Civil Penalty = $5,000) "
APPEhDIXII
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Response
As indicated in our response to Item 1, we have deter-mined that an inadequacy in Maintenance Procedure No. 2/3 CM-RVI/2.4 was the major cause of this exposure incident.
The procedure, based on information supplied by the plant designer in Plant Manual-General Operating Instructions, Fuel Handling Instructions Section F2
" Preparation for Refueling" did not contain the pre-cautionary notes as required by ANSI N18.7-1972, nor did it contain a provision for a radiation survey at any time before, during or after thimble withdrawal.
The radiation survey step (step 14) of Maintenance.
t Procedure No. 2/3 CM-RVI/2.4 was added as a result of in-house review prior to the current refueling outage.
Although some increase in radiation fields as a result of the withdrawal of the thimbles was expected, we did not anticipate levels as high as those which did occur.
This was fostered, we believe, by the absence of precautionary notes in the instructions and by the expectation that such unusually high radiation fields would be shielded from personnel access.
On the basis of these facts then, placing the radiation survey as APPENDIX II e-~~-.
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the last step in the procedure was deemed appropriate.
Because of delays in completing previous steps in the procedure the radiation survey step had not ns yet been reached at the time of the exposure incident.
The thimble removal procedure will be revised prior to its next use to require timely surveys and warn-ings for radiation protection.
In order to aid the operating staff in preventing recurrence of this item, we have revised the Station Nuclear Safety Committee (SNSC) Administrative Procedures to mandate that the radiation safety member of SNSC review every procedure for maintenance, test, operation, etc., to be performed in the controlled Area at Indian Point.
Because of the unusually high exposure rates which can exist in this area and not be bmnediately apparent, we have directly contacted the designer and the operators of all similar operating units in this country and advised them of the incident to prevent a similar occurrence at anothar site.
APPENDIX II
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Item 3.
" Technical Specification 6.11 requires that procedures for. personnel radiation protection shall be prepared consistent with the requ'irements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Pursuant to this requirement, Station Administrative i
Order (SAO) No. 105, Revision 3,
' Work Permits,' dated March 1, 1975, requires that work Permits (WP s) and Radiation Work Permits (RNPs) be issued and specifies
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the procedural steps to be followed.
Contrary to the above, SAO 105 was not adhered to on April 3, 1976, in that, (1) the Maintenance Foreman and the Health Physics Technician did not jointly present RRP 076-2-204 for the Reactor Vessel Sump Room to the Watch Foreman, which would have provided the opportunity for any required discussion of the' work to be performed to assure that the job was properly planned.
(2) the Health Physics Technician did not enter RNP No. 076-2-204 on WP 24560 and initial the WP signifying that the job was prepared from a radiation safety standpoint, (3) work Permit 24560 was issued by the Watch Foreman before he had received the required, completed RNP, (4) a com-plete job description, required to be attached to the RWP form and used as the basis for determining radiation safety requirements, was not supplied, (5) the ' Isolation S
and Protection Provided' section of WP 24560 was not stamped with the words ' Radiation Work Permit Required' and associated wording and spaces for signatures and dates, and (6) Work Permit 24560 remained in effect beyond the work shift of the person to whom it was issued and work was continued the following shift; however, neither the person to whom it was issued nor his relief signed and dated the reverse side of the WP under a heading 'Trans-fer of Work Permit' to indicate that they had discussed the work together and with the Watch Forman or General Watch Foreman, as required.
Further it was also noted that SAO 105 was not adhered to on March 31, 1976, in that RWP No. 076-2-149 was issued by an Outage Coordi-nator, a person not authorized to issue RNPs.
This violation contributed to an occurrence related to health and safety.
(Civil Penalty = $5,000)"
APPENDIX II
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Response
To prevent recurrence of such non-compliances as in parts 1-6 above, we have held a series of meetings with station personnel during which the necessity of strictly adhering to the requirements of SAO-105 was stressed.
Additionally, the follmeing steps have been taken to insure compliance with these require-ments and to improve communications among operations, maintenance and health physics organizations:
1.
