ML20080B564
| ML20080B564 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/29/1983 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20080B539 | List: |
| References | |
| IP-WDH-3969, NUDOCS 8402070192 | |
| Download: ML20080B564 (3) | |
Text
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Indian Point 3 Nuclear Power Plant P.O. Box 215 Buchanan, New Wrk 10511 914 739.8200
- > NewYorkPower tsf. Authority December 29, 1983 i
IP-WDH-3969 l
Docket No. 50-286 License No. DPR-64 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
Inspection 50-286/83-20
Dear Mr. Martin:
This letter responds to your Inspection Report No. 50-286/83-20 dated November 29, 1983 and received at this office on December 1,1983.
Attachment I to this letter responds to Appendix A of your letter.
Very truly yours, 1o
/ ohn. Brona WDH:jmd
(
Resident Manager Attachment cc:
IP3 Resident Inspectors Office 8402070192 840126 PDR ADOCK 05000286 G
PDR t
Attachment I Page 1 Dactmber 29, 1983 Violation A Section 6.5.2.10.c of the Technical Specifications requires, in part, that audit reports shall be forwarded to the Senior Company of ficers concerned with nuclear facilities and to the management positions responsible for the areas audited within 30 days after completion of the audit.
Contrary to the above requirement, reports of internal audits of the environmental program for 1980 and 1982 (80-01-EAB and 83-01-EB) were not forwarded to the Senior Company officers and to the management positions responsible for the areas audited within 30 days after the completion of the audit. Audit 80-01-EAB was completed on August 29, 1980 and reported on July 23, 1981. Audit 82-01-EA has not been reported as of October 14, 1983.
Response
While it is true that IP-3 Technical Specifications Section 6.5.2.10.c requires "that audit reports shall be forwarded to the Senior Company officers.....", the section actually requires audit reports encompassed by Section 6.5.2.8 be forwarded.
When you compare Section 6.5.2.8 requirements of IP-3 and IP-2 Technical Specifications there are differences in the audit requirements between the two plants. Specifically, IP-2 Technical Specifications contain requirements for auditing the environmental surveillance program pertaining to radiological matters and implementing procedures, and conformance to provisions contained in the Environmental Technical Specifications (Appendix B) pertaining to radiological matters. These requirements were removed from IP-3 Technical Specifications with the issuance of Amendment No. 12 to the Facility Operating License, effective March 10, 1978. These changes were made because Con Edison provides the radiological environmental monitoring services for both IP-2 and IP-3 in accordance with a memorandum of understanding.
We have reviewed Con Edison's response to this finding and concur in the corrective actions being taken.
The Authority does not agree however, that this finding constitutes a violation of IP-3 Technical Specifications.
Violation B Section 5.5.1 of the Environmental Technical Specification Requirements (ETSR) requires, in part, that detailed written procedures shall be adhered to for activities involved in conducting the environmental monitoring program.
Procedure QA 400-3 requires, in part, that the department responsible for the audited activity respond within 30 days of receipt of the report.
Contrary to this requirement Nuclear Environmental Monitoring (NEM) failed to respond to audit 80-01-EAB, reported on July 23, 1981, until September 18, 1981. As
? October 14, 1983, NEM has failed to respond to audit 83-03-A which was reported on June 8, 1983.
1
Attachment I P;cge 2 December 29, 1983 Respense The discussion above applies to this finding also.
Again, we have reviewed and concur in Con Edison's response to this item but do not agree that it constitutes a violation of IP-3 Technical Specifica-tions.
Violation C Section 5.6.1.a of the ETSR requires that results of all radiological environmental samples taken shall be summarized on an annual basis. The report shall explain the reasons for missing results.
Contrary to this requirement, strontium-90 results in lake surface water were not reported in the 1980 Annual Report. Twenty-four of the required thirty-six iodine-131 results in drinking water were not reported in the 1981 Annual Report. Neither report contained explanations for the missing results.
Response
The analyses of the above two isotopes were performed and the results were available. Due to typographical / editorial errors the results were inadvertently left out of the 1980 and 1981 Annual Reports.
To corract these errors, errata sections for both reports were prepared and included with Con Edison's response to this inspection.
In the future, this report will receive a more thorough review for accuracy and completeness.
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