IR 05000352/1985040

Safety Insp Rept 50-352/85-40 on 851007-11.No Violation Noted.Major Areas Inspected:Radiation Protection Program, Including Review of Licensee Action on Previously Identified Items & Internal Exposure Control

ML20209H433
Person / Time
Site:	Limerick
Issue date:	10/30/1985
From:	Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209H425	List: IR 05000352/1985040 ML20209H418
References
50-352-85-40, NUDOCS 8511110125
Download: ML20209H433 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-40 Docket No. '50-352 License No. NPF-39 Priority --

Category C Licensee: Philadelphia Electric Company

2301 Market Street Philadelphia, Pennsylvania 19101

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Facility Name: Limerick Generating Station, U' nit 1 Inspection At: Limerick, Pennsylvani Inspection-Conducted: October 7 - 11, 1985 Inspector: 9(Av.of ?l(Ll&'L>

M. Miller, Radiation Specialist

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'date-Approved by:

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W. Pasciak, Chief, BWR Radiological

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' da'te Protection Section Inspection Summary: .

Inspection on October 7 - 11, 1985 (Report No. 50-352/85-40)

Areas Inspected: Routine unannounced safety inspection of the licensee's

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radiation protection program including review of licensee action on previously identified items and internal exposure control. The inspection involved 27

. inspector hours onsite by one regionally-based inspecto Results: No violations were identifie PDR ADOCK 05000352 G- PDR l-

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DETAILS 74 1.0 Persons Contacted

[ 1^.1= Licensee Personnel

-*G. Leitch,. Plant Manager

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• . Knapp, Director, Radiation Protection Section (Corp.)

• Dubiel, Senior Health Physicist

'*J. Rubert, Quality Assurance Site Supervisor - EP

• C. Endriss, Regulatory Engineer P. Hetzner, Assistant Instructor B. Leddy, ALARA Physicist R. McBride,_ Physician Assistant

• J. McElwain, Auditor

• G. Murphy, Technical Support Health Physicist

• V. Warren, Technical Engineer - Regulatory

- Contractor Personnel-r 8. Bolger, Respiratory Protection Physicist J..Ferguson, Radwaste Consultant

• Denotes attendance at the exit meeting on October 11,_198 / Purpos U The purpose of this routine inspection was to review aspects of'the

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licensee's radiation protection program. The following elements were reviewed:

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Status of previously identified items-

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Internal exposure control

• Respiratory protection program-

• Use of engineering controls 3.0 . Status of Previously Identified Items (Closed) Inspector Follow-up Item (50-352/84-03-03):

. Revise NES 2.0, " Procedure for Specification of Qualifications of Personnel in Radiological Environmental Monitoring and Indoctrination and Training." The inspector noted revision 2 of NES 2.0 was issued to include Limerick Generating Station in the ' scope of the procedure. In

. addition, th'e inspector reviewed copies of training records which ~

-indicated cognizant personnel have been trained in accordance with NFS 2.0,. Revision .

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(Closed) Inspector Follow-up Item (50-352/84-45-13):

Complete development and implement a Respiratory Protection Program,

. including the-use of engineering controls. This item is discussed in Sections 4.1 and 4.2 of this repor (Closed) Inspector Follow-up Item (50-352/84-45-20):

Develop a Radiation Protection Plan and revise FSAR and Technical Specifi-cations to depict the Limerick Health Physics Organization. The licensee issued its Radiation Protection Plan which established a clear description of the organization and the responsibilities, goals and policies of the Radiation Protection Progra The inspector noted the FSAR and Technical Specifications had been. revised to depict the current site Radiation Pro-tection Organization and separate site Chemistry Organizatio (Closed) Inspector Follow-up. Item (50-352/84-45-21):

Define a Corporate Radiological Controls Organization. The licensee provided the inspector with a copy of the corporate Radiological Controls Organization. A procedure for interfacing with the site Radiation Protection Organization had been drafted and was in final revie (Closed) Inspector Follow-up Item _(50-352/84-71-03):

Include Unit 2 Systems for surveillance sampling, which interconnect with Unit 1. The licensee revised CH-1010, " Chemistry Sampling, Analysis and Calibration Schedule" to include sampling the following: turbine enclosure condensate pump; turbine enclosure floor drain / equipment drain; condensate pump backwash; and reactor enclosure floor drain / equipment sumps. The licensee's surveillance reports for these sample points reported no activ-it . Internal Exposure Control The Internal Exposure Control Program was reviewed against criteria contained in the following:

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10 CFR 20.103, 10 CFR 20.201, 10 CFR 20.203(d)

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Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection"

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NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials"

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ANSI Z88.2-1980, " Practices for Respiratory Protection"

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Technical Specification 6.11, " Radiation Protection Program."

4.1 Respiratory Protection Program The licensee's Respiratory Protection Program was reviewed relative

to the above criteria by:

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interviews with the Respiratory Protection Physicist and lechnical Suppcrt Health Physicist;

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discussions with the Assistant Training Instructor and cognizant- se

. personnel responsible for respiratory protection training and test fitting of respiratory protection equipment;

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discussion with the licensee's Physician Assistant responsible for performing physicals to determine medical qualification for respirator use;

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review of program documentation including Corporate Policy Statement, Radiation Protection Manual Chapter 12,-General Respirator Training (GRT) Lesson Plan, Radiation Protection Procedures, related vendor cleaning and inspection procedures ,

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and air quality test results;

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direct observation of GRT training program, fit testing and respirator selection and issuanc Within the scope of this review, no violations were identifie The inspector noted that the licensee notified NRC Region I in writing on July 31, 1985 of their intention t make allowance (i.e., assume protection factors) when estimating individual exposure. The licensee had fully established their respiratory protection program including the use of engineering controls to minimize airborne activity in work area . Based on this review of all the Respiratory Protection Program proce-dures and related contamination control procedures, the following 4, improvements should be addressed: ,

• - Ensure contamination surveys are performed prior to using supplied air system in contaminated areas;

• Require a whole body count if facial-contamination has been found;

• Ensure Senior Health Physics Technician review of Maximum Permissible Concentration (MPC) Log;

• Address prerequisite for medical qualification prior to respirator fit test;

• Address emergency entry into IDLH environments; and

• Perform inventory of respiratory protection equipment and replacement parts to meet needs of progra .-

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_J -The licenske stated these improvements would be incorporated into

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.the. respiratory protection program procedures. These items will be reviewed during a subsequent inspection (352/85-40-01).

4 2' Engineering Controls The. licensee's program to limit radioactive airborne environments was reviewed relative to the above criteria and by:

- ~* . interviews with the ALARA Physicist;

review of the respirator issuance log; and

review of program procedures and guidance including,

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.HP-814, Revision 1, "Use of Portable Ventilation s Devices"

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HP Standardized Guidance for Selection of Engineering Control Within the scope of this review, no violations were identifie .- . 5 . 0 Exit Interview

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The inspector met with the licensee representative (denoted in section 1.0) on October'11, 1985. The inspector summarized the purpose, scope and findings of the inspectio >.

At no time during the inspection _.was written material provided to the

. licensee by the'inspccto .

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