Operations personnel authorized to issue Work Permits and Radiation Work Permits have been specifically reinstructed in the requirements of SAO-103.
2.
Health Physics personnel have been reinstructed 4
in the interfaces between the Work Permits and Radiation Work Permits, in particular the requirement for entering the Radiation Work Permit number on the Work Permits.
l 3.
Health Physics personnel have been directed not
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to process any Radiation Work Permits not con-taining a detailed job description either on the face of the Radiation Work Permits or attached, that is, oral descriptions are no longer acceptable.
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., 7 We are also in the process of revising SAO-105 to make it a more workable attd n.anageable document with-out sacrificing key control features.
With ' respect to the assertion that Radiation Work Permit No. 076-2-149 was issued by an unauthorized individual, we believe that the Notice of Violation is in error.
By virtue of a memorandum dated March 29, 197,6, the Plant Manager authorized the subject individual, among others, to issue Work Permits and Radiation Work Permits for the duration of the Unit No. 2 refueling outage.
Therefore, Radiation Work Permit No. 076-2-149 was issued by someone authorized to do so.
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Item 4.
" Technical Specification 6 11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shalt be approved, maintained and adhered to for all operations involving personnel radiation exposure.
This item is an infraction.
a.
Pursuant to the above requirement, Station Administrative Order No.105, Revision 3, " Work bermit," dated March 1, 1975, requires that Work Permits (WPs) and Radiation Work Permits (RWPs) be issued and followed.
Contrary to the above, SAO-105 was not adhered to on April 9, 1976, in that individuals worked in the Reactor Cavity w'ithout the protective equip-ment (respirators) required by RWP 076-2-45, and individuals worked on the 95' elevation of the Vapor containment without the protective equipment (gloves) required by RNP 076-2-87.
(Civil Penalty $1,000) "
Responde:
The re.quirements of the regulations and the importance of adhering to the requirements of Radiation Work Pennits has been discussed with the individuals involved in the above noted infraction.
- Further, the subject of adhering to Radiation Work Permits was discussed as part of $he previously mentioned meetings held with personnel working at the Station, (see page 9) and will be included as part of this year's Padiation Safety Retraining Frogram.
In addition, a daily inspection program (as discussed APPENDIX II eep-aw-e om.
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on pages 23-24 of this letter).has been instituted which focuses on, among other items, compliance with
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Radiation Work Permits.
Individuals found not comply-
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ing with the requirements of Radiation Work Permits are then subject to disciplinary action.
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1 APPENDIX tI e
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t Item 4b.
aPursuant to the above requirement, revised Controlled Area Sign-In Procedure, effective November 11, 1975, requires certain types of information to be entered on the sign-in sheet by individuals entering or leaving the Controlled Area.
Contrary to the above, during the period of April 2'5, 1976, there were more than 60 instances wherein indi-viduals failed to log the number of the RNP under which they were entering the Controlled Area.
(Civil Penalty - $1,000)"
Response
The requirement for listing the Radiation Work Pennit number when entering the controlled Area was instituted primarily as an aid to ac. cumulating exposure data relative to jobs being performed, not for direct control of individual exposures.
The approximately 60 instances wherein individuals failed to list their Radiation t
WorF Permit represent a very small fraction of the total Controlled Area entries over this same period which numbered in excess of 1700.
In reviewing the exposures attributed to these approximately 60 entries, we have determined that the intent of the sign-in procedure has not been compromised.
Nevertheless, we have taken steps to eliminate instances where Radiation Work Permit numbers are not listed.
These steps include reinstruction of the APPENDIX II
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pers,on responsible for insuring compliance with the sign-in procedure.
As a long range soiution to this problem, we 1cok toward installation of our computerized recordkeep,ing system by the end of this year.
Once installed, sign-in to the controlled Area will be via computer terminal..
Incomplete sign-in will be recognized by the computer and an alarm will sound to alert the guard and Health Physics Technician in the area.
