IR 05000352/1990019

Insp Repts 50-352/90-19 & 50-353/90-18 on 900709-13.No Violations Noted.Major Areas Inspected:Radiological Control Program,Including Organization & Staffing,Training & Qualification of Personnel & Applied Health Physics

ML20058M337
Person / Time
Site:	Limerick
Issue date:	08/03/1990
From:	Chawaga D, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058M334	List: IR 05000352/1990019 ML20058M331
References
50-352-90-19, 50-353-90-18, NUDOCS 9008100053
Download: ML20058M337 (6)

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U.S. NUCLEAR REGULATORY COMMISSION ,

REGION I

Report No.- 50-352/90-19 50-353/90-18 Docket-N l 50-353

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License N NPF-39 Category

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C NPF-85 C-Licensee: Philadalchia Electric Company Corrascondence Control Desk P.O. Box 195 .

Wayne, Pa 19087-0195 Facility Name: Limerick Generatina Station. Units 1 and 2 Inspection At: Limerick. Pennsylvania Inspection Period: Zulv 9 - 13. 1990

Inspector: - 2^ ^^ ^e I-LOC D. Chawaga, Radiation Specialist, Date Facilities Radiation Protection Section Approved by: AJ' (#c24 ) 'IqfC W. Pasciak, Chief, Facilities Radiation Date-Protection Section

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Insoection Summary: Inspection on July 9-13, 1990 (Report N /90-19, 50-353/90-18)

Areas Insoected: The inspection was a routine, unannounced radiological safety inspection of the licensee's radiological controls program with respect to the following elements:

. organization and staffing, training and qualification of personnel, applied health physics and general control of the

. plant's radiological environmen Results: Within the scope of this inspection, no violations were identifie ,

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DETAILS '

' Persons Contacted i

l 1.1- Philadelohia Electric Comoany-

• R. Dubiel, Superintendent Plant Services

'* G. Murphy, Senior Health Physicist R. Leddy, Radiation Protection Assistant q

• D. Neff, Licensing Engineer-

• T. Dougherty, Training Supervisor j J. Mallon, Radiological Engineer 1 S. Taylor, Radiological Engineer H D. Gray, Radiation Protection Technician i NRC Personnel M. Evans, Resident-Inspector h

• T. Kenney, Sr. Resident Inspector  :;

• L. Scholl, Resident Inspector

• Denotes attendance at the exit meetin ;

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l Purpose i

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The purpose of this inspection was to review the licensee's

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radiological controls program with respect to the following L elements:. organization and staffing, training and qualification of personnel, applied health physics an general control of the plant's radiological environment.

l oraanization and staffing

h 'The Health Physics (HP) organization at the Limerick Generating Station,is. directed by the Plant Manager through !

l the Superintendent of Plant Services. The-organization is headed by the' Senior Health Physicist (position Equivalent ,

L to the Radiation Protection Manager) who directly supervises L

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the efforts of six Health Physics Shift Supervisors, the '

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Radiological Engineering Supervisor, the Technical Support Supervisor and an Assistant Senior Health Physicis The six HP Shift Supervisors equally share the ,

responsibility for implementation of the Applied HP program i which includes direct supervision of 46 HP Technician It was-noted that two HP Technicians are assigned the full-time

responsibility of reviewing and planning maintenance activities. This interdepartmental planning effort appears

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to support both radiation protection and maintenance goals i and is viewed by the inspector as a significant program j strengt ~

The Radiological Engineering Supervisor coordinates the

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efforts of six Radiological Engineers. Each Radiological l

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_ Engineer is assigned specific areas of responsibility. Two Radiological Engineers have offices near the HP Control Point and work closely with-the Applied Health Physics- j Grou The Technical Support Supervisor directs the work of the

, : Instrumentation, Effluent Monitoring, Dosimetry, and Respiratory. Protection Physicist At the time of the inspection,'the organization was fully staffed and no weaknesses were identified by the inspector'

in this are .O' Trainina tad Qualification of Personnel  !

4 j The. inspector reviewed the program for training and j qualification of HP personnel. Several discrepancies ~were- j found between two existing station document For example, ;

the station' procedure, HP-100, " Health Physics Departmen _I Selection, Training and Qualification" requires HP 'j Technicians to have 3.4 years of experience prior to i obtaining American National Standards Institute (ANSI) :I qualification. The'"HP Training Program Plan" and current ;

station practice' allows the same ANSI qualification to be !

obtained at 3 years after initial start date. Both j procedures define programs which satisfy the Technical 1-specification requirement for qualification in accordance .l with ANSI /ANI 3.1 (1978). The inspector noted that othe .i program changes appear to strengthen the qualification j proces Five technicians progressed from Health Physics "B"

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Technician - Non-ANSI qualified (HPBN), to Health Physics "B" Technician - ANSI qualified (HPBA) since the ,!

implementation'of the HP_ Training Program Plan in October of I L

l '1989.- These technicians started work in May of 198 At j the. time of promotion to HPBA (ANSI qualified) these l technicians had more than the 3 years of experience required !

by the HP training plan but less than the 3.4 years required *

by-the station health physics procedure HP-100. Although this progression was not in accordance with the requirements ;

of HP-100, the intent of the ANSI Standard was not  ;

compromise Although no deviation from the intent of ANSI 3.1 is l apparent, the inspector noted the following areas of j

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concern: j

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I o The licensee implemented a training program plan without evaluating and modifying related station procedures for consistency.

