IR 05000352/1986013
| ML20211M951 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/19/1986 |
| From: | Dragoun T, Shanbacky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211M917 | List: |
| References | |
| 50-352-86-13, NUDOCS 8607020459 | |
| Download: ML20211M951 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/86-13 Docket No.
50-352 License No. NPF-39 Priority Category C
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Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station, Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted: May 22 and May 27-30, 1986 Inspectors:
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(f -l?- D
. Dragoun, Radiation Specialist date Approved by:
kl h[M kn 6f Mlh M. Shanbaky, Chief," Facilities Radiation date Protection Section, EPRPB, DRSS Inspection Summary:
Inspection on May 22 and May 27-30, 1986 (Report No. 50-352/86-13).
Areas Inspected:
Routine unannounced safety inspection of the licensee's radiation protection program including:
radiation work permits, ALARA, control point operations, control of high radiation exclusion areas, and status of previously identified items.
Results: No violations were identified.
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8607020459 860620 PDR ADOCK 05000352 G
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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel J. Spencer, Superintendent - Plant Services-W. Lorenz, Senior Health Physicist J. McElwain EPQA D. Murphy, Technical Support Health Physicist R. Titolo, Applied Health Physicist V. Warren, Test Engineer 1.2 NRC Personnel E. Kelley, Resident Inspector S. Kucharski, Resident Inspector i
All personnel listed above attended the exit interview on May 30, 1986.
Other personnel were also contacted or interviewed.
2.0 Purpose The purpose of this routine. inspection was to review the licensee's radiation protection program with respect to the following elements:
Status of previously identified items Radiation Work Permits
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Control Point operation
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Control of High Radiation Exclusion Areas
Worker Heat Stress 3.0 Status of Previous _ly Identified Items 3.1 (0 pen) Inspector Follow-up Item (84-45-19) Establish an ALARA program prior to the first refueling outage.-
Implementation of an ALARA program is incomplete. Although RNG 14 establishes the corporate policy, there are no corporate implementing procedures or an ALARA manual.
This item is discussed further in Section 5.0.
3.2 (Closed) Inspector Followup Item (84-45-22): Include experience requirements in supervisory position description. Current position guides for. Health Physics Supervisors contain specific experience requirements.
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3.3 (Closed) Inspector Followup Item (84-45-24) Establish programs for special radiation surveys.
Procedure HP-200 describes performance.
of neutron and alpha surveys.
Procedure HP-310 specifies surveys to support RWP's.
Procedure HP-210 provides for various special surveys.
3.4 (Closed) Inspection Followup Item (84-45-23) Establish retraining program for Health Physics personnel.
Procedure HP-100, Section 6.11 establishes the retraining program for the professional staff.
In addition, the licensee is applying for INPO accreditation of the training program.
3.5 (Closed) Inspector Followup Item (85-40-01) Address emergency entry into IDLH environments. Procedure HP314, Section 6.1.3 requires I
verification of adequate oxygen concentration in the drywell prior i
to initial entry.
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3.6 (Closed) Inspector Followup Item (86-02-02) Establish procedure to document Radiological Incidents.
Procedure A-37, " Generation and Review of Plant Reports" was issued on April 21, 1986.
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item is discussed further in section 6.0.
l 3.7 (0 pen) Inspector Followup Item (86-02-01) Allow expedited access te north stack sample station for chemistry technicians. The licensee I
has issued modification request #919 to install a card reader lock'
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in lieu of a padlock.
Installation will be complete by the end of
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June 1986.
4.0 Radiation Work Permits (RWP)
The licensees implementation of a radiation work permit program for the outage was reviewed against criteria contained in:
Technical Specification 6.8 - Procedures and Programs
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10 CFR 19.12 - Instructions to workers
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10 CFR 20 - Standards for protection against radiation
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Station Procedure HP-310, " Radiation Work Permits"
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The licensees performance relative to these criteria was determined from:
A review of active RWP's and comparison of radiological conditions
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and protective measures.
i A review of pre-job radiation surveys, worker sign-in logs, and
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dose tracking records.
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Observation of the replacement of an Intermediate Range Monitor (IRM)
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in the reactor core from pre-job briefings through job completion.
Tours of the drywell and other work areas.
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Within the scope of this review no violations were observed. The licensee previously experienced difficulty replacing an IRM.
For this outage the procedure was changed to extend the guide tube to allow all work from the sump level rather than the CROM platform. This permitted the maintenance personnel to complete the IRM removal much quicker and thus saving expo-
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Three Health Physics technicians provided simultaneous surveys during the work. The maximum whole body exposure was 20 mR to one worker.
