IR 05000352/1987014

Insp Rept 50-352/87-14 on 870601-05.No Violations Noted. Major Areas Inspected:Radiation Protection Activities During Refueling Outage,Including Selection & Training of Contractor Technicians,Control of Work & ALARA

ML20234C835
Person / Time
Site:	Limerick
Issue date:	06/25/1987
From:	Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20234C828	List: IR 05000352/1987014 ML20234C826
References
50-352-87-14, NUDOCS 8707060685
Download: ML20234C835 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-14 l

Docket N License N NPF-39 Priority -

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: June 1-5, 1987 Inspectors: t/ot% b2[ 7 T.' Dragoun( 7enior Radiation Specialist date Facilities Radiation Protection Section

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Approved by: A ff 6 /s M.'Shanbaky, Chief b/25'/87

/ ~ date Facilities Radiation Protection Section Inspection Summar_y: Inspection on June 1-5, 1987 (Report No. 50-352/87-17)

Areas Inspected: Routine unannounced safety inspection of the licensee's radiation protection activities during a refueling outage including:

selection and training of contractor HP technicians; control of work; protective clothing program; ALARA; heat stress program; and status of previously identified item Results: No violations were identifie WJ S$h" O

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1.0 Persons Contacted 1.1 Licensee Personnel

• J. Spencer, Superintendent - Plant Services M. Cassada, Director, Radiation Protection B. Bolger, Physicist - Respiratory Protection

• R. Dubiel, Senior Health Physicist

• E. Gibson, E&R/QA R. Leddy, Physicist - Plant ALARA J. Moore, QA Auditor  ;

.T. Mscisz, HP Supervisor l G. Murphy, Technical Support Health Physicist

• D. Neff, Compliance Engineer

• W. Texter, Maintenance Supervising Engineer

• R. Titolo, Applied Health Physicist 1.2 NRC Personnel

• Kelley, Senior Resident Inspector

• Attended the Exit Interview on June 5, 1987 2.0 Purpose The purpose of this routine inspection was to review outage radiation protection activities including:

Selection and Training of Contractor HP Technicians Control of Outage Work i Protective Clothing Program ALARA Heat Stress Program Status of Previously Identified Items 3.0 Selection and Training of Contractor HP Technicans The screening, selection, training and qualification of contracted HP technicians was reviewed with respect to criteria contained in:

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Technical Specification 6.3, Unit Staff Qualifications

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Technical Specifiation 6.4, Training

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ANSI /ANS 3.1 - 1978, " Selection and Training of Nuclear Power Plant Personnel"

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Station Procedure HP-100, Rev. 3, " Health Physics Department Sel ectio Training and Qualification"

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l The licensee performance relative to these criteria was determined from:

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interviews with an HP Supervisor and Training Specialist

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review of HP Tech Procedure Exam, Entrance Exam and Lesson Plan

1. 8706 and #8707, "HP Training for Incoming Contractor Technicians"

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review of training records, selected resumes, and instructor qualification Within the scope of this review no violations were observe !

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The training provided to contractor technicians was found to be comprehensive. Two full days are devoted to classroom reviews of station HP procedures with a written test each da .0 Control of Outage Work The licensees program for the control of work in radiologically hazardous ,

areas was reviewed with respect to criteria contained in: 1

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10 CFR 20, Standards for Protection Against Radiation

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10 CFR 19.12, Instructions to worker ,

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Station procedure HP-310, Radiation Work Permits '

The licensee's performance relative to these criteria was determined from:

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Observation of outage work planning meetings

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Tours of work areas

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Review of radiation work permit at control points

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Discussions with workers, control point technicians and supervisors i Within the scope of this review no violations were observe The licensee assigned overall work coordination to Senior HP Technician Senior Technicians vere assigned to the Drywell, Refuel Floor, Turbine Deck and Balance of Plant areas in the Power block. These technicians receive daily guidarce and provide status to HP Supervisor The supervisors attend daily outage planning meetings with the major work groups on site to obtain work scheduling information. This system was found to be effectiv ,

A licensee strength was noted in that the Maintenance Department had borrowed three contractor HP technicians for the duration of the outag These technicians were used for job planning and interfacing with the HP '

Department regarding maintenance wor The Maintenance Supervising Engineer stated that use of the technicians would be expanded to include post-GET training for non-nuclear maintenance workers and to incorporate ALARA into the early stages of work planning. The inspector noted that

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this is an excellent initiative by the license p

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'i 5.0 Protective Clothing Program The inspector reviewed the licensee's program for the use of protective ;

clothing (PC) to limit the spread of radioactive material and protect I workers from uptake of radioactive material. The applicable station procedures are:

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HP - 508, Personal Protective Equipment Packaging and Shipment to l Off-site Cleaning Facility,

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HP - 509, Receipt of Personal Protective Equipment from Off-site >

Foundry Facility, and 3

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HP - 510, Selection and Use of Anti-Contamination Clothin The inspector noted that some minor skin contamination events have occurred. The licensee attributes this to the selection of 100% cotton garments for fire safety. reasons. The licensee is evaluating other cloth materials to replace the current stock of PCs and provide better protection against contamination while meeting applicable fire codes. The distri- l bution, use, collection, cleaning and reuse of PC is very well controlle A dedicated crew of contractor personnel (Sechtel National) perform routine QC checks on the PC at various stages in the process under the supervision of a licensee health physicis The inspector observed that the PC laundry (Interstate Nuclear Services)

has certified a cloth bag / plastic liner combination as meeting 00T i specification 7A. The bags are used as packaging to transport the 4 contaminated PC to the laundry. Although the test report and certification appeared proper, the inspector requested the licensee to provide additional information relative to the certificatio This matter will be reviewed in a future inspectio (50-352/87-14-01)

6.0 ALARA The licensee's ALARA program performance during the outage was reviewed with respect to criteria contained in:

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10 CFR 20.1, Purpose,

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Regulatory Guides 8.8 and 8.10, and

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Station Procedures HP - 301. HP - 302, HP - 310, and A - 83 The licensee's performance relative to these criteria was determined from:

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discussions with the Physicist - Plant ALARA, )

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review of RWP's, RWP exposure entries, and exposure summary reports, and

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observation of ongoing work

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Within the scope of this' review no violations were observed. The licensee's exposure goal for the outage is low (100 person-Rem). Progress

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towards this goal is on track and is aided by low radiation levels and 1 overestimates on early outage jobs. Achieving the outage goal will assist the station in meeting its challenging annual goal of 150 person-Rem for 1987. The corporate goal for the station, which is in excess of 400 person-Rem, was determined by the inspector to be unreasonably hig .0 Heat Stress Program During the 1986 outage the inspector observed the improper use of HP protective clothing in high temperature areas of the plant. (Inspection 86-13). In January 1987 the licensee produced a draft procedure titled

" Procedure for Heat Stress Management". (Inspection 87-04). However, a heat stress program was not implemented nor was responsibility assigned for a program prior to the start of the current refueling outag During this outage two workers were overcome by heat in radiologically controlled areas and several others complained of heat stress. Heat stress conditions were caused by abnormally hot weather, shutdown of plant ventilation systems for maintenance, and use of new heavy plastic PC coverall Based on discussions with the HP and safety staff and a meeting conducted on 6/3/87 by the Assistant Plant Superintendent to review heat stress, the inspector determined that the licensee's corrective action plan is as follows:

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The plastic _ coveralls will not be used without forced air cooling or an ice ves The corporate Medical Director will issue heat stress guidelines by 6/4/87 (action complete).

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Additional ice vests will be purchased (action complete 6/5/87).

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Future outage work that may cause heat stress will be iden?ified and ;

reviewed for appropriate preventative action Recommendations will be provided to the Vice President - Nuclear regarding a heat stress progra The licensee stated that the NRC would be advised regarding management assignment of responsibility for heat stress as soon as a decision was mad This matter will be reviewed in a future inspection (87-14-02)

8.0 Status of Previously Identified Item 8.1 (Closed) NRC Temporary Instruction (25-00-03), Drywell HP controls

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during fuel movement. The licensee uses the portable shield in the transfer chute to reduce dose rates in the drywell. Administrative

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controls and precautions are written into drywell RWP's warning wcrkers not to go above the 290' elevation (top of bioshield).

Inside the drywell the entire 290' elevation is roped off with warning signs. Licensee action on this matter is satisfactor '

8.2 (Closed) Inspector Followup Item (84-45-19) ALARA program development and implementation. An ALARA program with policies procedures and a dedicated staff have been implemente .3 (Closed) Inspector Followup Item (86-02-03) Licensee to use only standard warning signs per IEN84-82. Plant postings now follow generally accepted practice .4 (Closed) Inspector Followup Item (86-13-01) Review worker heat stres Certain licensee action is complete as discussed in Section 7.0. This item is replaced by item 87-14-0 .5 (Closed) Inspector Followup Item (86-13-02) Develop procedure for radiological events review. The licensee has implemented procedure HP 101, " Radiological Awareness Reporting". For 1987, a total of 14 events have been reported. A review of these events indicates that no trend is eviden .0 Exit Interview The inspector met with the licensee representatives indicated in section 1.0 at the conclusion of the inspection on June 5, 1987. The scope and findings of the inspection were discussed at that tim l

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