IR 05000353/1989020

Preoperational Safety Insp Rept 50-353/89-20 on 890530-0621. Programs Adequate to Support Testing & Startup.Major Areas Inspected:Control of Radioactive Matl & Contamination, Surveys & Monitoring,Facilities & Equipment & ALARA

ML20246N197
Person / Time
Site:	Limerick
Issue date:	07/13/1989
From:	Dragoun T, Loesch R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246N186	List: IR 05000353/1989020 ML20246N180
References
50-353-89-20, NUDOCS 8907190314
Download: ML20246N197 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.: 89-20 Docket No.: 50-353 License No.: CPPR-107 Category: C Licensee: Philadelphia Electric Company 2310 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station Unit 2 Inspection At: Limerick, Pennsylvania Inspection Conducted: May 30 to June 21, 1989

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[ww 1.Dragog,SeniorRadiationSpecialist 7//3/r?

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. Loes,ch/ RadiatMon Specialist date Approved by:

W. Pasciak, Chief, FacilitSes Radiation date Prs action Section Inspection Summary: Inspection on May 30 to June 21, 1989 (Report N /89-20)

Areas Inspected: Routine preoperational safety inspection of the licensee's radiological controls programs including: control of radioactive material and facilities and equipment, organization contamination, and staffing, external exposure contro and personnel monitoring, and ALAR surveys and monitoring,l ]

Results: The programs are adequate to support testing and startup of the plan l l

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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company

• M.J. McCormick, Jr., Plant Manager

• R.W. Dubiel, Superintendent-Plant Services

• G. Murphy, Senior Health Physicist

• M. Christinziano, Support Health Physicist

• R. Leddy, Applied Health Physicist K. Dickinson Instrumentation and Controls Engineer M. Moon,HealthPhysicist-Dosimetry W. Odam, I&C Engineer T. Mscisz F.O'Niell,AppliedHPSupervisorRadiological Engineer G. Rombold, Rad. Branch Head, Nuclear Engineering Dep S. Sieg, Health Physicist - Respiratory Protection R. Valitski, Operations Shift Supervisor L. Wells, Radwaste Engineer E. Wise, Radwaste Engineer R. Ragland, Radiological Engineer Hydro Nuclear Corp.)

K. Hurst, Radiological Engineer dro Nuclear Corp.)

R. Brown, NSSS Startup Engineer )

W. Dagan, NSSS Test Supervisor (

1.2 NRC Personnel T. Kenny, Senior Resident Inspector

• M. Evans, Resident Inspector

• Attended the exit interview on June 21, 198 .0 Purpose The purpose of this Unit 2 preopera'io'nal inspection was to determine the readiness of the radiological programs to support plant startup. Elements reviewed included:

- Control of Radioactive Material and Contamination, Surveys and Monitoring,

- Facilities and Equipment,

- Organization and Staffing,

- External Exposure Control and Personnel Dosimetry, and

- ALAR _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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3.0 Control of Radioactive Material & Contamination, Surveys, and Monitoring l

1-3.1 General Radioactive material and contamination control, in-plant surveys' and -

monitoring programs were reviewed against the requirements of 10 CFR i 20.201, " Surveys"; 10 CFR 20,401, " Records of surveys, radiation monitoring-and disposal"; licensee commitments in the FSAR Chapter 12; and criteria in Regulatory Guides (RG) 8.2, 8.7 and 8.8. Licensee procedures reviewed included:

=AP-30.6 Control of In-Plant Contaminated Tools, Rev.1,

- AP-30.8 Contamination Control Program, Rev. O,

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AP-44 Procedure for Special Nuclear Material Accounting, Rev. 4

- AP-80.1 Control of Radioactive Sources Used for Radiographic Non-Destructive Examinations, Rev. O,

- HP-109 High Radiation Area Key Control, Rev. 5,

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HP-200 Routine Surveillance Program, Rev. 6,

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HP-203 Health Physics Start-up Surveillance Procedure, Rev. 2,

