IR 05000352/1988004
| ML20153B916 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/22/1988 |
| From: | Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153B900 | List: |
| References | |
| 50-352-88-04, 50-352-88-4, NUDOCS 8805060112 | |
| Download: ML20153B916 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No.
50-352/88-04 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 Inspection At:
Sanatoga, Pennsylvania Inspection Conducte :
March 14-18, 1988 Inspector:
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Approved by:
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Radiation Pro ection Section,
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FRSSB, DRSS
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Inspection Summary:
Inspect on on March 14-18, 1988 (Inspection Report
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No. 50-352/88-04)
Areas Inspected:
Routine, unannounced inspection of the licensee's liquid and gaseous radioactive effluent controls program.
Results:
No violations or deviations were identified.
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DETAILS
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1.0 Persons Contacted
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During this inspection, the following licensee personnel were contacted or interviewed:
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- R. Dubiel, Superintendent, Plant Services
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- G. Murphy, Senior Health Physicist
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- M. Christinziano, Support Health Physicist
- V. Warren, Licensing
- J. Rubbert, Assistant Superintendent, QA G. Barley, Plant Supv. Chemist C. Hetrick, Support Supv. Chemist E. Frick, Chemist J. Muntz, ST Engineering K. Hunt, Radwaste
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- Denotes those individuals present at the exit interview on March 18, 1988.
2.0 -Actions on Previously Identified Findings 2.1 (Closed) Inspector Follow-up Item (50-352/86-21-01).
Licensee to establish recirculation times for tanks prior to sampling, develop alarm response procedures for Balance of Plant R/W alarm panels and initiate a means to inform personnel of changes to systems or procedures.
A field test was made on October 9, 1986 to determine tank recir-culation times. Alarm response procedures for alarm panels were recently completed; panels for radwaste were PORC approved during
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March, 1988. The PORC approval cover sheet includes a section to indicate if the change requires training. Within the chemistry, radwaste or health physics group, interdepartmental information notices are used.
These are initiated by the individual who changes the procedure.
This item is closed.
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2.2 (Closed) Inspector Follow-up Item (50-352/86-21-03).
Revise
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procedures to_ ensure tests of ventilation systems are conducted following maintenance, fire, or chemical release in any ventilation zone communicating with the system.
The licensee's Surveillance
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j Test coordinator uses a list of all procedures for event related parameters, including fire, maintenance and painting to evaluate t
whether ventilation systems have been exposed to potentially degrading conditions. This item is closed.
2.3 (Closed) Inspector Follow-up Item (50-352/88-06-02).
Licensee to document basis for use of collection efficiency factor (0.9) for charcoal cartridges.
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l The licensee provided the inspector documentation which establishes the basis for using the collection efficiency factor. The effi-ciency, over the range of sample flow rates, varies with the flow and type of cartridge but was.found greater:than 90% in all cases.
Therefore, concentration values will exhibit conservative bias.
This item is closed.
3.0 Chemistry / Radiochemistry Technical Specification 3/4.4.4, "Chemistry," establishes limits and surveillance requirements for chlorides, conductivity and pH in the Reactor Coolant System.
Technical Specification 3/4.4.5, "Specific Activity," establishes limits and surveillance requirements for radio-activity in the Reactor Coolant System.
The licensee's program to conduct surveillances and trend important parameters was reviewed.
Surveillance records related to Dose Equivalent Iodine (DEI)-131, 100/E microcuries per gram, chloride, conductivity and pH were reviewed from September 1987 to March 1988.
Regarding coolant activity, the inspector noted that the DEI values corresponded to small fractions of the 0.2 j
microcurie per gram limit, largely as a result of preconditioned barrier
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fuel.
Conductivity values generally ran less than 0.2 microsiemens per
centimeter. Administrative limits are set at conservative values well below Technical Specification limits.
The licensee uses action level
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criteria similar to BWR Owners Group guida14aae Within the chemistry group a senior chemistry technician tracks and coordinates the surveillance tests and LC0 driven tests.
Supervisory chemists demonstrated a computer-based system for maintaining chemistry data to the inspector.
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I With the scope of this review, no violations were found.
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4.0 Radioactive Effluents
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i Technical Specification 3/4.11, "Radioactive Effluents," establishes, t
in part, limiting conditions for operations and surveillance requirements for radioactive liquid and gaseous effluents.
Radioactive effluents for l
1987 and 1988 (January 1 present) were reviewed, i
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4.1 Semiannual Radioact1ve Ef fluent Release R'eport
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i The licensee reports radioactive gaseous and liquid effluents and i
solid radwaste shipments twice annually under Technical Specification 6.9, "Reports." The reports covering the first and second half of
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1987 were reviewed for errors, anomalous measurements, omissions, trends and conformance to the reporting requirements in NRC Regula-l tory Guide 1.21.
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Within the scope of this review, the inspector noted that reported gaseous radioactive releases of Sr-89 and Sr-90 were calculated from measured concentrations at levels well below lower level detection
- 1imits required by techr,1 cal specifications. These measurements were made by a contractor laboratory.
No liquid discharges were made in the first half of 1987.
- Approximately 4.4 and 1.6 curies of tritium were reportedly released
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in liquid effluents during the third and fourth quarters of 1987,
respectively.
In view of the operating history of the unit, these values appear high.
The licensee's computer staff member who is assigned to support this area changed during the reporting period and final release values
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i were hand generated for the tritium and noble gas effluents. The
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licensee will submit a supplemental report to reflect computer generated values with the next Semi-Annual Effluent Release Report.
