IR 05000352/1988012

Insp Rept 50-352/88-12 on 880509-13.No Violations Noted. Major Areas Inspected:Licensee Radiological Controls Program Including Organization & Staffing,Airborne Radioactivity Sampling & Control,Audits & Personnel Contaminations

ML20196K784
Person / Time
Site:	Limerick
Issue date:	06/23/1988
From:	Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196K773	List: IR 05000352/1988012 ML20196K769
References
50-352-88-12, NUDOCS 8807070116
Download: ML20196K784 (6)

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'U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Repurt-N /88-12 Docket N License N NPF-39 Priority --

-Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: . Limerick Generating Station Unit 1 Inspection At: Limerick, Pennsylvania Inspection Conducted: May 9-13, 1988 Inspector : by W &

T. Dragoun, Senior Rhdiation Specialist

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~date A,) proved by: h.l M 6l 23) W da'te '

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M. Shanbaky, Chief, Facilities Radiation Protection Section Inspection Summary: Inspection on May 9-13, 1988 (Report No. 50-352/88-12)

Areas Inspected: Routine, unannounced safety inspection of the licensee's radiological controls program including: organization and staf fing, airborne l radioactivity sampling and control, audits, specificity of RWP, control of contaminated tools, and personnel contamination Results: No violations were observed.

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' DETAILS'

1.0: Persons Contacted 1.1 ' Licensee-Personnel

'G.M. Leitch, Vice President, Limerick Generating Site  :.

R. W. Dubiel, Superintendent, Plant Services

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J.-A.- Devanney, HP Training Contractor r R. Leddy, Radiation Engineering Supervisor G. Murphy, Senior Health Physicist J. F. Rubert, Assistant Superintendent, Audits V. A. Warren, Test Engineer-Regulatory 1.2 NRC Personnel

, L. Scholl, Resident Inspector All of the above personnel attended the exit interview on May 17, 198 During the course of this inspection additional personnel were contacted or interviewe .0 Purpose The purpose of this routine inspection was to review the licensee's radiological controls program with respect to the following elements:

Organization and Staffing; Airborne Radioactivity Sampling and Control;

• Audits; Specificity of RWP; Control of Contaminated Tools; and

Personnel Contamination .0 Organization and Staffing The organization and staffing of the Health Physics Department was reviewed with respect to criteria contained in:

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Technical Specification 6.2, Organization;

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Technical Specification 6.1, Unit Staff Qualifications;

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ANSI Standard 3.1-1978, "Selection and Training of Nuclear Power Plant Personnel";

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Philadelphia Electric Company letter (Eugene J. Bradley) to Office of Nuclear Reactor Regulation /USNRC (Thomas E. Murley) dated November 18, 1987;

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Office of Nuclear Reactor Regulation /USNRC Letter (Steven A. Varga)

to Philadelphia Electric Company (Edward G. Bauer, Jr.) dated December 18, 1987; and *

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Station Procedure HP-100, "Health Physics Department Selection, Training and Qualification."

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Licensee performance relative to these criteria,was determined from interviews'with selected personnel and a review of se M tod record Within the scope of this review no violations were observed. The inspector noted. strengths and weaknesses'in this aret a follovs:

Several prom'otions in.the health physics department have occurred. The-Senior Health ohysicist moved up to .the Services Superintendent position, and was replaced by one of his staf The inspector determined that the

'two recently promoted supervisors, Support Health Physicist and Radiolog-ical Engineering Supervisor meet the qualification requirements for their position In general, the changes were accomolished in an orderly fashion which indicated good attention to staff development. However, the inspector noted that no supervisory training had been provided to the recent appointee The Senior Health Physicist stated that both individuals will receive one full week of initial training in June,198 .

To increase the technical knowledge of the staff, the Applied Health Physicist who supervises the HP technicians is enrolled in the "simulator certification" program. This program provides all of the training and *

l experience to become a reactor operator. This will enhance.the health physics staf f knowledge of' plant systems and operations. Staffing levels, at the current time, are adequat The licensee described the planned

. organizational changes and staff expansion to accommodate the operation of Unit 2. The new positions will be filled through promotions or with experienced new hires. The inspector noted that the changes should lead to improved performance of the health. physics program. This matter will !

be reviewed again in a future inspection after the reorganization plans are finalized and implemente A review of training and experience for responsible HP technicians found that qualification records were readily available for contracted techni-r cians. However, for house technicians only detailed computer printouts cf training courses could be produced since many were traasferred from the Peach Bottom station. Tha licensee stated that a file would be created on the site'for each house technician which wili clearly show the training '

and experience that establishes ANSI qualification. This matter will be reviewed in a future inspectio (88-12-01)

l- 4.0 Airborne Radioactivity Sampling i

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The licensee's program for measurement of airborne radioactivity and reporting of worker intake of radioactive material was reviewed with respect to criteria contained in:

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! -10CFR 20.103, Exposure of individuals to concentrations of radioactive

materials in air in restricted areas;

-10CFR 20.201, Surveys;

, -100FR 20.401, Records of surveys, radiation monitoring, and disposal;

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-10CFR 20.409, Notifications and reports to individuals;

-Station Procedure HP-214, Air Sample Analysis and Evaluation; and-Station Procedure HP-213, Airborne Activity Survey Techniques.

