IR 05000003/1985001

Forwards Safety Insp Repts 50-003/85-01,50-247/85-19 & 50-286/85-17 on 850722-26.No Violations Noted

ML20135E203
Person / Time
Site:	Indian Point
Issue date:	08/22/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC.
References
NUDOCS 8509160317
Download: ML20135E203 (2)

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AUG 2 21985 I

I Docket Nos. 50-247 50-03

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Consolidated Edison Company of New York, In ATTN: Mr. Murray Selman Vice President Indian Point Station Broadway and Bleakley Avenue Buchanan, New York 10511 Gentlemen: 1 Subject: Inspection Report No. 50-03/85-01 and 50-247/85-19 i

50-286/85-17 %

A routine safety inspection was conducted by Jean A. Cioffi of this office on July 22-26,1985 at the Indian Point Station, Units 1, 2 and This j inspection examined the implementation of your radiological environmental ,

< monitoring program, which is common to all units at the Indian Point sit '

i Within the scope of'this inspection, no violations were observe ;

-No reply to this letter is required. Your cooperation with us in this matter is appreciated.

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Sincerely,

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Original Signed By * ,

Thomase T. Martin, tor

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Diffd:h l Division of Radiation Safety ,

and Safeguards

Enclosure:

NRC Region I Inspection Report Number 50-03/85-01; 50-247/85-19 50-286/85-17 i

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i 0FFICIAL RECORD COPY- CIR IP 85-19/17 - 0001. /16/85 y L

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Consolidated Edison Company.of 2 New York, In

REGION I==

50-03/85-01-

. 50-247/85-19 Report Nos. 50-286/85-17 50-03 50-247 Docket Nos.-50-286 License Nos.DPR-26 Priority Category

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New York Power Authority and Consolidated Edison of New York Facility Name: Indian Point 1, 2, and 3 Inspection At: Buchanan, New York'

Inspection Conducted: July 22-26, 1985 Inspectors: -

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- Jea)i A. .Ciof fi, Radiagf do Specialist f' date

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Approved by: ._Moharied. MMd M. Shanbaky,/hief, PWR RPS M/f/f's--

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date Inspection Summary: Inspection on July 22-26, 1985 (Combined Report N /85-01; 50-247/85-19, 50-286/85-17)

' Areas Inspected: Routine, announced inspection of-the operational radiological environmental monitoring program fo: Units 1, 2, and 3, including: status of previously identified items; management controls; selection and training of personnel; the licensee's program for_ quality' control of analytical measure-

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ments; and implementation of the radiological environmental monitoring and meteorological monitoring programs. The inspection involved 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> on-site by one region-based inspecto Results: Within the. areas inspected, no violations were identifie M gp /H m .

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DETAILS p i

1.0 Personnel Contacted  !

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• V. Lander, Radiological Health Manager, Con Edison  !

• T. Schmeiser, Acting General Manager for M. Miele, Con Edison i

• Blatt, Director, Regulatory Affairs, Con Edison  !

• B. Raskovic, Engineer, Regulatory Affairs, Con Edison [

• D. Quinn, Senior Radiological Engineer, NYPA  !

• Byster, Senior Engineer in Emergency Planning, con Edison-  !

J. Odendahl, Acting I&C Engineer, ocn Edison  :

A.~ Rosenmeyer, Field Supervisor, York Services r N. Hartmann, Consultant, Con Edison  !

L. Townsend, Senior Watch Supervisor, Con Edison *

P. Madigan, Nuclear Environmental Monitoring Supervisor, Con Edison .

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R. Schacklinscky, Nuclear Environmental Monitoring Technician, Con-Edison !

W. Robinson, Shift Senior Reactor Operator, NYPA  !

G. Hugo, Operations Engineer, Con Edison i A. Klausmann, Associate Environmental Engineer, NYPA Corporate Office !

M. Pickham, Emergency Preparedness Analyst,-NYPA  !

• H. Sager, Manager, NPQA, con Edison  ;

• J. Ellwanger, Senior Engineer, Regulatory Affairs *

• Denotes attendance at exit intervie I i

2.0 Status of Previously Identified Items

2.1 (Closed) Violation (247/83-23-01): Failure to report internal audit i results within 30 days. The inspector verified the licensee's -

