IR 05000352/1989022
| ML19354D856 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/09/1990 |
| From: | Pasciak W, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19354D855 | List: |
| References | |
| 50-352-89-22, NUDOCS 9001220273 | |
| Download: ML19354D856 (5) | |
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U.S; NUCLEAR REGULATORY COMMISSION
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REGION Ir s
Report No..50-352/89-22
- Docket No.
50-352
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License No. NPF-27 Licensee:- Philadelphia' Electric Company
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2301 Market Street:
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Philadelphia, PA 19101
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. Facility Name:' Limerick Generating Station Unit 1
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Inspection'At:
Limerick, Pennsylvania.
. Inspection Conducted: November 27 - December 1, 1989
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Inspector:
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W. Thomas 7 Rap tation ' Specialist, Fac lities
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'f Radiation Protection Section Approved lby:-
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-W.
Pasciak, Chief, Facilities Radiation.
datd-Protection Section
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Inspection Summary: Inspection on November 27'- December 1,1989 (Report Nos. 50-352/89-22.
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-Areas Inspected:.. Routine, unannounced safety inspection of the licensee's
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radiological controls program, areas reviewed included audits and appraisals,
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and1the ALARA program.
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Results: No violations.were observed, it was concluded that the radiological controls activities for Unit I are being conducted in an appropriate manner.
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h DETAILS l
1.0 Persons Contacted l '.1 Philadelphia Electric Company
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S. Baker, Radiological-Occurrence Report Coordinator
- R. Dubiel, Superintendent Plant Services
J. Fongheiser, ALARA Coordinator
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R. Leddy, Radiation Protection (RP) Assistant
- M. McCormick, Jr., Plant Manager i
J. McElwain, Superintendent, Nuclear Quality Assurance
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- G.' Murphy, Senior Health Physicist
- D. Neff, Licensing Engineer R. Shortes, R. P. Technician
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S. Taylor, R. P. Assistant
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- W. Ullrich, Limerick Site Project Manager 1.2 State of Pennsylvania i
- Ajit Bhattacharyya, Nuclear Engineer, Department of Environment.1
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Resources, Bureau of Radiation Protection
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1.3 NRC Personnel
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- M. Evans, Resident Inspector
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- L. Scholl, Resident Inspector l
- W. Thomas, Radiation Specialist, Region I i
- Denotes attendance at the exit interview on December 1, 1989.
During the course of this inspection, additional personnel were
contacted or interviewed.
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2.0 Purpose l
The purpose of this routine inspection was to review the licensee's l
radiological controls program with respect to the following elements:
l audits and appraisals, and maintaining occupational exposures ALARA.
'3.0 Audits and Appraisals The licensee has implemented a Technical Monitoring Program to supplement the auditing and inspection programs by providing oversight of processing methods, equipment, and personnel. The Technical Monitoring Program applies to operations phase activities at Peach Bottom and a
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Limerick and may be applied to non-safety related activities on a selective basis..The procedure implementing the Technical Monitoring Program is Nuclear Quality Assurance (NQA) - S Rev. 2 effective-July 1, 1989.
The following reports were reviewed:
NQA Audit LA 89027, Dosimetry, Bioassay, and Respiratory Programs.
NQA Audit LA 88505, LGS Health Physics Operations In reviewing the 1988 and 1989 audit reports, the inspector was impressed with the apparent continuing attention placed on assurance that all materials which exit the Radiologically Controlled Area (RCA) are properly
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monitored prior to removal from the RCA.
The inspector was assured that l
this effort would continue.
In the past this has been a continuing L
problem area. The two audit reports which were reviewed were comprehen-l sive and detailed, and addressed programmatic weaknesses that could
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adversely affect the quality of the radiation protection program. During a previous' inspection, the inspector indicated that for one of the audit
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- findings,. assurance that personnel exiting the RCA properly frisk all items removed from the RCA, was not fully implemented in a timely manner (within 90 days).
Full implementation of the commitment to assure that l
all-personnel properly frisk all items removed from -the RCA has been
accomplished by reduction of the number of exits from the RCA, placing friskers at the remaining exits, monitoring of the exit locations by
Health Physics personnel to assure that all items removed are monitored, and direction from the plant manager to all personnel by letter dated
. June 29, 1989 to assure that all items removed from the RCA are properly monitored.
i 4.0 Maintaining Occupational Exposures ALARA The following procedures and documents were reviewed as a part of this inspection:
- Philadelphia Electric Company Nuclear Group ALARA Manual
- HP-301 ALARA Resiew of Design Modifications
- HP-302 Request for ALARA Evaluation
- HP-311 Pre-Job Planning
- HP-312 Post Job Review
- HP-324 ALARA Job Reviews The ALARA program is sound and is considered a licensee strength. The ALARA program was discussed with several employees. The inspector concluded that they understood their role in the program and were actively involved in the program. ALARA goals have been set for the year.
Progress toward the goals is tracked on a monthly basis.
In cases involving high exposure potential, progress towards ALARA goals is posted at the plant work sit,
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The Limerick Exposure Goal was revised from 225 man-rem to 275 man-rem for 1989, to accommodate increased exposure from the in-service inspection program activities. As of November 15,-the actual exposure received totaled 250 man-rem. With the expected decrease in work activities throughout the remainder of the year, the licensee anticipates that the goal of less than 275 man-rem will be met for 1989.
If the goal is achieved this will result in a three year annual man-rem average of approximately 135 man-rem.
The inspector verified that adequate procedures have been issued to ensure implementation of the ALARA program, and that responsibilities for conduct of the ALARA program have been assigned for the following:
- A full-time ALARA coordinator
'An ALARA committee
- A corporate ALARA organization
- The plant manager i
- The radiation protection supervisor
- The health physics department
- Individual workers Procedure HP-301 provides for early review during the initial design phase for proposed design changes, plant modifications, or maintenance work. Adequate ALARA reviews have been accomplished within the past six
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months on proposed changes, modifications, and maintenance work. A checklist is a part of each ALARA package. The ALARA program includes
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on going methods to prevent build-up and to reduce the concentrations of crud in primary system piping. The ALARA program also provides for continuing review and action for chronic plant radiation problem areas and
continual tracking of jobs-in progress to assure that ALARA projections are not exceeded.
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Adequate-action levels have been established for work activities within the RCA or involving radioactive materials. A routine program exists requiring Radiation Protection Technicians and Health Physicist Assistants to physically inspect all locked high radiation gates and doors during each shift to ensure that adequate control remains in place. Adequate audits of the ALARA program are performed by members of the corporate qual.ity assurance organization stationed on-site.
Adequate ALARA training is provided during general employee training, and special training sessions are given for selected groups on an as-needed basis. The ALARA program has provisions for worker's suggestions and l
feedback.
The ALARA program receives proper review and oversight as well
as proper support from corporate and plant management. The ALARA L
coordinator has adequate training and experience to qualify for the position.
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5.0/ Exit Meetir.g
. The inspector met with' licensee representatives (denoted in Section 1 of this report) on Decemeber 1, 1989. The inspector-summarized the purpose,
. scope and findings of the inspection.
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