The pre-job briefing and the post job lessons learned debriefing were thorough.
Performance of this work has improved.
The inspector.'oted that the majority of drywell entries were made by workers signing in on a " general access" RWP.
This RWP is non-job speci-fic and references the general radiological conditions in the drywell.
The licensee stated that prior to any work an RWP request must be com-pleted. If the work to be performed will only expose workers to " general" conditions then access is granted using the general access RWP.
5.0 ALARA The licensee's implementation of an ALARA program for the outage was reviewed against criteria contained in:
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10 CFR 20.1 Purpose
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Regulatory Guides 8.8 and 8.10 Station Procedures HP-301 HP-310,- HP-311 and HP-312
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The licensee's performance relative to these criteria was determined from discussions with the ALARA Physicist and Senior Health Physicist and a review of selected records.
Within the scope of this review no violations were identified.
The-licensee is committed to the implementation of an ALARA program prior to the first refueling outage in mid-1987.
The Health Physics department has implemented a program with dedicated personnel and procedures.
How-ever, other program elements such as advance outage planning, an ALARA manual, corporate implementing procedures and assignment of accountability to various departments, coordination with engineering and maintenance groups, and ALARA training are underdeveloped or lacking.
The licensee
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was advised of these weaknesses. This matter will be reviewed again in
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a future inspectio F~
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A station exposure goal of 125 man-Rem has been established as the 1986 target by the Health Physics Department. A percentage of.this exposure has been allocated to each site department by the Health Physics Depart-ment. The goal is based on average performance at other new BWR stations.
6.0 Control Point Operations Th'e operation of the control point access to the radiation work areas was reviewed in regards:
Adequacy of Health Physics technician coverage and briefing of
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workers
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Use of RWPs and recordkeeping
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Availability of protective clothing, respirators, and radiation survey instruments
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Control of radioactive material
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Implementation of procedure HP-300 " Access Control Point Policies" Within the scope of this review no violations were observed.
The inspector noted that many personnel exiting the control area were perspiring profusely. The high temperatures in the work area and worker heat stress resulted from the lack of ventilation and spot coolers while these systems were secured for maintenance. This condition was aggravated by the requirements for protective clothing and masks. The inspector determined that the site safety personnel had perviously identified this problem and proposed a program to control worker heat stress to corpo-rate management in September 1985.
Such a program could reduce radiation exposure through increased worker efficiency and avoid improper use of protective clothing and masks in high temperature environments.
Licensee action on this matter will be reviewed in a future inspection.
(86-13-01)
The licensee issued procedure A-37," Generation and Review of Plant Reports",in response to a concern that information regarding radiological deficiencies / incidents was not documented.
The inspector noted that this procedure was generic and applicable to various station events. The licensee stated that another procedure with specific-guidance concerning radiological events will be developed. This matter will be reviewed in a future inspection (86-13-02).
A licensee strength was noted as follows:
frisking of-personnel at the drywell control point and the power block entrance is accomplished with sensitive Eberline automatic friskers.
This equipment is maintained and calibrated'by site I&C technicians using PORC approved procedures.
This system provides enhanced personnel contamination control, t
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7.0 High Radiation Exclusion Area Control The licensees program to control locked high radiation exclusion areas was reviewed with respect to criteria contained in Technical Specification 6.12.2 and station procedure HP-109, "High Radiation Area Key Control."
The licensees performance relative to these criteria was determined from:
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Interviews with the Health Physics Supervisor and Senior Health Physics technicians.
A review of records and the key log for April and May 1986
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An inspection of postings and locking devices on the following areas:
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Reactor Water Cleanup Tank Room (RWCU)
TIP Room Reactor Water Cleanup Pump Room "C" Outboard Main Steam Isolation Valve
"A" RWCU and Separation Tank Room
"B" RWCU and Separation Tank Room Pipeway 162' Elevation Room Within the scope of this review no violation was observed.
The inspector noted the following problems:
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The daily check of keys was noted in the shift technician log rather than the key log as required by procedure.
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Keys were signed out but not signed in.
The inspector verified that these keys had been returned to the key locker.
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If a key is lost a Radiol.ogical Deficiency Report is required per procedure HP101. However, this procedure does not exist.
The inspector noted that site QA performed an audit on April 14, 1986 (Report #AL-86-26-01) and found similar problems.
Therefore, these problems are licensee identified and inaccordance with 10 CFR 2, i._
violation is issued.
8.0 Exit Interview The inspector met with licensee personnel denoted in Section 1 at the conclusion of the inspection on May 30, 1986 to discuss the scope and findings.
At no time was written material provided to the licensee by the NRC inspector.
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