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'o Procedure maintenance problems may exist:in other area For example, chemistry procedure'CH=1025 had -

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similar discrepancies. The licensee informed the inspector of the discrepancies in CH-1025 and'promptly implemented corrective action with regard to this specific issu l o' Although a Quality Report from April 18, 1990- ;

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identified this~ easily resolved issue, prompt corrective action was initiated ~only after NRC .

inspector identification. This inconsistency existed )

i since October 23, 198 o No formal mechanism has b(ta established to assure '

diversified experience during the three year qualification period for technicians. Therefore, assignments could be limited in scope (i.e., ,

respiratory maintenance, dosimetry processing, control point watch) and may not provide the diversified experience required for full credit'toward ANSI qualification. The licensee stated that the .

combination of the Technician Qualification Manual, written examinations and oral boards provides adequate assurance of overall abilities prior to ANSI qualification. This item will be reviewed in future inspection s o No procedure exists for guidance in review of contractor HP personnel qualification Program requirements are described in the specification written for the vendor bidding process. The inspai; tor noted that this could lead to inconsistencies in the review 4 of contractor credentials (i.e., the amount of credit allowed for Navy experience, decontamination work).

Strict compliance with well maintained procedures is an essential element of an acceptable: health physics program.

These concerns were discussed with licensee personnel during

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the inspection and at the exit meetin Licensee personnel agreed to review each issue-and implement changes provided that their evaluation indicates that. program improvements-would result. The completed analysis and the corrective actions will be reviewed during a future inspectio .0 Applied Health Physics Radiation Work Permit (RWP) and ALARA Review Process l

L The inspector reviewed several RWP packages and found them L to be complete and in accordance with station procedure The RWP procedure is lengthy and difficult to use as a reference for writing RWPs. A RWP writer's guide is being l

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developed to provide a more clear and concise reference for

, RWP writer .

-l The licensee purchased an extensive set of photographs of-plant systems and areas. These photographs are stored on laser video discs.for viewing on a computer display. The n,

system provides excellent resolution of details in many areas of the plant. The inspector considers this addition l to the licensee's'"As Low As Reasonably Achievable"-(ALARA) i program to he a valuable new resourc l Radiation Surveys Radiation surveys of the facility were reviewed by the l

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inspecto The inspector noted that the symbols used for documentation of radiological conditions on survey maps of *

L the' Limerick Generating Station differ greatly from the symbols used at the licensee's Peach Bottom Atomic PoNer Station.. consequently, radiation workers providing support -

to both stations must be able to understand both methods of-documentation. The licensee informed the inspector that efforts have been initiated to achieve commonality between practices and procedures at the two facilities. Progress in this area will be reviewed in future inspection According to the legend on the bottom of some radiological survey maps, a diamond shaped-symbol is used for indication of " general area exposure rates". The inspector reviewed several survey maps and could find no use of this symbo In practice, it appears that a circle is used to indicate

. general area dose rates. According to the survey map's legend, circles designate exposure rate readings taken at 18 inches from-a. source of radiation.- Using. circles ,

interchangeably for " general area" and "18 inch" .

measurements could make survey information less clear-to station personnel. With this minor exception, survey maps were generally found to effectively denote the radiological conditions of the plant in sufficient detai .3 Tour of the Radioloaical Controlled Area iRCA)

Several tours of the RCA were conducted by the inspecto Housekeeping practices in the RCA were generally observed to be adequate with a few areas in need of attention. On three occasions during the inspection period, the inspector observed a door connecting the maintenance shop to the RCA had been left ajar. The door was held open by the air draft exiting the turbine building. Under normal conditions, the ventilation system in the turbine building is designed to maintain a lower pressure in the turbine building than outside the RCA. However, at times during the inspection period, the ventilation system was not operating adequately

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6 i to provide the desired' pressure differentia Asia result, potentially contaminated air <could escape,to the " clean"

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maintenance shop'through the door which failed to close, j-Additionally, the door failure resulted in a minor degradation of access control and accountability-for" entries to the RCA. Communication with the-HP Department is warranted if other departments recognize conditions or tak actions which could impact the radiological control progra ' Prior to the end of the inspection period, tho' licensee I began investigation of this inciden )

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6.0' Exit Meetina A meeting was held with licensee representatives at the'end'

of this inspection on July, 13 1990.. The purpose and scope-of the inspection were reviewed and the findings of the inspection were' discusse l i

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