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3 Item 4c. " Pursuant to the above requirements, General Administrative Directive RS-GAD-2, Revision 1,
' Radiological Eealth and Safety Procedures,' dated February 24, 1975, requires that
- areas be roped off and contamination control instituted when removable radioactive contamination exceeds 1,000 dpm per 100 square centimeters.
Contrary to the above, the waste evaporation room of the unit 2 PAB, an area containing removable radioactive con-tamination in excess of the above specified limit, was not roped off and contamination controls were not instituted.
(Civil Penalty - $,1,000)"
Responce-The Unit 2 PAB waste evaporator room had been pre-viously identified as a r.ontaminated area and a step-off pad had been placed at the entrance to this room.
The step-off pad and shoe cover containers were in place on April 8.
Sometime prior to the NRC inspection of April 9, 1976, in an. unauthorized action, the step-off pad and shoe cover containers were removed.
Imme-diately subsequent to the discovery of their removal, a new step-off pad and show cover containers were again placed at the entrance to this room.
It should be noted that while this one area did lack a step-off pad for a short period of time, it did not decrease i
the effectiveness of our overall contamination control program, 'that is, radioactive contamination was not found to have been brought beyond the confines of our APPENDIX II me I
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O Controlled Area during this period.
Augmented contamination control is part of the recently instituted daily inspection program described on pages 23 and 24 of this letter.
The inspector examines all ident,1fied contaminated areas encountered during the course of his-inspection in order to ensure that effective controls are being maintained.
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Item'5. "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 wi"h 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 over each individual entry.
Contrary to the above, on April 9, 1976, six high radiation areas in the Unit 2 PAB and one high radiation area in j
the Unit 1 PAB established for more than 30 days were not equipped with the specified control device and were unlocked and unattended with no positive control maintained over each individual entry.
Further, positive co" trol was not maintained over other locked high radiation areas in the Unit 2 PAB in that at least one employee, not authorized to enter such areas, had a master k'ey in his possession
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and could unlock and enter the high radiation areas withou't the authorization of plant management.
This is an infraction (Civil Penalty - $3,000) "
Response
We believe that effective control over the above entries was maintained by virtue of the training received by the pe'rsonnel who have been granted unescorted access to the Controlled Area, the direct escorting of all other personnel by.these trained individuals, and the posting at each location that alerts the individual to the radiological conditions within the area.
To assure adherence to the specific requirements of 10 CFR 20.203 (c) (2), personnel have APPENDIX II
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I been' reinstructed as to the control requirements, including locking when the areas are left unattended even for brief periods..Further, unlocked and uncon-trolled High Radiation Areas are reported as part of the daily inspection program with personnel responsible for leaving the area uncontrolled subject to disciplinary action.
In addition, operations personnel conduct a complete inspection at least once per day to ensure that all High Radiation A'reas are either locked or access is being controlled.
To improve key control in High Radiation Areas, all High Radiation Area door locks have been replaced with 5
new units and keys issued to authorized personnel.
Lists of authorized personnel are maintained by the Unit Operations Engineer.
As to the individual referred to in item 5, he was a Nuclear Plant Operator and as such was authorized to have a master key in his possession.
APPEllDIX II m
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Item 6.
"10 CFR 20.203 (c) (1) requires that each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words,
' Caution - High Radiation Area.'
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Contrary to the above, high radiation areas accessible to personnel inside the containment were not properly posted in that (1) on March 31, 1976, the Reactor Vessel
- Sump Room had radiation levels up to 150 mR/hr and was not posted as a high radiation area, (2) on April 9, 1976, the RER Heat Exchanger Room had radiation levels up to 200 mR/hr and was improperly posted as a radiation area with a notation that the radiation field was 100-150 mR/hr, and (3) on April 9, 1976, the area around the letdown valves had radiation levels up to 150 mR/hr'and was improperly posed as a radiation area with a notation that the radiation field was 150 mR/hr.
This is an infraction.
(Civil Penalty = $3,000) "
Response
We believe that our posting practices within the containment area comply with the requirements of 10 CFR 20.203 (c) (1), reasonably and practicably interpreted.