4.2 Radioactive Liquid Effluents
Batch liquid releases for the period July to December,1987 were reviewed. Concentrations, total estimated activities, radiation monitor setpoints and dose projections were reviewed and discussed with cognizant personnel within the chemistry and health physics groups.
Sampling and analysis are performed by chemistry; health physics performs dose calculations. Within the scope of this review, monthly and quarterly dose estimates / calculations and verifications
of the Offsite Dose Calculation Manual (0DCM) were reviewed and found acceptable. The licensee is currently revising its ODCM to reflect comments in the NRC's contractor's Technical Evaluation Report (TER).
The licensee stated that the ODCM would be submitted to the Plant Operations Review Committee (PORC) in the near future and that the majority of comments in the TER were incorporated. Brief review
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of the ODCM draf t revision 5 by the inspector determined that it generally uses documented and approved methods and guidelines in
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Late sampling of the Reactor Enclosure Cooling water on July 31, 1987 was reported as Licensee Event Report 87-039. The Resident
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Inspector followed up on this event and dispositioned the matter.
Within the scope of this review, no violations were noted.
4.3 Radioactive Gaseous Effluents
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The inspector reviewed the results of the licensee's surveillances for radioactive gaseous effluents for sampling and analysis and
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calculations to demonstrate compliance with Technical Specification j
requirements for dose contribution to unrestricted areas.
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1987, offgas treatment systems effectively reduced plant emissions to very low levels as a result of deep bed charcoal / filtration of the offgas.
The inspector reviewed the licensee's performance against the following surveillance tests:
ST-5-076-810-1, "North and South Stack Monthly Noble Gas and
Tritium Sampling and Analysis" ST-5-076-815-0, "Weekly Charcoal Analysis"
ST-5-076-820-0, "Weekly Particulate Analysis"
Spot checks on various surveillances from September to December, 1987 were reviewed.
Calculations for monthly dose projections and quarterly computational model evaluations per the licensee's procedure RT-0-026-861-0, "RMMS Computational Model for Calculating Noble Gas Release Doses from Plume Exposure Pathways," were reviewed for December monthly doses
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and found acceptable.
Within the scope of this review, no violations were found.
5.0 Instrumentation Technical Specification 3/4.3.7.11 "Radioactive Liquid Effluent Moni-toring Instrumentation," and 3/4.3.7.12, "Radioactive Gaseous Effluent Monitoring Instrumentation," provide effluent monitoring instrumentation
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requirements.
Charcoal checks, source checks, calibrations and functional
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tests for the following monitors were reviewed on a sampling basis from May 30, 1986 to March 5, 1988.
Monitor Surveillance Procedure Type Test
Hot Machine Shop Vent ST-2-082-600-0 Functional Hydrogen Recombiner ST-2-057-406-1 Channel Cal.
l-Hot Machine Shop Vent Flow ST-2-026-645-0 Cal./ Functional Main Steam Line Radiation ST-2-041-621-1 Functional
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North Stack Flow Rate ST-2-026-640-0 Functional
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North Stack Flow Rate ST-2-026-440-1 Calibration i
Main Steam Line Radiation ST-2-041-421-1 Calibration North Stack Radiation ST-2-026-604-0 Functional
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Hydrogen Recombiner ST-1-058-320-1 Operability The licensee has experienced ongoing problems with the RHR Service Water Radiation Monitor due to indications of low sample flow from accumulations of corrosive materials on the pipe walls.
The Technical Specification requirement to take grab samples every eight hours has been generally observed. On August 21, 1987 the licensee failed to take this sample at
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the required frequency.
Licensee Event Report 87-026 was submitted. A
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six hour sampling frequency was administratively established to prevent recurrence. This occurrence was reviewed by the Resident Inspector and discussed in Report No. 87-21.
Failure of the Radiation Monitor associated with the Hot Machine Shop Ventilation System was reported by the licensee in LER 87-031. The resident inspector followed up this event in IR No. 87-18.
Within the scope of this review, no violations were noted.
6.0 Ventilation Systems Technical Specifications require periodic testing of the unit Standby Gas Treatment System (SGTS) for flow and operability of heaters, and the SGTS filtration systems and components are tested for removal efficiencies of FREON, DOP and methyl iodide. The inspector reviewed surveillance tests for the SGTS against Technical Specification 3/4.6.5.3 frequency require-ments and test results were found satisfactory.
Filtration system tests against Technical Specification 3/4.6.5.4,
"Reactor Enclosure Recirculation Subsystem," and 3/4.7.2, "Control Room Emergency Fresh Air System," were reviewed. Surveillance test packages for these units were found satisfactory.
Within the scope of this review, no concerns were identified.
7.0 Management Controls The inspector reviewed the licensee's management controls as they related to the effluent controls program. Within the scope of this review, the licensee demonstrated an effective program for determining when surveil-lances were due to be performed.
Each functional group has an individual assigned as a Surveillance Coordinator who is responsible for initiating surveillances, both routine and those initiated by plant conditions or
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In addition, the licensee was found conducting timely, comprehensive audits which included technically qualified individuals who assisted the Team Leader. Audit A0-87-35-50, conducted in May, 1987 encompassed the gaseous and liquid effluents program and the ODCM.
No major findings or discrepancies were found.
Within the scope of this review, no violations were noted.
8.0 Exit Interview The inspector met with licensee representatives (noted in Section 1.0)
at the conclusion of the inspection on March 18, 1987.
The inspector summarized the scope of the inspection and the inspection findings.
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