ML20050A066
| ML20050A066 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/09/1977 |
| From: | Bores R, Stohr J, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A063 | List: |
| References | |
| 50-003-77-14, 50-247-77-33, 50-286-77-31, 50-3-77-14, NUDOCS 8203310058 | |
| Download: ML20050A066 (12) | |
See also: IR 05000003/1977014
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U.S. NUCLEAR REGULATORY COMI
, ION
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OFFICE OF INSPECTION AND ENFORCEMENT
77-14
Region I
77-33
j Noncs
RePart No. 77-31
- L
g W UII-
arcl0N 1 MAS NOT OBTAINED PROPRILW
50-3
cuARANCE IM ACC00 DANCE WITH 'O Cf W 2hu
Docket No. 50-247 50-226
D
C
License No.
Priority
Category
C
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Licensee:
Consolidated Edison Company of New York, Inc.
4 Irving Place
New York, New Jork 10003
Facility Name:
Indian Point Nuclear Generating Units 1, 2 and 3
Inspection at:
Indian Point Nuclear Generating Station, Buchanan, N.Y. and at the
Corporate .0ffftces of Consolidated Edison Company of New York, Inc.
Inspection condected: September 27-29 and October 12, 1977
Inspectors:
// ' 0 7' 7 7
'R.
. Bo 's, Radp3 tion Cpecialist
date signed
2 b/ne//W
//-o 9 -17
J. P. Stohr, Chiff, E&SP Section
date signed
b
2,
77 only)
//-07
77
,
J. V. Stmeter, Reactor Inspector
date signed
)
4,
// "Di-77
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Approved by:
0. P. Stohr, Ch(ef, E55F Se~ction
date signed
FF&MS Branch
Inspection Summary:
Inspection on September 27-29 and October 12, 1977 (Consolidated Report Nos.
50-3/77-14; 50-247/77-33; and 50-286/77-31)
Areas Inspected: Special, unannounced inspection of the environmental protection
program (operational phase) on September 27-29, 1977 and NRC meeting with licensee
management on October 12, 1977.
The inspection was limited to the followup of pre-
viously identified enforcement and unresolved items and i.o areas relating to these
items, including management controls for these programs; implementation of environ-
mental monitoring programs - radiological; and licensee's program for emergency
plan training.
The inspection involved 31 onsite inspector-hours by three NRC in-
spectors.
Results:
Of the three areas inspected, no items of noncompliance were identified in
Three apparent items of noncompliance (Infraction - failure to have re-
one area.
viewed and approved procedures - Detail 3.c; Infraction - failure to follow proced-
ures - Detail 3.c; Deficiency - failure to meet analytical sensitivity requirements
for I-131 in vegetation - Detail 4) were identified in two areas.
Region I Form 12
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(Rev. April 77)
9203310058 771115
DRADOCK05000g
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DETAILS
1.
Individuals Contacted
Consolidated Edison Comoany of New York, Inc. (Con Ed)
- W. Cahill, Jr. , Vice President - Licensing
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- E. Kessig, Assistant Vice President, Power Generation Operations
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- J. Jannarone, Vice President-Environmental Affairs; Chairman of
Environmental Protection Committee
- E. Sack, Law Department
E. Kelleher, Director of Biology Department
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- A. Cheifetz, Sr. Engineer, Environmental, Nuclear and Gas
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F. Norris, Alternate Secretary of the Environmental Protection
Committee (EPC)
J. Szeligowski, Past Secretary of EPC, Emissions Control Engineer
- N. Hartman, Consultant, Quality Standards and Reliability (QS&R)
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- M. Byster, Engineer, Qual:ty Assurance and Reliability (OA&R)
- T. Law, Plant Manager, Indian Point Generating Units (IP)
- J. Makepeace, Director, Technical Engineering, IP
M. Shatkouski, Training Director, IP
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G. Liebler, Sr. Engineer, Radiation Safety, IP
- L. Volpe, Supervisor, Nuclear Environmental Monitoring (NEM), IP
R. Schacklinscky, NEM Technician, IP
R. Tuttle, Manager, Biological Studies, IP
<
D. Shepard, Project Biologist, IP
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J. Higgins, Chemistry Supervisor, IP
Power Authority of the State of New York (PASNY)
- J. Blake, Director - Environmental Programs
- S. Farber, Radinlot cal Engineer
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- J. Kilduff, Assistant to Resident Manager, IP-3
J. Kelly, Radiological and Environmental Services Superintendent,
IP-3
Texas Instruments, Inc.
G. Roth, Documentation Group Leader, IP
The inspector also interviewed several other individuals of the
Con Ed and PASNY staffs.
