IR 05000352/1986008

Insp Repts 50-352/86-08 & 50-353/86-06 on 860310-14.No Violation Noted.Major Areas Inspected:Radiological Environ Monitoring Program,Including Implementation of Meteorological Monitoring Program

ML20141D851
Person / Time
Site:	Limerick
Issue date:	04/01/1986
From:	Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141D828	List: IR 05000352/1986008 ML20141D823
References
50-352-86-08, 50-352-86-8, 50-353-86-06, 50-353-86-6, NUDOCS 8604080293
Download: ML20141D851 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-352/86-08 Report N /86-06 50-352 Docket N NPF-29 -

C License N CPPR-107 Priority -

Category C Licensee: _ Philadelphia Electric Company

_ 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Units 1 and 2 Inspection At: Limerick, Pennsylvania and Philadelphia, Pennsylvania Inspection Conducted: March 10-14, 1986 Inspector: l1)a1Yt e% d' ~ "

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$b Richard K. Jtruckmeyer, Rapition Shecialist Approved by: udc ( ,_\ . ad~ Y-\ -%b Walter J. Pi,a(ciak, Chief date Effluents RMitation Protection Section, EPRPB Inspection Summary: Inspection on March 10-14, 1986 (Combined Inspection Nort Nos. 5F312/8648; 50-353/86-06 Areas Inspected- Routine, announced inspection of radiological environmental monitoring program, including: management controls for these programs; the licensee's program for quality control of analytical measurements; implementa-tion of the radiological environmental monitoring program and the meteorological monitoring program; and, training and qualifications of personnel involved with these program Results: Within the areas inspected, no violations were foun PDR G ADOCK 05000352 PDR

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1 Individuals Contacted Philadelphia Electric Company (PEco) Corporate Offices Engineering and Research Department - Mechanical Engineering Division

• R. Mulford, Engineer in Charge, Nuclear and Environmental Section

• A. Diederich, Supervising Engineer, Environmental Branch

• A. Marie, Senior Engineer, Environmental Branch

• G. Rombcid, Engineer, Environmental Branch J. Elser, Technical Assistant, Environmental Branch Engineering and Research Department - Quality Assurance Division W. Baxter, Branch Head, Technical Services Branch, Office Section J. Evans, Branch Head, Projects Branch, Office Section i

• L. Ferraro, Quality Assurance Engineer  :

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Engineering and Research Department - Testing and Laboratories Division J. Smerke, Senior Engineer, Materials Laboratories Branch J. Annable, Technical Assistant, Materials Laboratories Branch  :

Electric Production Department - Quality Assurance Division

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• C Mengers, General Supervisor, Audit Section V. Lucia, Training Coordinator  :

• J. Nagle, Licensing '

• Denotes those present at the exit meeting on March 14, 1986, at PECo Corporate Offic Limerick Generating Station (LGS)

• • G. Leitch, Plant Manager C. Endriss, Regulatory Engineer

• • L. Perkoski, Sr. Technical Assistant, Testing & Laboratories

• • D. Ciarlone, QA Engineer, Engineering & Research Department

• • V. Cwietniewicz, I&C Engineer D. Wahl, Project Scientist, Canberra-RMC J. Fostige, Consultant, Canberra-RMC

• • Denotes those present at the exit meeting on March 10, 1986, at LG + Management Controls i

The inspector reviewed the licensee's management controls for the envi-ronmental monitoring program, including assignment of responsibility, program audits, and corrective actions for identified inadequacies and problem areas in the progra P

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a. Assignment of Responsibility The inspector reviewed the organization and administration of the environmental monitoring program. The program is administered by a PECo corporate engineer, who has responsibility for review of the contractor's performance of the radiological environmental monitoring program. The engineer reports to the Supervising Engineer, Environ-mental Branch. This individual reports through the Engineer-in-charge of the Nuclear and Environmental Section, to the Chief Mechanical Engineer of the Mechanical Engineering Division, to the Vice President in charge of the Engineering and Research Departmen Radiological analyses are contracted to Teledyne Isotopes, which, on July 1,1983, took over the prograr formerly carried out by Radiation Management Corporation (RMC). RMC continued to provide environmental TLD services until the fourth quarter of 1985, at which time Teledyne Isotopes also assumed responsibility for this program, b. Audits The inspector reviewed audits of the Radiological Environmental Monitoring Program, including corporate activities and contractor activities. Audits of the corporate REMP oversight are performed by the Quality Assurance Division of the Electric Production Departmen This Department is separate from the Engineering and Research Depart-ment, in which the responsibility for the REMP is' located. Each Department reports to a different Vice Presiden Audits of Teledyne Isotopes are carried out by the Quality Assurance Division of the Engineering and Research Departmen The inspector reviewed the following audits conducted by the QA Division of the Electric Production Department:

• AL 84-76 PL, "Offsite Radiological Environmental Monitoring Program, and LGS Environmental Protection Plan," October 2, 1984

- January 18, 1985

• AL 85-40 HP, " LGS Liquid / Gaseous Effluent Releases,"

April 29, 1985 - May 16, 1985

• AL 85-62 HPC, " LGS Onsite Radiological Monitoring Program,"

July 24, 1985 - September 10, 1985

• AL 85-69 HP, " Limerick Offsite Dose Calculation Manual,"

August 5, 1985 - August 9, 1985

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With the exception of audit No. AL 85-40 HP, there were no unaccept-able' findings identified in these audit Two deficiencies were noted in AL 85-40 HP, both of which were closed in audit No. AL 85-102 PR, " LGS Corrective Action _ Program." The inspector found the above referenced audits to be reasonably thorough, and noted that the auditors were qualified per the licensee's procedure QADP-14.

l -The inspector noted that the LGS Technical Specifications require an audit of the REMP once per 12 months. This is reflected in the licensee's procedure QADP-6,-Revision 10 " Quality Assurance Division Audit Program - Preoperational and Operational Phases." The only such audit performed since LGS-1 began commercial operations was performed October 2,1984 to January 18, 1985, and another audit had not been' scheduled to occur within the 12-month period. However, the

! licensee's Technical Specifications permit an extension not to exceed L 25". of the surveillance interval. The licensee stated that an audit l

of the REMP would be scheduled and performed prior to the end of the

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extension period. This will be reviewed in a subsequent inspection l (352/86-08-01).

The audit of Teledyne Isotopes is performed in accordance with the

. Engineering and Research Department QA Division procedure Proce-l dure QAI 18-4 states criteria for the frequency of audit of suppliers, including suppliers of services such as Teledyne Isotopes. The licensee has chosen to audit Teledyne at the minimum frequency (once per 3 years) permitted per its FSAR commitment to USNRC Regulatory Guide 1.144. One audit has been conducted, on February 22-24, 1984, and is documented in Audit Report No. OP-273. The inspector reviewed l the audit checklist, audit report, findings, and resolution of

! unacceptable findings. All of the latter have been closed. The audit l was performed by a qualified lead auditor, and appeared to be quite l thorough and of sufficient technical depth to adequately assess the l contractor's capabilities and performance. Nevertheless, the auditor was not considered to be a technical specialist.

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conducts Technical Reviews of its contractor laboratory; however,

! these have no specified frequency. A Itcensee representative stated that these reviews are cunducted as necessary to assure itself that the contractor is performing as expected and meeting the requirements

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of the licensee's purchase order.

l The inspector stated that the three year audit of Teledyne may l benefit by including one or more Technical Specialists associated ( with the REMP, and that this would also ensure a maximum of three j years between Technical Reviews.

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3. Implementation of the Radiological Environmental Monitoring Program The inspector reviewed the licensee's commitments pertaining to its operational radiological environmental monitoring program, by discussions with the licensee, by review of reports, and by direct observation. The inspector concluded that an effective program is in place, and that it conforms to the licensee's Technical Specification The inspector examined selected environmental mc,nitoring stations includ-ing water sampling stations, air samplers for iodines and particulates, and TL0s for direct radiation measurement. All equipment at these stations was operational at the time of the inspection. The inspector reviewed procedures and records for calibration and maintenance of the air samplers and vacuum gauges, and found that these calibrations were performed regu-larly and on schedul The inspector reviewed the following reports prepared by Teledyne Isotopes for the licensee:

Preoperational Radiological Environmental Monitoring Program Report, January 1, 1982 through December 21, 1984;

Regional Radiological Environmental Monitoring Program Report #1, December 22 through December 31, 1984;

Oraft copy of Regional Radiological Environmental Monitoring Report

1. 2, January 1 through December 31, 198 These reports provided thorough summaries of the environmental sampling and analyses conducted during the stated periods. Exceptions to the program (e.g., missing data) were noted and explained. The results of Teledyne's participation in the EPA Cross Check program are summarize . Meteorological Monitoring The inspector examined the licensee's meteorological monitoring system, including the primary and backup meteorological towers, the recorder charts in the equipment houses at each tower, and the charts in the control roo The inspector also reviewed the Surveillance Test Procedures for calibra-tion of the wind speed, wind direction, temperature, and AT sensors on the two towers. The licensee's Technical Specifications require calibration of certain sensors on a semi-annual basis. The inspector reviewed selected records of these calibrations and determined that they had been performed adequately and at the required frequenc The inspector reviewed procedure ST-2-036-416-0, Revision 2, "Meteorolog-ical Monitoring - Wind Direction Tower 2, Elevation 159 Ft. Calibration,"

performed on November 14, 1985. A note attached to the completed procedure indicated that procedural steps referenced in Table 1 did not exist in the J

