IR 05000352/1993012
| ML20036C448 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/09/1993 |
| From: | Bores R, Peluso L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20036C440 | List: |
| References | |
| 50-352-93-12, 50-353-93-12, NUDOCS 9306170085 | |
| Download: ML20036C448 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-352/93-12 and 50-353/93-12 Docket Nos.
50-352 and 50-353
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License Nos.
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Licensee:
Philadelphia Electric Company
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2301 Market Street
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Philadelphia. Pennsylvania Facility Name:
Limerick Generatine Station. ~ Units 1 and 2 Inspection At:
Limerick. Pennsylvania Inspection Conducted:
May 10 - 14.1993
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/Idur N/d/93 Inspector:
<
e Laurie A. Peluso, Radiation Specialist Ifate'
Effluents Radiation Pmtection Section (ERPS)
Facilities Radiological Safety and Safeguards Branch (FRSSB)
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Appmved by:
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Rob J. Bores, Chief, Date ER
, FRSSB, Division of Radiatio 'afety and Safeguards (DRSS)
Areas Inspected: Announced inspection of the Radioactive Effluent Contml Programs including: management controls, quality assurance audits, calibration of effluent / process radiation monitoring systems, air cleaning systems, Offsite Dose Calculation Manual (ODCM), and implementation of the above prognms.
- Results: Within the areas inspected, implementation of the above pmgrams was effective.
However, one violation and one non-cited violation were identified. (See Section 3.3 of this inspection report for details.)
9306170005 930610 DR ADOCK 05000352 PDR
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Results: Within the areas inspected, implementation of the above programs-was effective.
However, one-violation and one non-cited violation were identified. (See Section 3.3 of this
' inspection report for details.)
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DETAILS
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1.0 Individuals Contacted
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1.1 Licensee Personnel J. Alben, System Engineer
- J. Bruno, System Manager, Health Physics
- K. Cenci, Radwaste Manager R. Cribb, Instmment & Controls
- J. Doering, Plant Manager i
J. DiVenanzio, Assistant Manager, Technical Support E. Frick, Radiochemist, Chemistry
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B. Graber, Radiation Engineer, Health Physics
- F. Hickey, Effluents Physicist, Health Physics l
M. Kaminski, Auditor - NQA
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K. Lally, Chemist, Chemistry G. MacNeill, Radwaste System Manager
- J. Mallon, Health Physics Support Manager J. Melaugh, Instrument & Controls
- C. O'Donnell, Senior Auditor - Nuclear Quality Assurance (NQA)
B. Payne, System Engineer
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- J. Phillabaum, Licensing Engineer
- G. Stewart, Licensing Engineer 1.2 Nuclear Reculatory Commission
- T. Easlick, Resident Inspector
- N. Perry, Senior Resident Inspector
- Denotes those present at the exit interview held on May 14, 1993.
Other licensee employees were contacted and interviewed during this inspection.
2.0 Purpose The purpose of this inspection was to review the licensee'.s ability to contful and quantify
radioactive liquid, particulate, and gaseous effluents and to implement the Offsite Dose Calculation Manual (ODCM) during both normal and emergency operations.
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'I 3.0 Management Controls
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i 3.1 Organization j
The inspector reviewed the licensee's organization and discussed with members i
of the Radiation Protection (RP) Section changes made since the last inspection.
l conducted in January 1992. The Radiation Protection Section was formerly the l'
Health Physics (HP) Section, and consisted of_ the Radiological Engineering
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Group, Technical Suppon Group, and HP Group. The supervisors of each group
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reported to the HP Manager. In April,1993, the Radiation Pmtection Section underwent personnel changes and added an RP Consultant, to whom the i
Radiological Engineering and Tecimical Suppon Supervisors report.
These supervisors repon to the RP Manager, who repons to the Plant Manager. The RP Consultant also repons to the RP Manager.
i There have also been changes in the stmeture of the Quality Division. This j
division consisted of four groups, Quality VeriGcation, Quality Assurance (QA),
j Technical Monitoring (TM), and Quality Suppon. As a result of the changes, Quality Verincation will be separated and absorbed into specific divisions, as appropriate. The QA and TM groups will be combined and absorb members i
from Quality Support i
Based on the above revier and discussions, the inspector found that the efDuent I
control program:. vca being implemented without impact from the reorganization.
