ML20100E987
| ML20100E987 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/23/1984 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8412060428 | |
| Download: ML20100E987 (3) | |
Text
E J2n D. O'Toole 3
vice Preudent y
Consohdated Ed: son Company of New York. Inc.
4 Irving Place. New York. NY 10003 4
Telephone (212) 460 2533 November 23, 1984 Ret Indian Point Unit No. 2 Docket No. 50-247 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.
S. Nuclear Regulatory Commission Region'I
- 631 Park Avenue King of. Prussia, Pa.
19406
Dear Mr. Martin:
This refers to I.E.
Inspection 50-245/84-17 conducted by Mr.
J.
R. White
- of your office on July 10-13, 17-20, 1984 of activities authorized by NRC License No. DPR-26~at Indian Point Unit No.
2.
Your October 24, 1984 letter' stated that it appeared that certain of our activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A.
Our response to.
the items of non-compliance is presented in Attachment A to this letter.
Should you or your staff have any questions, please contact us.
trulyyouys, Ve j
ff cc.
Senior Resident. Inspector U.
S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511 8412060428 841123 PDR ADOCK 05000247 G
/Eo(s
_ ~ _
w..
50-247/84-17
(
+
. ATTACHMENT A Response to Notice of Violation Appendix A Violation A fl0 CFR 20.201,_ " surveys",- requires the licensee to perform surveys (evaluations.of the radiation hazards. incident to the presence of radioactive materials) as necessary to comply with the regulations of
' 'this part.
Contrary to the above, on July 14, 1984, the licensee performed sampling
,of airborne radioactivity to support the work of two individuals compacting dry radioactive waste in accordance with Radiation Work Permit 8217.
Though the air sample analysis indicated the presence of alpha activity, the licensee failed to evaluate this radiation hazard and consequently failed to take prompt action to estimate personnel exposure due to. alpha or transuranic activity in accordance with 10 CFR 20.103,
" Exposure of indivduals to concentrations of radioactive materials in air in restricted areas."
This is a Severity Imvel -IV-Violation (Supplement IV).
Response
Prior to this licensee identified incident, continuous breathing zone air sampling. had been adequate to provide radiological control of baling station operations.
In this instance,' the failures of the baler door
. lock and ventilation system combined with the work practices employed at the time contributed to the incident.
Several actions were taken in inusediate response to. this incident prior to-involvement by the NRC inspector. These actions included' stopping all work associated with baling operations; notification of the Shift Radiation Protection Supervisor and Radiation Protection Manager; barring
'of the two. involved individuals from areas requiring respirators; EH&S with conducting a post-job critique by the Acting General Manager, all involved personnel; decontamination of the baling station; whole body counting of the two individuals at Indian Point 2 and at non Con Edison facilities; analysis of bioassy samples; generation of an event report s issuance of a Maintenance Work Request to repair the baler door; and initiation of isotopic / gross alpha analysis of air samples.
To prevent ' recurrence - of this incident, the following additional actions have been implemented:
Revised FH&S procedure 4 304 to require an - alarming constant air. monitor, proper ventilation, operating ' door latch, and pre-job briefings of personnel for baling operations.
4 a
. Documented instruction of personnel in baling station operations.
Rerouted ventilation exhaust to building exhaust plenum.
Depaired baler door lock.
Violation B 10 CFR 19.12, " Instructions to Workers", requires the licensee.to provide instructions to personnel. in precautions and procedures to minimize exposure to radiation and radioactive materials.
. Contrary to the above, on July 14, 1984, two individuals were directed to compact dry radioactive waste in accordance with Radiation Work Permit 8217,' but were not adequately. instructed in precautions and procedures to minimize their exposure to radiation and radioactive material.
Consequently, the individuals. conduct in the area resulted in creating an airborne radiological hazard and their unplanned intake of radioactive materials.
This is a Severity Ievel IV violation (Supplement IV).
(..
. Response
~
Con Edison agrees with the description of 'the event as stated in ' the Notice of Violation.
l-In-immediate response to' the above event, all oprations at the baling l
station were halted. - To preclude the recurrence of ' such ' an event EH&S Procedure 4.304 " Dry Active Waste -Drum Compacting Operations" was revised
[
~ to require contractor personnel to receive 'a pre-job briefing in
[
I.
accordance. with EH&S 2.203,
" Management controls for Contractor Decontamination Services." In addition, the individuals involved in the event.were reinstructed in the precautions and procedures to minimize their exposure to radiation and radioactive material.
l r
l' i.
h 4
y-ey y
g y
e,e,,
--gg--..,-,
,,,,-,-,.r.,
,,-,,,%,,..e-m,.m,,~-.-g.m,,.c,._,,m,-,,rw
,,%,7,.,ww,-y.,
,,,-v+.
g---.3 r-,,,,.e,