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body of the procedure. However, all the nec.essary steps were in the pro-cedure; a revision to this and a similar procedure for the wind direction sensor at 304 ft. resulted in a new format for Table 1 that matched the steps of the latter procedure, but not those of the former. There was no indication on the note as to whether it had been written by the technician who performed it, or by a reviewer. The inspector stated that the tech-nician or reviewer should have initiated a Temporary Procedure Chang The licensee acknowledged this oversight, and took correct actions prior to the completion of this inspection. The necessary changes were made to the procedure, and Revision 3 was reviewed and approved on March 11, 198 In addition, during a meeting of I&C technicians on March 12, 1986, the importance of implementing Temporary Procedure Changes was stresse Because of the minor nature of the problem and the licensee's prompt corrective actions, no violation was issue . Quality Assurance The licensee described the methods used by its contractor laboratory, ,,

Teledyne Isotopes, to assure the accuracy of its analytical measurement These include participation in the EPA crosscheck program, an intri-laboratory program for analysis of spiked, split, and blank samples, and a program for analysis of duplicate and replicate samples from various locations and sample media within the LGS radiological environmental monitoring program. The quality of environmental TLD measurements is supported by two programs: A study to demonstrate compliance with USNRC Regulatory Guide 4.13 (" Performance, Testing, and Procedural Specifica-tions for Thermoluminescence Dosimetry: Environmental Applications"),

and periodic participation in the International Environmental Dosimeter Intercomparison Projec The inspector reviewed selected quality control data submitted to the licensee by its contracto These data indicate that the contractor's results are for the most part in agreement with the EPA values and that its intralaboratory results are normally in agreeinent with the actual values. For those instances in which the results did not agree, reasons for the dif ferences were investigated and the discrepancies were resolve Generally good agreement was noted among the licensee's duplicate and replicate sample With regard to the environmental TLDs, the results of the sixth (1982)

and seventh (1984) International Environmental Dosimeter Intercomparisons indicated reasonable agreement between Teledyne Isotope's results and the known exposures. The study performed by Teledyne to demonstrate compli-ance with Regulatory Guide 4.13 resulted in agreement in seven out of eight-tests. (The tests are described in ANSI N545-1975, which is refer-enced by the Regulatory Guide.) The test for " dependence of exposure interpretation on the length of the field cycle" (section 4.3.3 of ANSI N545-1975), requires the testing laboratory to compare the results of TLDs exposed for a period equal to the field cycle (F )g to TLDs exposed for a period equal to exactly half the field cycle (F2 ) ""d*" C "Std"' **P 5"I

rate condition The test is to be performed at the temperature used for

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calibration, and at the mininum and maximum temperature conditions expected in the field. At the extreme temperature conditions, the ratio F /(2=F )

3 2 shall not be less than 0.85. The result reported by Teledyne Isotopes for the test conducted at the upper temperature extreme (normally 50*C in the test) was 0.81, which is below the minimum acceptable ratio. At the icwer ard normal (calibration) temperatures, acceptable results were achieve The discrepancy was not explained, although the study did note that the temperature had increased to near 70'C near the end of the full cycl Teledyne Isotopes has committed to retest the TLDs for compliance to ANSI N545-1975, paragraph 4.3.3. The results of this study vill be reviewed in a subsequent inspection (352/86-08-02).

6. Training The inspector discussed with the licensee its training program for personnel involved with the LGS radictogical environmental monitoring program. The procedure relevant to tr. 5 training was reviewed:

NES " Procedure for Specification of Qualif' cations of Personnel in Radiological Environmental Monitoring and Indoctrination and Training" Revision 3 of this procedure was issued in October 1985. All personnel associated with the LGS REMP are required by this procedure to receive the

! specified training, which includes reviews of the staticn Quality Assurance Plan, Technical Specifications, and USNRC Regulatory Guide 4.15.

l The records indicated that those individuals requiring this training had received it as of September 198 Section 6.2.2 of procedure NES 2.0 requires " Records as shown on Exhibit 2.0-I shall be filed and maintained in the Nuclear Records Managen?nt System (NRMS)... It shall be maintained for the life of the plant."

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Exhibit 2.0-1 is a copy of the form used for indicating that Environmental Branch personnel have received the training required by NES 2.0. A licen-see representative stated that he did not know for certain whether the form had been sent to the NRMS, but that the current form would be sent, and in the future, the form will be transmitted to the NRMS each year af ter it is signed by the af fected personnel. This will be reviewed in a future inspection (352/86-08-03).

7. Exit Interview The inspector met with licensee representatives denoted in Detail 1 at the conclusion of the inspection at the LGS site on March 10, 1986, and at the PECo corporate offices on March 14, 198 The inspector suenarized the i purpose and scope of the inspection, and discussed the findings. At no time during this inspection was written material provided to the licensee by the inspecto ,

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