- HP-212 Airborne Contamination Monitoring - CAMS, Rev. 5,

- HP-213 Airborne Activity Survey Techniques, Rev. 5,

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HP-214 Air Sampling Analysis and Evaluation, Rev. 9,

- HP-300 ' Access Control Point Policies

- HP-314 Initial Entry into the Drywell,Rev.1, Rev. 4

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HP-315 InitialEntryintotheSuppressionPoolContainment,Rev.4,

- HP-317 TIP Drive Unit Access, Rev. O,

- HP-318 TIP Room Entry, Rev. 1,

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HP-400 General Requirements for Calibration of Portable Health Physics Survey Instrumentation, Rev. 4,

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HP-401 Control and Accountability of Health Physics Instrumentation, Rev. 4

- HP-524 Dryweli Oxygen Monitoring, Rev. 2,

- HP-618 Determination of Neutron Dose, Rev. 6,

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HP-701 Control and Use of Byproduct Material Used in Unit 2, Rev. 0,

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HP-810 Radioactive Material Control, Rev. 8,

- HP-1000 Determination of Offsite Doses during Startup Testing, Rev. 2,

- ST-0-RRR-900-1 Drywell Closeout Inspection, Rev. O,

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ST-0-RRR-901-1 Sup)ression Pool Closeout Inspection, Rev. O, and

- ST-0-104-642-1 Loc (ed High Radiation Area Checks, Rev. Within the scope of the inspection, no violations were identified, however, some of the procedures were noted to be Unit I specific and should be revised to either be unit independent or include Unit 2 reference Specific examples noted by the inspector were brought to the licensee's attention and resolved during the inspection. The licensee stated that a complete review of all procedures was in progress, l

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3.2 Radioactive Material and Contamination Control The inspector reviewed procedures related to radioactive material (RAM) and contamination control. The procedures appear adequate a decontamination facilities are in place. Allmaterials,ndtheassociated tools, and are equipment required totobebesurveye removed In from the Radiologically addition, employees Controlled Area throug leave the RCA (RCA)h beta / gamma sensitive portal monitor It is the licensee's policy to allow individuals to self survey personal items simple hand tools, tool boxes, hand trucks, and other items without complicated or internal surface During the inspection the licensee activated a second control point and expanded access controls to include Unit 2. However, the inspector noted that some individuals were not performing proper frisking techniques when surveying small items, and in one case, a Health Physics technician allowed a worker to exit the RCA with an open can of paint after only a self frisk and without the normally required isotopic analysis. For this type of policy to be effective, all plant personnel must be appropriately trained and make a conscientious effort to properly survey all items to prevent the inadvertent release of radioactive materials from the RC ,

3.3 In-Plant Surveys and Monitoring The inspector reviewed the Limerick survey program for compliance with the !

requirements of 10 CFR 20.201, 20.203, and 20.401; the criteria of RG and ANSI N13.2-1969, and FSAR commitments. The licensee program includes routine includingandthe special surveys capability forforsurveillance alpha, beta,dan measurements of dose rates, gamma and neu contamination levels, and airborne particulate, iodines and noble gase Frequency of surveys generally appeared adequate for controlled area Survey maps are under develop' ment and will be incorporated into a new computerized " Surrogate Tour system which will allow the overlaying of j survey information onto photographs stored on video dis .0 Facilities and Equipment 4.1 Radiation Protection Facilities and Equipment The inspector reviewed the licensee's onsite Radiation Protection facilities and equipment with respect to that described in FSAR Chapter 12.5.2, " Facilities, Equipment and Instruments."

Conformance with these criteria were determined from discussions with cognizant personnel, tours of the facilities to include the field office, access control stations, counting room, instrument storage and calibration facilities, decontamination facility and balance of plan Facilities and equipment as described in the FSAR were in place and a)peared to be adequate. Additional access controls were implemented during tie inspection to include Unit !