- denotes those present at the exit interview on September 29,
1977.
- denotes those present at management meeting on October 12, 1977.
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2.
Licensee Action on Previous Inspection Findings
(0 pen)
Noncompliance (77-03-01; 77-09-01; 77-10-01):
Failure to
have properly approved procedures.
The inspector determined
through the review of selected procedures, the EPC meeting minutes
and discussions with the licensee, that the procedures identified
during the previous inspection of this area had been reviewed and
approved.
The inspector determined, however, that a group of NEM
procedures had not been obtained by the licensee and, therefore,
not reviewed and approved.
This item is, therefore a recurrent
item of noncompliance.
(77-14-01; 77-33-01; 77-31-01)
(Detail
3.c)
(0 pen) Noncompliance (77-03-02; 77-09-02; 77-10-02):
Failure to
follow procedures.
The inspector determined through discussions
with the licensee, review of program results and selective review
of the procedures, that the procedures for the collection, prepara-
tion and counting of precipitation and fallout and for soil have
been modified to reflect the changes implemented as a result the
contracting of analyses formerly performed by Con Ed to Teledyne
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Isotopes, Inc. in Westwood, New Jersey.
The inspector had no
further questions in the above areas.
With respect to the Environ-
mental Quality Control Program, Procedure NEM-A-08, Revision 2, the
inspector determined that the above procedure was revised and
approved on May 9, 1977 (NEM-AD-08, Revision 3) and required, in
part, specified audits of the NEM program and that quality control
samples, spikes, etc. to be analyzed routinely to assure the quality
of the analytical results.
The inspector determined that as of the
time of the inspection, this procedure nor its predecessor (NEM-A-
08, Revision 2) had been implemented, such that this remains an
uncorrected item of noncompliance.
(77-14-02; 77-33-02; 77-31-02)
(Detail 3.c)
(Closed)
Noncompliance (77-03-03; 77-09-03):
Failure to review
changes in procedures prior to implementation.
The inspector
determined through discussions with the licensee and contractor
personnel, selective reviews of procedure changes and review of the
EPC meeting minutes, that changes are now reviewed prior to imple-
mentation in accord with Section 5.4.B of the ETSR for Units 1 and
2.
The inspector had no further questions in this area at this
time.
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(Closed)
Noncompliance (77-10-03):
Failure to review annual
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environmental operating report.
The inspector determined through
the review of the EPC meeting minutes and discussions with the
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licensee that the 1976 annual environmental operating reports were
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reviewed by the EPC, as required.
The inspector also noted that
provisions were made in the charter of the EPC to encourage and
accommodate early review of these reports.
The inspector had no
further questions in this area at this time.
(0 pen) Noncompliance (77-03-04; 77-09-04; 77-10-04):
Failure to
report radiological environmental monitoring results in accord with
the requirements.
The inspector determined through discussions
with the licensee that the licensee has contracted the writing of
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the 1977 Annual Environmental Operating Report, Part B to a vendor.
The inspector also determined that the licensee was in the process
of supplying the vendor with prior data for the required compar-
isons.
The licensee also stated that a supplemental report
containing missing data from the 1976 report would be submitted by
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November 1,1977.
The inspector stated that while corrective
action has been initiated, this item would be considered unre-
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solved, pending the submission of the supplemental report and its
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subsequent review; along with the review of the 1977 report under
the contractual arrangement.
(77-14-03; 77-33-03; 77-31-03)
(Detail 3.d)
(Closed)
Noncompliance (77-10-05):
Failure to notify NRC of
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changes in Section 5.0 of the ETSR.
The inspector determined
through discussions with the licensee and the review of letters
submitted to the NRC, that the NRC has been informed of the current
organization and responsibilities and any changes that had been
made to Section 5.0 of the ETSR.
The inspector had no further
questions in this matter.
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(0 pen) Noncompliance (77-10-06):
Failure to document by letter
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the results of the milch animal census.
The inspector determined
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through discussions with the licensee and the review cf the letter
submitted to the NRC dated August 1,1977, that-the data submitted
was not complete, in that it contained the enumeration of the
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farms rather than the enumeration of the milch ar.imals.
The licen-
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see stated that- the latter data would be submitted by November 1,
1977.
The inspector stated that this item would be considered
unresolved, pending the reccipt and subsequent review of the supple-
mental data.
(77-31-04)
(Detail 4)
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(Closed)
Deviation (76-14-04; 76-32-04; 76-32-04):
training program not adequately documented in the form of lesson
outlines and schedules.