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corrective actions, as stated in a letter dated December 30,.1983, and '

determined that these actions appear sufficient to prevent recurrenc .2. (Closea) Violation (247/83-23-02): Failure to respond to internal audit ,

reports within 30 days. The licensee's corrective actions, as stated in !

a letter dated December 30, 1983, and verified by the NRC inspector,  ;

appears sufficient to prevent recurrenc .3 (Closed) Violation (247/83-23-03): Failure to report Sr-90 results in-

-1980, and I-131 results in 1981 annual reports. The licensee's response

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to this violation, as stated in a letter dated December 30, 1983, is adequate to correct this deficiency, t 2.4 (0 pen) Violation (247/85-05-03): Failure to have procedure to implement i dose calculation methods of ODC The inspector reviewed Revision 4 of ;

. Procedure IPC-S-050, and noted that it has been retitled " Radioactive Gaseous and Liquid Release Calculations".- This procedure provides

- detailed methods for the required dose calculations both by computer program and by manual methods, and therefore generally meets the require-ments of Section 6.8.1 of the Technical Specifications. However, the procedure contains numerous typographical errors and erroneous references *

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to its attached tables. The latter, in particular, could lead to erroneous dose calculations. This procedure will be reviewed for correc-

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tions in a subsequent inspectio '

3.0 . Management Controls The licensee's management controls for the Radiological Environmental l Monitoring Program (REMP) were reviewed, including the assignment of responsibility, program audits, and corrective actions for the identified I

weaknesses and problem areas in the program. The REMP is common to all

units at the Indian Point sit Assignment of Responsibility

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The radiological environmental monitoring program is administered by Con Edison. The Nuclear Environmental Monitoring program is the responsibility of the Radiological Health Manager, who reports to the General Manager, Environmental Health and Safety. The Nuclear

Environmental Monitoring (NEM) Supervisor implements the program and

! directs two NEM technician The meteorological monitoring program is administered by a contractor under the direction of New York Power Authority. The meteorological monitoring program is the responsibility of the Supervisory Environ-i mental Engineer in the Environmental Programs Group at the corporate

! office in White Plains, New Yor Licensee Audits The radiological-environmental monitoring program and the meteoro-logical monitoring program is audited annually by the Con Edison Quality Assurance Group. Additional audits may be performed by New 4 York Power Authority's Radiological Environmental Services department or Quality Assurance Grou The inspector reviewed audits performed by the con Edison QA Group, of the radiological environmental monitoring program for 1983 and 1984, and the meteorologi::al monitoring program for 1984. The audits were thorough in technical review, and timely response to audit _ findings was documente .0 Selection'and Training of personnel

The licensee has established a Station Administrative Order (SAO) which clearly describes each position within the Environmental Health and Safety Organization. However, there was no delineation of reporting levels-within the Environmental Health and Safety Organization. The licensee stated that they will examine a method for clarification of the report level . - , , _

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i The Environmental Health and Safety Department has established procedures

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.for personnel selection and qualification criteria and for Nuclear Environmental Monitoring personnel duties and responsibilities. The inspector reviewed NEM personnel files, and found that all selection criteria and the documentation of required training were available and

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completed in each NEM employee's file.

No violations were identifie .0 Quality Control of Analytical Measurements

The licensee utilizes a vendor laboratory for the preparation of spiked i- samples of soil, air particulate filters, charcoal cartridges, organic I material, and water. These spiked sam;.les are sent to another vendor for j analysis along with routine samples. Approximately 10%,of all samples sent to the analytical vendor annually are spiked and split samples for quality control . -

The licensee identified a consistent anomaly in the data otitained from

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the spiked charcoal cartridges and has performed statistical tests to trend these results. The licensee believes that the difference between the activity-reported by the vendor laboratory preparing the spiked samples and the vendor used for all the environmental analyses, may be due to inadequate, but consistent, spiking techniques, and to geometric considerations of the analytical vendor's counting equiptrant. This area will be reexamined during a future inspection (50-247/85-19-02).

2 The NEM supervisor performs audits of all vendors used for environmental

- work on an annual basis. This establishes an additional means of quality assurance on.the handling and processing the environmental samples, and ensures compliance with the technical specifications.