The implication of the phrase in Itbm 6, "high radiation areas accessible to personnel inside the containment", is that separate "High Radiation Areas" must be identified within larger "High Radiation Areas".
We do not believe that the regulations require such identification.
APPEi1 DIX II me
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E At Indian Point, each of the three containment buildings is considered a High Radiation Area,and its entrance is so posted.
Such des'ignation is required due to the design of the containment building which precludes controlling access to each isolated surface area within the building where the field is 100 mR/hr or higher.
When the Unit is in a shutdown condition access is controlled at the entrance to containment which is manned 24-hours a day.
Additional informational signs are posted within the containment in order to alert personnel to the presence of " hot spots", areas where high radiation' fields' exist, areas where low radiation s
fields exist (for use as rest or staging areas) and areas of high contamination or airborne radioactivity.
Moreover, the control of individual exposures on a particular job is presently based on the specific survey (and re-surveying if the duration of the job is more than one day) associated with the Radiation Work Permit covering that job.
That survey delineates the radiological conditions APPENDIX II
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g within the work area.
Thus, the informational signs provide supplementary rather than primary source of information fdr control of individual exposures.
Pending further interpretation of 10 CFR 20.203 (c) (1) relative to identifying and posting local High Radiation Areas within general High Radiation Areas, we have embarked on a program of posting those parts of the containment where Eelds exceed 100 mr/hr with " Caution HigP.*ACiation Area" signs to the fullest extent p:<.cticable.
However the identification o_f e,ach local area within containment having _a fi_ eld in excess of 100 mR/hr is sometimes not feasible due to tha very geometry of the containment building.
We very often have found it difficult to delineate the exact boundaries of such areas.
Furthermore, 1
f we have found that even with the Unit in a cold shutdown condition,the area boundaries change with time as radiation levels change.
Such was the case with respeet to part (1) of this item, where the radiation levels were indeed up to 150 mR/hr on March 31, 1976, but within a day had dropped to less than 100 mR/hr.
APPENDIX II
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Item 7.
"10 CFR 20 203 (b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words,
' Caution'- Radiation Area.'
Contrary to the above on April 9, 1976, a corridor accessible to personnel at the 15 foot level in the Unit 2 PAB' connecting the sump pump and tank rooms with the No. 21 and 22 RHR pump rooms had field radiation levels wherein an individual could receive a radiation dose of up to 20 mrem in any one hour and was not posted as a radiation area.
This is a deficien'cy:
(Civil Penalt'y - None) "
Response
At Indian Point the entire Controlled Area is desig-t nated a Radiation Area and as such all entrances to the Controlled Area are posted in accordance with the requirement of 10 CFR 20.203(b).
In addition, each
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room and cell in the Controlled Area is posted with an informational sign noting the radiological conditions l
within.
Due to changing conditions, delineati-~ the exact boundary of each local " radiation area", other than rooms and cells, often poses practical difficulties.
However, as with Item 6 above, pending further inter-pretation of 10 CFR 20.203 (b) relative to identifying and posting Radiation Areas uithin Radiation Areas, we have embarked on a program of posting those parts of the Controlled Area where individuals could receive more than 5 mrem /hr or 100 mrem / week with " Caution Radiation Area" signs to the fullest extent practicable.
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Your letter also expressed concern about the implementation of our management control system that permitted the items of non-compliance listed in the Notice of Violation to occur and requested
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a description of those actions taken or planned to improve the effectiveness of our management control systems.
It also expressed an interest in the improvements we plan to better control activities in Radiation and High Radiation Areas, and to improve communications t;
among operating, maintenance and health physics organizations performing and controlling such activities.
In order to accelerate the st engthening of the effectiveness of our control system at the working, on-the-job level we initiated the following actions:
1.
A series of employee radiation safety meetings
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was held with each of the various groups working at the Station.
The purpose of these meetings was to stress the importance of adhering to the radiological l
protection requirements as stated on the Radiation Work Permit.