3.2 Ouality Assurance Audits I
The inspector reviewed the licensee's Nuclear Quality Assurance Audit ' +>n, l
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A0407886, " LGS Liquid and Gaseous Effluent Releases /Offsite Dose Calculation Manual (ODCM)", dated November 12, 1992, as pan of the evaluation of the
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implementation of Technical SpeciGcations.
j The audit had been performed during the period of July 2 - August 19,1992 by
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members of Nuclear Quality Assurance. The audit verified that the licensee had effective control, monitoring, and reponing of radioactive ef0uents in accordance with the ODCM, Regulatory Guide 4.15, and Administrative and Implementing Procedures. The audit covered the stated objectives, utilized a knowledgeable technical specialist, and was of sufficient technical depth to assess the ef0uent control programs. The audit identified one d.:ficiency and one recommendation, neither of which were safety signincant The deficiency was corrected. The inspector reviewed the NQA Master Audit Plan from which the Liquid and i
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i Gaseous Effluent Sampling Essential Eements and Sub-Elements were used to constniet the check list to focus on the audit and noted that this document was i
very comprehensive.
3.3 Semi-Annual Effluent Release Repons The inspector reviewed the Semi-Annual Effluent Release Repons for 1992 and the second half of 1991 and determined that the licensee met the Technical Specification reponing requirements. These reports provided total released mdioactivity for liquid and gaseous effluents.
No obvious anomalous
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measurements, omissions or trends were identified.
The inspector noted that the licensee had reported in accordance with the ODCM l
reporting requirements, in the effluent release repons listed above, threc separate occurrences et radiation monitors out-of-service. Two of the occurrences, as described below, were in noncompliance with the respective ODCM action statements.
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During the review of the second part of the 1991 repon, the inspector noted that the 2B South Stack effluent sample pump became inoperable on 11/23/91 at 0830 and the 2A South Stack previously had been declared inoperable. Since both sampling skids were out-of-service, the licensee was required to take grab samples for paniculate, iodine, and noble gases at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> l
according to ODCM Control 3.3, Action Statement (b).
The iodine and paniculate sampling was initiated immediately, however, noble gas sampling was not initiated until 11/25/91 at 0725 (two days later). This constitutes an apparent violation of the ODCM requirements. (50-353/93-12-01)
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i The inspector noted that this violation was identified by the licensee, however,
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corrective actions were not completed. The inspector reviewed the licensee's i
draft partial event investigation report, written in May 1993. The licensee stated that the original "Reportability Evaluation / Event Investigation Form (RE/EIF)
was either lost or not written. The draft RE/EIF summarized root causes and proposed corrective actions. The inspector noted that corrective actions had not
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been completed by the end of this inspection on May 14,1993, one and one half
years later.
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During the review of the first part of the 1992 repod, the inspector noted that the Unit 1 Service Water Radiation Monitoring System (RMS) was declared out-of-l service. The monitor was out of service for longer than thirty (30) days due to
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a defective pre-amplifier. Appropriate sampling was performed more often than
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the required 8-hour frequency. The monitor was placed in service on 7/17/92.
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The ODCM required actions were taken for this occurrence and the inspector had
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no funher questions reganting this event.
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During the review of the second half of the 1992 repon, the inspector noted that the Unit 1 Service Water Radiation Monitoring System (RMS) was declamd inoperable. The ODCM Control 3.2, Action Statement (b) requires, in pan, that grab samples be taken and analyzed for radioactivity by gamma isotopic analysis
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at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The chemistry technician was notined by Operations
that the RMS was declared out-of-service. The chemistry technician took an
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initial sample and analyzed it as required. One hour later, the technician notified
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Operations that the activity of the sample was less than the lower limits of detection. The technician was apparently unaware that the monitor remained in l
the inoperable status and therefore, did not take the next 8-hour sample as l
requimd. This constitutes noncompliance with the ODCM requirements. The j
inspector reviewed the licensee's Reponability Evaluation / Event Investigation i
Form (RE/EIF), which provides a summary of the event, root causes, and
corrective actions.
The root cause of this incident was documented as a
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miscommunication between the Operations and Chemistry Departments. The l
corrective actions wem to revise the Limiting Condition for Operation (LCO) Log so that appropriate notification and specific notification infonnation are recorded.
The inspector noted that this event had not recurred.
l This occurrence is being categorized as a non-cited violation because the licensee identified and corrected it. The inspector mviewed the root cause analyses and i
corrective actions during this inspection. The root cause analyses and the corrective actions appeared to be adequate and the inspector had no funher
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questions concerning this matter.
4.0 Liquid and Gaseous Effluent Contmls Procram
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The inspector reviewed the following procedures and available effluent release data as part of the examination of the implementation of the Technical Specification (TS)
requirements.