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4.2 Area Radiation, Criticality, and Containment Post-LOCA High Range Radiation Monitors Documents Reviewed

- Preoperational Test Procedure 2P-79.1, Rev. O,

- Preoperational Test Procedure 2P-79.1A, Rev. O,

- Surveillance Test Procedure ST-2-026-444-2, Rev.1,

- Surveillance Test Procedure ST-2-026-407-2, Rev. 6,

- Surveillance Test Procedure ST-2-026-408-2, Rev. 6,

- Surveillance Test Procedure ST-2-026-409-2, Rev. 7,

- Surveillance Test Procedure ST-2-026-410-2, Rev. 6,

- Testing Lab Procedure TL-11-00384, Calibration of General Atomic Digital High Range Radiation Monitors, Rev. 1,

- Calibration Test Data Sheets for Area Radiation Monitors RE31, RE32 and RE33,

- General Electric Area Radiation Monitor Basis, Rev. O,

- Draft Technical Specifications, Section 3.3.7, Monitoring i Instrumentation,

- Draft Calculations for Criticality Accident Alarm System, Unit 1, dated 6/25/84,

- FSAR, Chapters 7.7.1.10 and 12.3.4, and

- Plant Master Instrument Inde Findings The inspector performed a walkdown of the Area Radiation Monitoring (ARM)

system, verifying that each location contained a detector, indicator and local alarms. The ins)ector noted that the locations and monitoring ranges were as specified in tie FSAR, Chapter 12.3.4. Control Room and Auxiliary Equipment Room alarms, indicators and recorders were also verified to be consistent with the FSAR. However, the following discrepancies were noted by the inspector:

- ARMS RE21-M1-2N001 and RE22-M1-2N001 were incorrectly identified as to location in FSAR Table 7.7.2 and on local instrument identification tag Site maps located in the Technical Support Center were not updated to indicate locations of the Unit 2 ARM Corporate Engineering had not taken into consideration the approximately six feet of concrete between criticality detector RE32, located inside the new fuel storage vault, and the spent fuel pool. Rough calculations performed by the inspector indicated that the detector did not meet the i for a criticality monitor as committed to criteria of 10toCFR in the basis the 70.24(a)(2)

Technical Specifications. Preliminary calculations performed during the inspection by Corporate Engineering were in agreement with the inspector's observations. The licensee committed to reevaluate all ARMS located on the refueling floor to determine their effectiveness to function as criticality monitors.

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- All ARMS are recorded on a single chart recorder located in the control room. The recorder is labeled and contains chart paper with the range

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1E-2 to IE4 mR/hr. However, radiation monitoring channels 13, 14, 19 and l 20 have a range of IE0 to 1E6 mR/hr. The licensee had previously l identified this problem during preoperational testing and adequate l- corrective actions have been initiated.

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- The Sdiveillance Test Procedures for the Containment Post-LOCA High Range

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Radiation tionitors were inadequate. Technical Specification 3.3.7.5, Accident Monitoring Instrument, defines the channel calibration as an electronic range decadescalibration ofR/hr above 10 the channel,)not including the detector, forand a one point of the detector below 10 R/hr(7 decades 1 decade) with an installed or portable gamma source. Inspector review (of the test procedure indicated that no provisions had been made for the electronic calibration of the upper 7 decades. Although the calibration of the recorder included many of the electronic modules utilized by the detector, it did not test the current-to-frequency converter which receives the signal from the detector and modifies it for storage by the microprocessor. The licensee revised the calibration procedur .3 Portable Survey, Sampling, and Contamination Monitoring Instruments The inspector reviewed instrument storage facilities and verified that adequate procedures for issue and use had been developed. Adequate types of instruments were available for alpha, beta, gamma, and neutron surveys, including high and low range radiation surveys, and contamination and airborne radioactivity surveys as described in the FSAR. Inventory was adequate to support dual unit operation. Instruments are stored and issued from the HP Field Office located in a trailer near Unit 1. Final storage, issue, and calibration facilities are still under developmen .4 Protective Clothing and Equipment PCs) and equipment available and The variety storage of protective facilities clothing (ith-the FSAR. This includes coveralls, were-consistent-w shoe covers, gloves and liners, hoods and respirators. Supplies of coveralls are adequate and additional new stock is available in storag Reusable protective clothing including respirators are sent to an outside vendor for cleaning. PCs are checked for residual contamination prior to reissue. Repair of respirators is performed onsite. Permanent laundry and respirator cleaning facilities are under developmen .0 Organization and Staffing The inspector reviewed the organization, staffing, and motivation of the Health Physics Department to control radiation and radioactive material during the startup and operation of Limerick Unit o