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

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observation of the use of- continuous air onitors and low volume air i samples in the plant; j

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review of airborne radioactivity records; '

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discussions with selected personnel; and

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review of reports to workers with recordable intake .

> : Within the scope-of this review, no violations were observe The licensee experienced some fuel cladding degradation beginning in late March,198 This problem was manifested in increased levels of airborne radioactivity in the plant and increased off gassing in the effluent stack, To trend the levels in the plant, HP supervision increased the air sampling frequencies. The levels in the plant have remained low and well below' regulatory-limit As a further check, a program to select workers at random for Whole Body Counting (WBC) was instituted. The inspector reviewed these WBC records and WBC records of workers from the recent outage. No inadequacies were noted. The. inspector found that a computer program called NUPERS is used to store and report personnel exposures and other related data. Two weaknesses were noted with NUPERS:

1)The action leve's to flag management attention are based on ANSI standards rather than NRC requirements and given as percent body burden 7ther than MPC-hour )A worker.'s qualification te wear a respirator is inoicated as an "X" in a column with no date given. Due to a lag time of several weeks in processing the NUPERS report, a qualification could lapse yet a respirator could be issued based on the outdated informatio The l licensea stated that these and other problems with NUPERS had been l

documented and that a replacement computer program is under developmen The inspector discussed the ALARA impact of continued operation with defective fuel cladding with HP supervisors. The licensee stated that several high level management meetings were scheduled within the next 1 few months to determine the actions to mitigate this proble To detect any further fuel cladding degradation, the licensee performs alpha contamination checks of chemistry sample sinks. The smears from the sink are counted for alpha in the radiochemistry laboratory. During interviews with technicians the inspector found some confusion regarding the responsibility to maintain, calfbrate and operate the alpha counter The licensee acknowledged that the situation dieveloped as a result of special arrangements between the Chemistry and HP departments during plant startup. The licensee stated that action would be taken to clearly assign the responsibilities, This matter will be resitwed in a future inspectio (88-12-02)

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.e 5.0 Audits The inspector reviewed the licensee's program for the conduct of Quality Assurance Audits with respect to criteria contained in Technical Specifi-

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cation 6.5, Review and Audit. The performance of this program was deter-mined from inte-views with the Assistant Superintendent of Operational Audits and a review of the following audit reports:

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AL87-139 HP, "LGS Health Physics Operations" conducted 9/9/87 through 11/13/87;

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AL 87-77 MEM, "LGS CRD Rebuild / Replacement" conducted 5/28/87 to 7/6/87;

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AL 87-126 HPC "LGS Chemistry / Radiochemistry Program" conducted 9/9/87 to 10/22/87;

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AL 87-145 HP "LGS Dosimetry /ALARA Program" conducted 9/14/87 to 10/14/87;

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AL 88-07 TR "LGS Craftsmen /QC Training and Requalification" conducted 1/15/88 to 2/8/88;-and

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Surveillance Check Repor t SL87-11'PL, "Health Physics, ALARA, and Use of Radiation Work Permits (RWP) During the First- LGS Refueling Outage" conducted from 6/1/87 to 8/12/87.

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The licensee's auditing program appears adequate. In a recent change the i licensee has contracted technical experts as team members to help identify areas for program improvement rather than focusing only on procedure L

complianc The inspector informed the licensee that'this new initiative l should lead to an improved auditing program. Follow-up on deficiencies, and non-compliances appears adequate and they are brought to the appropri-ate level of management for actio The inspector also discussed the results of very recent internal audits with the Senior Health Physicis No major programmatic weaknesses were reporte .0 Specificity of RWP The inspector reviewed Radiation Work Permits (RWPs) for specificity in describing the work or radiological conditions. RWPs issued last year during the first rsfueling outage and during the mini-outage in April,1988, l were reviewed. Within the scope of this re';+; , no problems were observed.

! A few questionable RWP's were adequately em '.'ned by the senior HP

! technicians who had issued the RWP. The i- , tor had no further questions.

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7.0 Control of Contamloated Tools  :

Yi Last year the licensee advised the inspector that a "hot Tool" crib would ,

be constructed to consolidate all contaminated tools on site. The inspec-tor toured the crib area and interviewed workers. Although the procedures and policies for use of the facility are available, physical construction is not complete. During the Exit Interview, the Services Superintendent

, ' stated that difficulty in procuring various hardware'had delayed construc-tion but these prcblems have been overcome. Completion and use of the facility would be accomplished in the ~ next several week i-1.0 Personnel Contaminations The Limerick station experienced a number of low level personnel contami-nations (2x to 3x normal), mostly clothing, during 1997. Since the-station is relatively clean and does not have hot pirticles, the re6 son for this was unclear. A health physicist was receatly added to the staff and charged with analyzing these events to determine root causes. During the interview, he stated that this effort is only a month old and will

require.further investigation. The inspector stated that this matter l will be reviewed in a future inspectio .0 Exit Interview i The inspector met with the personnel denoted in Section 1, on May 17, 1988, to report the scope and findings of this report ~.  !

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