In addition, a portion of each meeting was spent in general discussion of the radiation safety program during which problem areas and suggestions for improve-ment were solicited from the attendees.
2.
A formal audit program was initiated whereby an experi-enced staff member of the health physics group has been APPENDIX II
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assigned to conduct a daily inspection of the controlled Area in order to determine ccmpliance with Radiation Work Permit requirements, Station procedures and Federal and Station radiation safety rules and regulations dur-ing periods of major activ. y in the controlled Area.
This individual submits a daily report of his findings to the Manager of the organization responsible for con,
ducting the activities inspected.
A weekly summary report is also provided to the Assistant Vice President for Power Generation.
In addition, the Assistant Vice President for Fower Generation initiates independent special audits to be conducted by his qualified repre-sentative.
Reports of these audits are submitted dir-ectly to the Assistant Vice President.
Finally, our Quality Assurance and Reliability organization is con-tinuing to audit the radiation protection program at Indian Point.
3.
Additional contract Health Physics personnel were brought in to supplement the Health Physics outage force.
The addition of these Health Physics personnel has increased the health physics force by about 70 percent, has made APPENDIX II e
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Health Physics more visible and more readily accessible, and has resulted in improved communications between the
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operating, maintenance and health physics groups.
4.
The, Station Nuclear Safety Committee member representing the Radiation Safety Sub-Section is now reviewing all procedures submitted to the Station Nuclear Safety Committee for any work, operation, test, etc. in the Controlled Area.
5.
As part of the daily inspection noted in item 2 above, where individuals are found to be in violation of any of the requirements, said individuals are named in the inspection report and disciplinary action is initiated by their responsible Manager.
6.
Union officials'have started a program in paral'lel with that of Station management of stressing to employees the importance of adhering to all rules
' and regulations, in particular the requirements of the Radiation Work Permit.
7.
Our Operations force checks High Radiation Areas during s
the normal tours of the plant and completes a High Radiation Area check list at least once per day.
Further, wherever a work group is given access to a APPENDIX II w
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High Radiation Area (excluding containment) 'they are reminded by the person granting them access of their responsibility for controlling access to the Area and
' he Area when'they leave it (the entire t
for locking group) for any-reason.
8.
A major portion of this year's Radiation Safety Retrain-ing Lecture will be devoted to Radiation Work Permits their issuance,' use and the responsibilities of those individuals working under'the permits.
Your letter also requested that particular attention be given to items 2,~3, 5 and 6 in Appendix A,' which were similar to those previously found in earlier inspections.
The corrective action described above with respect to each of these items covers in detail the action taken to prevent recurrence of these items of noncompliance.
All corrective action which con Edison agreed to take as a result of those inspections has been taken.
Con Edison believes the corrective actions outlined above will prevent recurrence of the items of non-compliance outlined in your letter of June 21, 1976.
We wish to assure you of our g/ firm resolve to implement necessary actions to prevent recurrence.
In this regard, we would be pleased to meet with you'and l
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members of your staff to discuss our health physics program and especially to solicit any suggestions you may wish to make.
Sincerely, L(b k ;.v, w.s C h
Arthur Hauspurg/
t President enc:
Exhibit A Letter of April 29, 1976 e
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EXHIS/T A *
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- Consol. dated Edison Cern;tny of New Yort. Inc.
4 trwng Place. Nc.v York. N Y 10003 e
Telephone (212) 460 3819
%L April 29, 1976 Re:
Indian Point Unit No. 2
'D'ocket No. 50-247 s
Dr. Ernst Volgenau, Director-l Office of Inspection and Enforcement l
U. S. Nuclear P.egulatory Commission
,., Washington, D.
C.
20555
Dear Dr. Volgenau:
This recort is submitted to vou as recuired bv Title 10 Code of Federal Regulations, Part 20, Section 20.405 and describes a.n instance wherein the limit for whole body expo,sure in paragraph 20.101 (b) (1) was exceeded by one of our employees.
The reported exposure was 10.06 rem for the quarterly period April 1 - June 30, 1976.