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Qualifications of the staff were reviewed in a previous inspection and determined to be adequate. Performance was determined from interviews with

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selected personnel, review of records and Position Guides, plant tours, and observation of meetings. Adherence to commitments made " Final Safety Analysis Report Chapter 12 and 13 was also reviewe HP Department staffing levels needed to support two unit operation were  ;

determined last year with input from a management consulting fir i Projected HP technician levels tended to be low due to reliance on i implementation of significant innovations such as the "radworker" concep l This concept, developed in Canada, trains workers to determine protective I measures for work under minimal radiological conditions. This eliminates '

I the need for some job coverage by HP technicians. The approved staffing level is 41 technicians. Currently on site are 41 ANSI gualified technicians,12 trainees, 5 corporate-based radiological engineers, and about 12 contractor HP technicians. These levels are adequate to support o)eration of Unit I and startup of Unit 2. The Senior Health Physicist 4 (tadiation Protection Manager) stated that management will review l technicians staffing levels again after Unit 2 startup is complete ]

All HP supervisory positions are filled by qualified personnel except for the Radiological Engineering /ALARA Supervisor. This vacant position will be filled by an internal transfer before Unit 2 startup. Although the number of supervisors is adequate, the licensee's staffing review last year identified the need to expand the professional staff to improve HP program performance. Additions will include an Instrumentation Physicist, 7 technician foremen, and several radiological engineers. A new " Assessment Center" will screen candidates for supervisory aptitude prior to selectio Oversight of Unit 2 construction progress and system tie-ins was assigned to a separate group consisting of 2 licensee and 2 contractor HP personne The Senior HP stated that these additional personnel will be retained through the Unit 2 power ascension phase. Prior to accepting a completed

" area from the Construction Group a formal HP walkdown was completed per procedure RW-516 " Unit 2 Facility Turnover". A punchlist of specific items, primarily ALARA concerns, was completed and formally processed to the for correction. This activity is Architect discussed/ further Engineering firm in section (Bechtel)this of report. Tie-in of Unit 2 fluid systems to Unit I contaminated systems was well planned and coordinated by the HP group. At the time of this inspection most tie-ins were completed with no radiological incidents reporte Relationships between HP and the other Unit 2 organizations appears goo Formal delineation of responsibilities are found in procedures RW-516 and A-220, " Procedure for Transfer / Release of System Responsibility from Startup to Plant Staff". In a recent corporate decision, the primary responsibility for coordinating all startup activity was placed on the Outage Planning Department. Outage planning meetings and the TRIPOD (3 day work plan) now discuss startup activities. Since the HP department attends these meetings overall coordination has improve _ ____--__

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The Unit 1 Spring Refueling Outage was recently concluded. The inspector noted that the scope and duration of the outage had expanded significantly _!

beycud early projections. Recovery from the outage diverted HP resource away from Unit 2 startup.The Senior HP also recognized this fact and

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increased the number of contracter HP technicians onsite towards the end of