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The vendor laboratory, used for analytical measurements of the licensee's

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I i environmental samples, participates in the EPA Interlaboratory Comparison l Program. The results of the intercomparison are published in Appendix F '

of the licensee's. Annual Radiological Environmental Operating Report. The inspector examined the intercomparison results for 1983 and 1984, and

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determined that the vendor laboratory's performance was satisfactor .0 Implementation of the Environmental Monitoring Program ,

The environmental monitoring' program was reviewed against criteria contained in: -

- 10 CFR 20.105, " Permissible levels of radiation in unrestricted areas"

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10 CFR 20.106, " Radioactivity in effluents to unrestricted areas"

- Indian Point 2 Technical Specifications, Appendix A, sections 4.11 and 6.9.1.5.

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Indian Point 3 Technical Specifications, Appendix B, sections 2.7, 2.8, 2.9, 3.7, 3.8, 3.9, 5.3.3.2. The licensee's performance related to the above criteria was determined from the-following:

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a review of the Nuclear Environmental Monitoring procedures;

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a review of the Annual Radiological Environmental Operating Reports for 1983 and 1984;

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discussions with licensee personnel;

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a review of logs and data;

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visual inspections of four offsite sampling locations.

i Direct Observation l The inspector examined selected air sampling and TLD monitoring

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stations. All stations examined were located as required by the i

Offsite Dose Calculation Manual and were operating at the time of the inspection. The licensee's method of changing air sample filters was observed to reduce sample losses and cross-contamination of the

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j filters and cartridges. Dry gas meters were maintained and cali-brated as require i

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Review of Annual Reports

The inspector reviewed the Annual Radiological Environmental Operating Reports for 1983 and 1984. The licensee has complied with

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the Technical Specifications requirements for sampling frequencies, measurements, analytical sensitivities, and reporting schedules.

I Environmental Dosimetry, The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Moni-toring Network is operated by the NRC (Region I) to provide continuous measurement of the ambient radiation levels around nuclear power

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. plants (70 sites) througnout the United State Each site is monitored by arranging approximately-30 to 50 thermoluminescent

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dosimeter (TLD) stations in two concentric rings extending to about five miles from the power plant. The monitoring results are j published in NUREG-0837 quarterl One of the purposes of this program is to serve as a basis of I comparison with similar programs conducted by individual utilities I

i which operate nuclear power plants. Therefore, five NRC TLDs are co-located with each licensee's TLD stations.

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During this inspection the monitoring results of co-located TLDs were compared and the results are listed in Table 2. Table 1 describes the NRC TLD location around the Indian Point sit All NRC exposures are normalized to a 90-day calendar quarter and reported in units of milliroentgens (mR), and uncertainties are the total uncertainty (random and systematic uncertainties). The licensee's TLD results are normalized to 91.2 days per quarter; uncertainties are determined in the same manner as the NRC TLD In general, there is good agreement between the licensee's TLDs and the NRC's data. The inspector observed in two locations, that the NRC's TLD's are mounted on a metal pole or base whereas the licensee's TLDs are Ic:ated inside a wooden box housing the air sampler and dry gas mete This difference in placement of the TLDs may have a slight effect on the results. Also, the co-located TLDs are not necessarily monitoring at the same station; a tenth of a mile apart is not unusua .0 Implementation of the Meteorological Monitoring Program The inspector examined the licensee's meteorological monitoring system, including the onsite meteorological tower, the recorder charts in the equipment house at the base of the tower, and the digital displays and recorder charts in the Units 2 and 3 control rooms. The meteorological tower is equipped with redundant wind speed and wind direction sensors at the 10 meter, 60 meter, and 122 meter elevations. Temperature sensors are also located at these elevations and measure AT between 10 meters and 60 meters, and between 10 meters and 122 meters to give the atmospheric stability clas The licensee uses a vendor to calibrate meteorological instrumentation semi-annually. The inspector reviewed the calibration procedure and a sample of calibration records. A New York Power Authority Quality Assurance audit of the calibration vendor was also reviewed, and found to be adequat Daily channel checks are performed at the meteorological equipment house for all channels. However, there is no verification of these readings in the control rooms of Units 2 and 3 on a routine basi Unit 3 has no technical specification requirement for meteorological monitoring equipment. However, licensee representatives stated that a mechanism to verify the readouts in the control room would be initiate This matter will be reviewed in a future inspection (286/85-17-01).

