IR 05000352/1986021
| ML20215M822 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/20/1986 |
| From: | Mark Miller, Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20215M817 | List: |
| References | |
| 50-352-86-21, NUDOCS 8611030327 | |
| Download: ML20215M822 (7) | |
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O U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-21 Docket No.
50-352 License No. NPF-39 Priority
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Category C
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station, Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted: September 16-19, 1986
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Inspectors:
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M. Miller, Radiation Sp6cialist date Y
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R. Struckmeyer, RadiatigSpecialist
'd a t'e Approved by:
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W. Pascrak, Chief, Effluents Radiation date
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Protection Section, EP&RPB Inspection Summary:
Inspection on September 16-19, 1986 (Report No. 50-352/86-21)
Areas Inspected:
Routine unannounced safety inspection of the licensee's
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radioactive waste management program including: organization and program manage-
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ment; liquid waste systems, gaseous waste systems, process control program, quality assurance audits, and previously identified items.
Results: No violations were identified.
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8611030327 861021 PDR ADOCK 05000352 O
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m Details 1.0 Persons Contacted 1.1 Licensee Personnel
- J. Doering, Operations Superintendent
- R. Dubiel, Senior Health Physicist
- W. Lorenz, Senior Health Physicist (Corporate)
- J. Wiley, Senior Chemist
- P. Duca, Technical Engineer
- M. McCabe, Radwaste Test Engineer
- J. McElwain, QA Auditor
- J. Muntz, Performance Engineer G. Murphy, Technical Support Health Physicist
- V. Warren, Test Engineer - Regulatory L. Wells, Radwaste Physicist
- J. Risteter, Health Physicist 1.2 Vendor Personnel
- J. Ferguson, Radwaste Consultant T. Grim, Quality Engineer S. Blacklock, Support Chemist
- denotes attendance at the exit interview on September 19, 1986.
2.0 Status of Previously Identified Items
(0 pen) Inspector Follow-up Item (352/84-66-06):
Ensure representative samples can be collected from the small volume line of the Post Accident Sampling System. The licensee conducted a comparison in December,1985.
However, the results were inconclusive, because most isotopes could not be identified or had uncertainties greater than fifty percent. A follow-up comparison was to be completed when more radioactive reactor coolant would t e present.
Since that time, a PASS sample had not been taken be-cause of a design problem -- alignment of the sample bottle with the delivery syringe. The licensee stated that this recurring problem would be investigated.
(Closed) Inspector Follow-up Item (352/85-26-01): Develop the following Radioactive Waste Management Controls: administrative procedure for con-duct of operations, liquid radioactive waste volume and liquid discharge goals, and qualification of the radwaste supervisor.
The licensee ade-quately addressed these concerns.
See Section 3.0 of this report for details.
(Closed) Unresolved Item (352/85-28-01):
Perform a 10 CFR 50.59 Safety Evaluation for temporary onsite radwaste storage.
The licenseecompleted a safety evaluation for storage of low level radioactive waste in the new fuel stcrage area in March, 1986 with final approval on September 19, 198.
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The inspector stated that the low level waste storage facility would be reviewed during a subsequent inspection.
(Closed) Inspector Follow-up Item (352/85-28-03): Surveillance of Unit 2 sump water. The licensee submitted a request to Engineering for a modifi-cation to install a temporary storage tank for Unit 2 sump water. During-the interim, any liquid is transferred to Unit 1 for analysis prior to discharge.
Shift Superintendent approval is also required prior to any transfer to Unit 1.
(Closed) Inspector Follow-up Item (352/85-28-04):
Control of Radwaste procedures and subsequent revisions or temporary changes. The licensee instituted administrative control for all radwaste procedures.
Controlled copies were available in the Radwaste Control Room and all revisions were current.
(Closed) Inspector Follow-up Item (352/86-02-04): Correct arithmetic errors in Startup Test results for STP 1.2, STP 1.3 and STP 34.1.
The in-spector reviewed the above procedures and verified that corrections had been made to the official test copies on January 9, 1986.
(Closed) Inspector Follow-up Item (392/86-02-05): Ensure operation of sample sink drain lines during loss Uf vacuum.
The inspector discussed with the licensee, plant modification 86-0918, which was completed on February 18, 1986. The sample sink drain line was rerouted to the rad-waste system.