ST-5-061-570-0, Preparation of Radwaste Discharge Pennit l
ST-5-076-810-0, North Stack Monthly Noble Gas and Tritium Sampling and Analysis ST-5-076-810-1, Unit 1 South Stack Monthly Noble Gas and Tritium Sampling
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and Analysis ST-5-076-810-2, Unit 2 South Stack Monthly Noble Gas and Tritium Sampling and Analysis ST-5-076-815-0, Nonh Stack and Hot Maintenance Shop Weekly Paniculate Analysis
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. ST-5-076-820-0, North Stack and Hot Maintenance Shop Weekly Charcoal i
Analysis l
ST-5-076-815-1, Unit 1 South Stack Particulate Analysis
ST-5-076-815-2, Unit 2 South Stack Paniculate Analysis l
ST-5-076-820-1, Unit 1 South Stack Charcoal Analysis i
ST-5-076-820-2, Unit 2 South Stack Charcoal Analysis
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The inspector noted that the above procedures provic" a required direction and
guidance for impicmenting an effective program. No anomrJous data was identified during this inspection. The reviewed results indicated that simples were collected as
required.
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i During the previous inspection, the inspector identiGed higher than expected background
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count rates for the liquid radwaste efDuent monitor. (See Inspection Repon 50-352/92-01
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and 50-353/92-01 for details.) During this inspection, the inspector noted that the i
background count rates were as high or higher than reported during the last inspection.
The inspector noted that the Radwaste Depanment was assigned the responsibility to
minimize the background of the monitor and write a procedure for that purpose and that
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the procedure was being reviewed and finalized by the Plant Operations Review Committee. The inspector reviewed the draft procedure and determined that it appeared to provide adequate controls to minimize the background count rates. The inspector
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noted that with the higher background rates, the licensee used a conservative approach
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in adjusting the monitor set point to ensure that no release exceeded regulatory limits.
The results obtained by the use of the new procedure will be reviewed during a
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subsequent inspection.
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Based on the above reviews of permits, procedures, and discussion with the licensee, the l
inspector determined that the licensee had implemented the radioactive liquid and gaseous efDuent control programs effectively.
l 5.0 Calibration of Effluent / Process Radiation Monitors
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l The inspector reviewed the calibration procedures and the most recent calibration results for the following effluent / process monitors to determine the implementation of the
Technical Specification requirements.
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Liquid Radwaste Effluent Monitor A/B RHR Service Water Effluent Monitors
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Nonh Stack EfHuent Monitor (Noble Gas)
l South Stack Effluent Monitors (Noble Gas)
Hot Maintenance Shop Vent Exhaust Radiation Monitor (Noble Gas)
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l Main Condenser Offgas Monitors
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Nonh Stack Wide Range Accident Monitor (Noble Gas)
Main Steam Line Monitors
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The Instrument and Controls (I&C) Depanment had the responsibility to perfonn the electronic and. radiological calibrations for the above monitors.
The Chemistry.
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Depanment had the responsibility to perform alann and trip set point calculations required by the ODCM.
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The inspector independently calculated the radiological calibration factor usmg a -
i statistical method (linear regmssion) and verified the alarm and trip set point calculations
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for the Liquid Radwaste Effluent Monitor. The results were in agreement with the -
licensee's results.
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During the review of calibration procedures and the above actions, the inspector noted.
l that the licensee has been in the process of improving the calibration methodology to minimize systematic errors by (1) applying statistical methods to calculate monitor
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efficiency rather than utilizing graphical methods, (2) adding two more Cs-137 source l
strengths to the current three sources, and (3) utilizing appmpriate individuals, sucli as
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the Radiochemist and Effluent Physicist to review the radiological calibration results.
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(See Inspection Report 50-352/92-01 and 50-353/92-01 for details.)
l Based on the above procedure review and discussions with the licensee representatives, j
the inspector determined that the licensee follows the appropriate pmcedums and met the
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ODCM requirements.
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6.0 Air Cleaning System The inspector reviewed the licensee's procedures and most mcent test msults to verify -
the implementation of the Technical Specification requirements.
The following.
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documentation for the (1) standby gas treatment system, (2) reactor enclosure
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recirculation system, and (3) control room emergency fresh air supply system were
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myiewed:
j i-Visual Inspections
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-In-place HEPA Irak Tests j-In-place Charcoal Ieak Tests
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-System Air Flow Tests ci-Laboratory Tests for the Iodine Collection Efficiencies
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The inspector toured all the air cleaning system areas. All reviewed test results were -
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found to be within the licensee's Technical Specification limits.
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Based on the above review, the inspector detennined that the licensee was implementing Technical Specil'ication mquirements effectively.
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7.0 Exit Interview j
The inspector met with the licensee repmsentatives denoted in Section 1.0 of this
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inspection report at the conclusion of the inspection on May 14, 1993. The inspector summarized the purpose, scope, and findings of the inspection.
The licensee acknowledged the inspection findings.
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