The inspector determined through dis-
cussions with the licensee and the review of the Indian Point
Station Training Manual, Section 14, Emergency Plan _, that the
Emergency Plan training program was now documented in the form of
lesson outlines and schedules.
The inspector stated that this item
is considered closed.
(Detail 5)
(0 pen) Unresolved Item (77-03-05; 77-09-05; 77-10-07):
Gamma
spectral analysis of water samples.
The inspector determined
through discussions with the licensee and review of the contractor
reports and procedures, that (1) since May 1.1977 all water sam-
ples were analyzed by a contractor, such that no new samples were
added to the " unresolved category" and (2) action has not yet been
taken to resolve the discrepancies in the gamma spectral analyses
for the 1976 and 1977 water samples until May 1,1977.
This item continues
to be unresolved.
(77-14-04; 77-33-04; 77-31-05)
(Detail 4)
(Closed) Unresolved Item (77-03-06; 77-09-06; 77-10-08):
Inlet
and discharge water sampling.
The inspector determined through
discussions with the licensee and his observations of the water
samplers, that the continuous water samplers at the inlet and dis-
charge sampling locations had been modified such that the water
sampled for radiological analysis was now more representative of the
total water flow at these locations.
The inspector had no further
questions in this area at this time,
(0 pen) Unresolved Item (77-10-09):
Analytical sensitivities for
Sr-89, Sr-90 and I-131 in environmental samples.
The inspector
determined through discussions with the licensee that action had
not yet been taken to obtain the necessary analytical data to ver-
ify that the minimum required sensitivities for Sr-89, Sr-90 and I-
131 have been achieved.
The inspector stated that this item re-
mains unresolved.
(77-31-06)
(Detail 4)
3.
Management Controls
a.
Changes
The inspector discussed with the licensee any changes that
were made in the organization with respect to assignment of
responsibilities or management changes with respect to the
environmental programs at the hJian Point site.
The follow-
ing changes were implemented since the previous inspection in
this area (Report 50-3/77-03; 50-247/77-09; 50-286/77-10).
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(1) Mr. t. Volpe has replaced Mr. P. Crinigan as supervisor
of the Nuclear Environmental Monitoring (NEM) program.
(2) The Supervisor - NEM now reports to Dr. A. Cheifetz,
Senior Engr. and Corporate Radiation Safety Officer, who
in turn reports to Mr. E. Kessig, Ass't V. Pres. for
Power Generation Operations, through the Division Chemist,
the Chief Chemical Engineer, and the Mgr. Operations
Services Dept. Formerly, the Supervisor-NEM reported to
Mr. R. Van Wyck, Senior Health Physist and Corporate
Radiation Safety Officer, who reported directly to Mr.
Kessig as Ass't " President for Power Generation.
(3) Mr. E. Kelleher has replaced Mr. G. Cowherd as Director,
Department of Biology, Con Ed.
(4)
Since May 1, 1977 all environmental samples requiring
radiological analyses have been analyzed by Teledyne
Isotopes, Inc., Westwood, New Jersey.
Prior to this
time, samples analyzed for H-3, gross beta activity or
gamma-emitting nuclides had been analyzed at the Indian
Point site by the NEM group.
(5)
Selected samples of environmental media are no longer
split and submitted to Eberline-Southeast Facility for
evaluation of the quality of analytical performance of
the other radiological analytical laboratories.
The inspector determined through discussions with the licensee
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and the review of the results of these changes that these
changes did not result in a decrease in the level of manage-
ment controls from the previous program.
b.
Licensee Audits
The inspector reviewed the results of the 'QSR-401 Audit 77-El
conducted on May 23-31, 1977 of the NEM program.
The inspector
determined that any item requiring correction or resolution
was documented in the report to Con Ed managenent.
Each of the
identified items were addressed by Con Ed and action was initiated
to resolve these items.
The inspector had no further questions in the above area at
this time.
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c.
Procedures
The inspector reviewed selectr:d procedures required by the
ETSR, reviewed the minutes of the Environmental Protection
Connittee (EPC) at which the various procedures were review-
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ed and approved, and discussed these procedures with the
licensee.
The inspector determined that the procedures identified dur-
ing the last inspection as not reviewed and approved by the
EPC, as required, had subsequently, received these actions.
Procedures specifically involved, included those procedures
required to implement Sections 4.1 ?. and 4.2, Environmental
Surveillance Programs of the ETSR; .he NEM procedures required
to conduct the radiological environmental sampling of media;
and selected radio-analytical procedures for environmental
media.