It previously drained to the condensate drain tank and did not drain when vacuum was lost.
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'3.0 Radioactive Waste Organization and Prodram Controls The inspector discussed with the licensee the current matrix organization and expected changes to the line organization to strengthen the radio-active waste management program.
Funding has been budgeted for a Senior Radwaste Engineer to head the department.
In addition, a Radwaste Manual has been developed to describe the conduct of operations, position responsibilities and a summary of the governing federal and state regula-tions. The manual should be finalized by December 31, 1986. Within the scope of this review, no violations or concerns were identified. A parti-cular strength of the Radioactive Waste organization was the involvement of senior management in the enhancement of Radwaste Operations, and over-sight of all radwaste discharges. Management commitment to a water Balance Program was evident, particularlyz with the establishment of a zero release goal. Technical support was also in place to identify equip-ment problems, establish priorities for work requests and identify equip-ment improvement.
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4.0 Radioactive Waste Operations 4.1 Process Control Program The inspector verified the licensee was implementing the Process Control Program (PCP), Revision 2, dated March 1985, and Technical Specifications 6.13 and 6.15.
Radwaste operating procedures and related surveillance procedures.were also reviewed against the PCP, and against 10 CFR 61.55 and 10 CFR 61.56.
Within the scope of this review, no violations were identified. The inspector verified that the process descriptions and boundaries established in the PCP were met or exceeded.
Especially noteworthy was the licensee's extra sampling to ensure product control with regard to waste form, and verification of scaling factors through gamma analysis.
No changes to the PCP had been made.
However, the licensee plans to revise the PCP to address onsite vendor solidifica-tion and super compaction.
4.2 Liquid Waste Systems and Operations The licensee's liquid radioactive waste system was reviewed with respect to. Technical Specification 6.8, " Procedures," for' the collec-tion, transfer, concentration and limiting of liquid waste; Technical Specification 6.15 " Major Changes to Radioactive Waste Treatment Systems;" and ANSI N197-1976, "BWR Liquid Radioactive Waste Proces-sing System," for proper operation, surveillance and maintenance of the system.
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The licensee's performance in this area was determined by discussions with the Radwaste Shift Supervisor, Radwaste Operators and Radwaste Engineer; as well as plant tours including the R/W Control Room, selected waste tank and pump cubicles; and review of selected operat-ing procedures.
Within the scope of this review, no violations were identified.
However the following concerns were noted:
Recirculation times for the floor and equipment sample tanks had not been evaluated to ensure 2 to 3 tank volumes would be circu-lated prior to sampling. The licensee conducted a field evalua-tion on October 9, 1986 to determine the recommended recircula-tion times.
- Alarm Response Procedures for the Balance of Plant R/W alarm panels had not been completed.
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- Changes to systems, procedures, and the magnitude of error associated with instrumentation malfunctioning but not out-of-service, was not readily made known to the R/W operators. The licensee indicated a mechanism, such as a controlled information notice system, would be developed.
These items will be reviewed during a subsequent inspection (352/86-21-01).
4.3 Gaseous Waste Systems The inspector reviewed the licensee's air filtration system tests with regard to Technical Specifications requi mments and FSAR commit-ments. The inspector reviewed the results of the HEPA filter and charcoal adsorber in place tests, and the laboratory tests on char-coal samples, for the tests conducted as part of pre-operational testing and following start-up. Tests are required by Technical Specifications for the following systems:
Standby Gas Treatment, Reactor Enclosure Recirculation, and Control Room Emergency Fresh Air Supply. Other systems tested per FSAR commitments include the Reactor Enclosure Equipment Compartment Exhaust, SGTS room, Turbine Building Equipment Compartment Exhaust, Radwaste Common Tanks Vent, and Radwaste Equipment Compartment Exhaust.
With respect to safety-related systems, the inspector determined that both trains of each system met the Technical Specifications operabi-lity requirements, although this was achieved in several instances by replacement of the charcoal adsorbers.
Replacement was necessary in both trains of the CREFAS and train A of the RERS. Although there is no Technical Specification operability requirement for the non-safety related ventilation systems, the inspector noted that problems were experienced with the charcoal adsorbers in these systems as well.
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Specifically, the charcoal adsorbers in Train B of the REECE, Train A of the SGTS room, and the Radwaste Common Tanks Vent failed the laboratory analysis (methyl iodide penetration test).