Unit 2 technical specifications require that meteorological monitoring instrumentation channels be operable at all times with indication of the tabulated paremeters available in the control room. (T.S. 3.15. A. )

Furthermore, the technical specifications also require a daily channel

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1 I i check of the meteorological monitoring instrumentation and states that j

? '"each meteorological monitoring instrumentation channel shall be demon- i i

strated operable" (T.S. 4.19.A) . The inspector discussed the methodology  !

for channel-checks, which should include all channel parts and components [

from the detector to all readout locations. Licensee representatives

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i stated that they felt that the daily channel checks at the meteorological l equipment house was sufficient to satisfy the requirements of the tech-  !

nical specifications. They further stated that an analysis had been per- [

formed on the . instrumentation, and it was decided that if the digital i readout failed, it would indicate no reading. However, the inspector [

, observed that the digital readout of stability class (AT) in the Unit 2 [

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control room had partially failed, in that the readout indicated erroneous l data. Furthermore, the condition of the instrument had been known since  ;

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May 7, 1985, and was not tagged out of servic j

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i In a telephone conversation with the inspector, on August 12, 1985 the  !

i licensee representative stated that they agreed that the control room .!

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instrumentation should be verified in the daily channel check. They  !

further stated a method would be instituted to verify the readouts in the  ;

control room as well as at the met towe j

. t This matter will remain unresolved pending further review by the NRC t (247/85-19-01). I

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Unresolved Item t

i i IJnresolved items are matters about which more information is required in  !

2 order to ascertain whether they are acceptable items, items of noncompli- {

J ance, or deviations. An unresolved item disclosed during this inspection  ;

, is discussed in paragraph 7.

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' T Exit Interview l

The inspector met with licensee representatives (denoted in Section 1) on I l July 26,.1985. The inspector summarized the purpose, scope, and findings l of the inspection. At no time during this inspection was written material t I

provided to the licensee by the inspecto l l i'

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Table 1 Co-Location of the TLD Stations

! NRC Station Indian Point Sta_tign Location pescription

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6 35 E, 90*, 0.5 mi Broadway lle Bleakley l 10 5 SSW, 206*, 0.9 mi. NYU Tower l

[ 30 57 N,8*, 1.9 mi Cortlandt Township Ca rage

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2 90 NE, 53*, 1.0 m Charles Point 35 79 WNW, 297*, 4.4 mi. Anthony Wayne Recreation Area l

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Table 2 Environmental Monitoring Results (mR/90 days)

TLO Station: NRC Station Number /IP Station Number Monitorina Period I 6/35 1 10/5 30/57 1 2/90 35/79 1 l I let QTR 1983 NRC i 15.5 1 .4 1 .0 1 f 16.6 2 .0 1 IP 1 t l 13.8 t .6 i NM 15.8 i nJ QTR 1983 NRC H 1 .9 I 13.9 1 i 20.4 1 N/C 18.7 i IP 1 .7 13.7 i .0 NM 16.3 1 rd QTR 1983 NRC 15.0 1 .4 1 ll 18. 4 1 .9 i l N/C l IP l 1 i .7 .8 + NM 2 .5

4th QTR 1983 NRC

18.2 1 i N/C 20.3 2 .1 1 .5 i IP P 1 .9 l 14.9 i .8 t NM 1 1 .5 l i i l 1st QTR 1984 NRC I 15.4 t .1 1 .9 1 h 17.1 1 .3 1 IP l 1 i l 11.2 1 .0 1 .7 i .7 I 2nd QTR 1984 NRC i 1 .6 l 14.0 i l 13.9 1 l N/C N/C l IP I 1 i i 14.0 1 l 13.8 1 .4 .3 1 I i l l l 3rd QTR 1984 NRC i 1 i l 16.1 1 l 15.4 i i 14.1 i .1 1 IP l 1 t .7 t .3 '. 9 .6 i  !

4th QTR 1984 NRC i 15.9 1 l 16.5 1 ll 16.4 1 .6 1 .0 1 ll IP I 1 .9 1 13.5 i .7 i .7 0.8 1 14.7 1 l l l l 1st QTR 1985 NRC i 1 i l 16.7 1 l 16.2 i .4 1 l 17.3 1 IP I 1 i l 14.4 i .2 i .2 i .8 i l (1) N/C (not compared because the NRC data were not available due to missing or damaged TLDs)

(2) NM (Not Monitored during 1983 due to earlier Tech Spec . requi rements)