The inspector had no further questions in the above areas;
however, the inspector identified a number of radioanalyses
which are required by the ETSR for which the licensee did not
have copies of the employed procedures, nor were they reviewed
The specific procedures
and approved by the EPC, as required.
identified, included those for the analyses of Sr-89 and Sr-90
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in air particulates, clams / crabs, fish and soil and for the
analyses of gross beta activity in aquatic vegetation, clams /
The inspector stated that this item was in
crabs and fish.
noncompliance with Section 5.4.B of the ETSR for Units 1 and
2 and Section 5.4.2 of the ETSR for Unit 2, which requires
that the detailed procedures required for conducting the
activities of the ETSR be reviewed and approved by the EPC.
(77-14-01; 77-33-01; 77-31-01)
The inspector also determined through discussions with the
licensee and the review of selected radiological environmen-
tal media sampling procedures and available records that these
procedures had been revised to reflect the activities conducted,
One exception
and had been reviewed, approved and implemented.
identified was Procedure NEM-AD-08. Rev. 3 " Quality Control
Program," approved on May 9,1977, superseding Procedure NEM-
While the above procedure had been properly
A-08, Revision 2.
It should
reviewed and approved, it had not been implemented.
be noted that its predecessor, NEM-A-08, Revision 2 had not
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been implemented either and was so identified during the last
inspection of this area (77-03-02; 77-09-02; 77-10-02).
The
inspector stated that this item appears to be uncorrected and
is in noncompliance with Section 5.4. A of the ETSR for Units 1
and 2 and Section 5.4.1 of the ETSR for Unit 3 (77-14-02; 77-
33-02; 77-31-02).
The inspector discussed with the licensee and contractor per-
sonnel the existing control system as used by the licensee to
assure proper distribution of approved procedures and proced-
ure changes, the timely implementation of those changes and appro-
priate checks to assure that the implemented procedures had
received the required approvals prior to implementation.
The
licensee stated that this area is currently being reviewed and
some improvements will be made in this area.
The inspector also discussed with the licensee the use of a
" master list" or " master copy file" of procedures which require
review and approval by the EPC.
The licensee stated that such
a file is currently being developed and should be completed
by December 15, 1977.
The inspector had no further questions
in this area at this time.
The licensee stated that by November 1,1977, a computer pro-
gram package would be developed and implemented to aid in the
control of the Nuclear Environmental Monitoring program.
The
package would be used as a surveillance tool to assure that
all of the required sampling and analyses were performed
within the scheduled / required performance windows and would
be used to " flag" the licensee of anomalous / atypical measure-
ment results and of analytical results which do not meet the
required sensitivity levels.
The inspector had no further
questions in this area at this time.
d.
Reports
The inspector determined through discussions with the licensee
and through the review of the EPC meeting minutes, that the
1976 Annual Environmental Operating Reports, Parts A and B,
have been reviewed as required by the ETSR. The inspector also
determined that the language of the EPC Charter had been modif-
ied to encourage and accommodate the review of future reports
prior to their submittal to the NRC.
The inspector had no
further questions in this area.
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The inspector also examined the corrective actions taken by
the licensee with respect to the item of noncompliance (77-
03-04; 77-09-04; 77-10-04) relative to failure to report all
of the information required in the 1976 Annual Environmental
Operating Report, Part B - Radiological.
The inspector de-
termined through discussions with the licensee that (1) the
1977 report preparation has been contracted to a firm who has
produccd satisfactory reports in the past and (2) data missing
from the 1976 report will be submitted as a supplemental report
to the NRC by November 1, 1977.
The licensee stated that the
comparisons with past operational data and with preoperational
levels will be done in the 1977 Annual Environmental Operating
Report.
The inspector stated that until the supplemental re-
port and the 1977 reports are received and are reviewed by the
NRC relative to the required information and evaluations.
This
item is considered unresolved.
(77-14-03/ 77-33-03; 77-31-03)
4.
Nuclear Environmental Monitoring (NEM)
The inspector reviewed corrective actions and actions taken to re-
solve items identified during the last inspection of this area
(Report 50-3/77-03; 50-247/77-09; 50-286/77-10).
With respect to the documentation of the 1976 milch animal census
as required by Section 4.2.1.3 of the ETSR for Unit 3, (Item 77-10-06)
the inspector noted that documentation was submitted by a letter
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dated August 1,1977 to the NRC along with the 1977 milch animal
data.
The inspector further noted that while the ETSR required the
documentation of the number of animals with respect to their loca-
tion from the IP site, the documentation supplied indicated the
number of farms with milch animals and their locations from the site.