The inspector noted that at least one train of each non-safety related system was operable, with the exception of the Radwaste Common Tanks Vent, which has only one train. The licensee stated that periodic analyses of the exhaust from this area have shown that no Technical Specification or regulatory dose limits have been ex-ceeded due to the inoperability (low efficiency) of the charcoal adsorber, and that if limits were approached, ventilation via this system would be shut down. The licensee further stated that an attempt is being made to determine the reason for these failures and possible remedies. One reason may be continued construction activi-ties at the site; the age of the charcoal may also be a contributing factor.
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The licensee intends to by pass the Turbine Enclosure Equipment Com-partment Exhaust System (TEECES) filters when plant activities are being performed that could potentially degrade the charcoal adsor-bers. Administrative controls will be used to ensure that the TEECES bypass will be limited to those periods when filtration is not re-quired to limit off-site doses. A safety evaluation for this modifi-cation has been prepared by the licensee and reviewed by the NRC.
The safety evaluation states that during periods of bypass opera-tions, station health physics personnel will perform a weekly dose assessment in accordance with the methodology and parameters in the Offsite Dose Calculation Manual, using the results of the weekly charcoal cartridge and air particulate filter samples for the North Stack effluent.
The inspector stated that the results of these weekly dose assess-ments will be reviewed in future inspections (50-352/86-21-02).
The licensee stated that there have been no event-initiated tests of safety-related ventilation systems since the plant began operating.
Such tests would be required after any structural maintenance on the HEPA filter or charcoal adsorber housings, or following painting, fire, or chemical release in any ventilation zone communicating with the system. The inspector inquired as to what mechanisms are in place to ensure that, if such an event were to occur, the appropriate testing would subsequently be carried out. The licensee stated that this would be accomplished through the use of appropriate statements in those procedures used for carrying out such maintenance and/or for coping with " emergencies" such as fires and chemical release. At the time of this inspection, a program was underway to incorporate the necessary revisions into such procedures; this program was approxi-mately 40% comp'ete.
The inspector stated that satisfactory comple-tion of this ctfort will be reviewed in a future inspection (50-352/86-21-03).
5.0 Quality Assurance Audits The inspector reviewed the Quality Assurance Division Audit Program (QADP-6, Rev. 11, May 1986), which presents requirements and guidelines for deter-mining the activities and program areas that are subject to audits and/or surveillances. All audits required by Technical Specification 6.5.2.8 are specified in QADP-6.
The inspector also reviewed selected sections of the Quality At.surance Plan, Operations Phase, Vol. III (Rev. 1, June 1986).
These sections provided additional details regarding the conduct of audits of specific areas.
The inspector reviewed several audits conducted by the Quality Assurance Division in 1985 and 1986. The purpose of this review was to determine the extent of audit coverage concerning the operation of liquid and gaseous radwaste systems. Audits reviewed included liquid and gaseous
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n effluents, chemistry and radiochemistry activities, Offsite Dose Calcula-
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tion Manual, radwaste, surveillance testing, and procedures. These audits included some coverage of radwaste systems operations, particularly in AL 86-18 S0,"" LGS Liquid / Gaseous Effluent Release and Offsite Dose Calcula-tion Manual. The inspector determined on the basis of discussions with Q.A.D. personnel that the current audit plan aid not include a specific commitment to audit radwaste _ system operations. Although audit no.
AL 86-18 50 covered this area adequately, tha lack of a specific commit-
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ment could result in inadequate covt: rage of this activity in the future.
The licensee responsed to this concern in a very timely manner, prior to the conclusion of the inspection. The licensee stated that a new audit would be added to its plan; this audit will be titled "Radwaste System Operations," and will include at least (a) operation of solid, liquid and gaseous radwaste systems, (b) radwaste control room activities, (c) docu-ment control, (d) use of o,nerator aids,- (e) training for operators, and (f) radwaste control room log book.
The licensee stated that the first such audit would be performed in June 1987, and would be done at two-year intervals after that. The inspector stated that this audit will be reviewed in a future inspection (50-352/86-21-04).
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6.0 Exit Interview
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The inspectors met with licensee representatives at the conc 1usion of the inspection on September 19, 1986. The scope and findings of the inspec-l tion were discussed at that time. At no time was written material pro-l vided to the licensee by the NRC inspectors.
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