His exposure for the first quarter of 1976 was 0.810 ren~.
As required by paragraph 20.403 (b) notification of this i
incident was made to,the Director, Office cf Inspection and Enforcement, Region 1, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The individual involved is a Nuclear Plant Operator assign-I ed to the Unit No. 2 Operations group.
On. Monday, April 5, 1976, he was assigned the task of determini..g lighting re-
.quiremencs in the general sump area beneath the Unit No.2 reactor vessel in preparation for installat.on of a pump in this area.
The Unit was in a cold shutdown condition, having been shutdown five (5) days earlier for a rcfueling outage.
Gamma field measurements made several hours after shutdown and again on the following day, s.howed general radiation APPEt4 DIX II n, _,ioms-m w-J
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levels in the sump area ranging from 30-150 mR/hg.
- However, between the time of the last field survey and the time the individual entered the area, the thimbles which house the fixed and movable in-core detectors had been withdrawn from the reactor vessel.
WithdEawal of the thimbles is a step required in the refueling procedure and is mechani-cally performed at the seal table at elevation 68' outside l
the crane support wal'1, an area far removed from the reactor g
sump area at the 19' elevation within the biologic'al shield wall where the exposure occurred.
Unaware that the radiation field in the area had increased considerably as a result of thimble withdrawal, the individual proceeded ~down to the sump level.
Upon reaching the sump level he checked his self-reading pocket dosimeters (C-200 and 0-500 mrem), found them off-scale, immediately left the area and reported to the
'cI"-
Health Phy' sics Office.
Upon investigation ir was determined tha.t the maximum radi-ation field to which this individual was exposed was approxi-mately 600 R/hr.
Further, based on retracing the individual's steps in identical Unit No. 3 (not yet critical), it was estimated that he spent approximately 100 seconds in the area.
Table 1 shows a summary ef this individual's cxposure. history, including the exposure attributable to this incident.
As creviously notad, it is clear that the NRC' quarterly limit as expressed in 10CFR Part 20 has been exceeded.
We view this regrettabl9 incidence of cver exposure very seriously and are taking the steps outlined below to assure that it will not recur.
Nevertheless, it is,also important tha~t this exposure be evaluated in relationship to the permissible total accumu-lated dose as also expressed in 10CFR Part 20.
This requires that an individual's total accumulated exposure be limited so as not to exceed 5 (N-18) where N is age of employee in years.
Within this limit the allowable exposure in any one year is 12 ram.
For this employee, the total permissible accumulated dose is 70 rem, whereas his actual accumulated dose is only 16.98 rem, including, the dose received in thir incident.
To assure that the employee's annual allowo.e exposure does not exceed the 12 rem limit, he w1 not be assigned to further work involving potential radiation exposure for the balance of the year.
APPENDIX II
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Ao e result of this expos.ure incident,'tho immediato correctiva
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action taken to prevent,a recurrench included locking of the access hatch, conspicuously posting a warning sign at the entrance, partial reinsertion of the thimhles into the reactor vessel thereby lcwering the radiation levels from 600 R/hr. to 50 R/hr. and placing a gamma monitor in the area to alert individuals to any increase in radiation fields above the posted levels.
9 In view of the unusually high radiation level that,can exist in this area, we are investigating longer range corrective actions for controlling personnel access to the area which could be used in addition to the controls described above.
In addition, we are reviewing the' design of Units Nos 2 and 3 and have found no similar situations whereby an operation at one location can signifigantly affe'ct radiation levels at a different location.
Finally, because of the unusually high dose-rate which can exist in this area and not be immediately apparent, we have'directly hontacted all rimilar operating units in this country and the vendor to advise them of the incident to prevent a recurrence at another site.
very truly yours, i
f g fil/
/
William.J. Cahill, Jr.
attach.
Vice President cc - Mr. James P. O'Reilly, Director Office of Inspection and Enforcement Region I (2 copies)
Mr. William F. Mcdonald, Director Office of Management Information and Program Control Exposed Individual APPENDIX II 4
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