The inspector stated that the corrective actions to this previous
item of noncompliance would be considered unresolved until documenta-
tion is supplied for both 1976 and 1977, which enumerates the milch
animals and their locations from the site (77-31-04).
The licensee
stated that this information would be supplied by November 1,1977.
The inspector also reviewed any licensee action taken to resolve
item 77-03-05; 77-09-05; 77-10-07 relative to the licensee's gamma
spectral analyses.
The inspector determined that the only action
taken in this matter to date was the contracting of all radiological
analyses to an outside laboratory since May 1,1977.
Consequently,
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no subsequent gamma analyses fall into the unresolved category.
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With respect to the resolution of apparent ganma analysis spectral
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discrepancies of water samples from January 1976 through April
1977, the licensee stated that a) spiked water samples would be
analyzed for gamma emitters using a Marinelli breaker and then
evaporated and analyzed via the in-house procedures utilized be-
tween January 1976 and April 1977 and b) the analytical results of
those analyses performed prior to May 1977 will be compared with
those analyzed by the contractor subsequent to May 1,1977.
The
licensee stated that this action would be completed by April 1,
1978. This item remains unresolved (77-14-04; 77-33-04; 77-31-05).
The inspector examined selected environmental radioanalytical re-
sults since January, 1976 and discussed with the licensee the con-
trols and reviews performed on the data and analyses.
The inspector
determined that since January 1976 the Minimum Detectable Level (MDL)
had not been. achieved for T-131 analysis of Hudson River aquatic
vegetation nor for lake aquatic vegetation.
Section 4.2.1.1 and
Table 4.2-1 and 4.2-3 of the ETSR for Unit 3 require,in part, that
I-131 in these media be analyzed with a MDL of 0.05 pCi/g.
The
data reviewed indicated the MDLs achieved were 0.09 - 0.4 pCi/g
or larger. The inspector stated that this wa. an item of noncompli-
ance (77-31-07).
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The inspector also determined through discussions with the licensee
that action had not yet been taken to resolve item 77-10-09.
The
inspector stated that additional analytical data, including chemi-
cal yields, background count rates, counter efficiencies, sample
count rates, etc. were necessary to determine whether MDLs for
Sr-89, Sr-90 and I-131 in environmental media had been achieved.
The licensee stated that this data would be obtained from the
contractor and would be reviewed by the licensee and available for
inspection by January 1,1978. The inspector stated that this item
remains unresolved pending the review of the data by the NRC
(77-31-06).
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5.
Emergency Planning
The inspector reviewed Section 14, Emergency Plan, of the Indian
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Point Station Training Manual and determined that the Emergency
Plan training program was now documented in terms of lesson out-
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lines and schedules to correct the previously identified deviation
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(76-14-04;76-32-04;76-32-04). The inspector discussed specific
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training items with the licensee.
In this regard, the licensee
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stated that the Training Manual would be modified to reflect that
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the First Aid Teams would receive technical qualification training
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via the Red Cross Multi-Media and CPR Training and that the fire
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fighting teams members would receive initial .. formal technical
qualification training with an established technical fire fighting
program.
In addition, the licensee stated that the local service
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support training section would be modified to include Peekskill
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Memorial Hospital . The inspector stated that with these modifica-
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tions, this item is considered closed.
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6.
Unresolved Items
Unresolved items are matters about which more information is re-
quired in order to ascertain whether they are acceptable items,
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items of noncompliance, or deviations.
Unresolved items disclosed
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during the inspection are discussed in Details 3.d and 4.
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Exit Interview and Management Meeting
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On September 29, 1977, at the conclusion of the inspection, the
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inspector met with the licensee representatives indicated in Detail
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The scope and findings of this inspection, including each of
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the unresolved items and items of noncompliance were discussed.
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On October 12, 1977, Messrs. Stohr, Streeter and Bores of the.NRC:I
staff met with the licensee management representatives denoted in
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Detail 1.
The purpose of this meeting was to discuss with the licen-
see management the NRC's concern. that proper management attention
and controls be focused on the implementation of the licensee's
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environmental monitoring programs.
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At this meeting the results of the inspection were discussed along
with previously identified problems relative to these programs
and progress to date in currecting/ resolving them.
In addition,
to reaffirming the dates at which time specific actions would be
completed as given in Details 3 and 4, the licensee stated that
by December 15, 1977 the Environmental Protection Committee will
have developed a master list of all procedures required by the
ETSR, will have determined that the Master List is complete by
matching the ETSR with the corresponding procedure; and have
developed, reviewed and approved any procedures which were found
to be lacking from the Master List. The licensee further stated
that the Master List would be utilized to ascertain the current
review status of the required procedures per the ETSR.
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