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As a management tool, the HP Department issued a list of action items for Unit 2 startup. Responsibilities were assigned to specific HP Supervisors with target dates. A review of the tasks indicates that the efforts are l appropriate as are the timetable Within the scope of this review, the inspector determined that the HP Department is fully capable of implementing the radiation safety programs for Unit 2 startup and operatio .0 External Exposure Control and Personal Dosimetry The licensee's program to control external exposures and personnel dosimotry during Unit 2 startup and operation was reviewed with respect to criteria in FSAR Chapter 12 and 10 CFR 20. The adequacy of administrative and physical controls was determined from interviews with selected personnel, review of selected procedures, and plant tour Routine radiation surveys of Unit 2 spaces began last year while l construction was still in progress and system cross ties were minimal. This- '

conservative approach was taken to acquaint the HP technicians with the plant layout and to detect increases in radiation levels due to nearby Unit ,

1 pipin . Surveys are the same as the Unit 1 program described in procedure 1 HP-200,g" Routine Surveillance Program." A review of surveys performed the week of 5/21/89 indicated that this effort is satisfactory. The licensee {

stated that the survey maps would be updated to reflect the final as built -

plant layout and to facilitate computerized storage of the data. This i matter will be reviewed in a future inspectio l The inspector discussed the availability of portable radiation survey

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instruments with the acting Instrumentation Physicist station has quantities of instruments in excess of the(a contractor). TheFSAR specifi for two unit operatio The on-site calibration facility appeared able to maintain the increased numbers of instruments. The licensee stated that a new computer based accountability system for instruments will be implemented in September 1989 to replace the current manual system. Using bar codes, a rapid and accurate inventory can be taken. This matter will be reviewed in a future inspection.

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on May Unit 2 wasThis 30,198 designated as a Radiologically was a significant milestoneControlled in regardsArea (RCA)l exposure to externa controls in that:

- only workers completing General Employee Training are granted access to the RCA,

- radiation area postings and warning signs were placed,

- several cubicles with reactor system components were locked and placed under HP departmental control,

- all equipment installation and maintenance is now reviewed to determine if a Radiation Work Permit is required, and

- dosimetry (TLD+SRD) is required for acces Observations in the RCA indicated that implementation of these controls was proceeding smoothl The licensee has identified 34 rooms to be controlled as Locked High Radiation Areas during plant operation. Two doors remain to be installe Actual locking will not occur until radiation levels begin increasing (at about 25% reactor power) to allow for equipment inspections during startu A radiological engineer has been designated to ensure that areas will be locked when required. After startup these areas will be controlled using procedure HP-109, "High Radiation Area Key Control". This effort appears satisfactor After a review of Startup' Test Procedures 2STP-2.0, " Radiation Measurements - Main Body , Rev. 1, and 2STP-2.1, " Radiation Surveys -

Subtest 2.1", Rev. 1, the inspector determined that these tests would not adequately verify that the permanent plant shielding met design criteri Recommendations for startup surveys provided in ANSI Standard ANS-6.3.1,

" Testing Radiation Shields in Light Water Reactors", had not been incorporated. In response the licensee made major changes to the test procedure and issued Revision 2A. Additionally, the HP technicians will be trained to perform shield surveys, written guidance will be given to the technicians, and the routine survey program will be reviewed to incorporate lessons learned from the special surveys. The inspector determined that this corrective action was satisfactor Dosimetry is available on site for about 6000 individuals. This is far in excess of peak needs even if both units are in a outage. The licensee's in-house dosimetry processing is NVLAP certified as required by 10 CFR 20.202. Local processing also allows short turnaround if needed. The dosimeter is the Panasonic 4 chip thermoluminescent dosimeter (TLD).

The TLD is attached to the security badge which is issued on entering the station. The badge is used in computer controlled card readers to gain access to the RCA. This control gives a high confidence that only ,

authorized workers can enter the RCA. There is one group and supervisor in i the HP Department whose sole responsibility is issuance of dosimetry and maintenance of record l l

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Within the scope of this review the inspector determined that the licensee's programs for external exposure controls and personnel dosimetry for the operation of Unit 2 met the commitments in the FSAR. ho violations of 10 CFR 20 requirements were observe .0 ALARA-The design steps taken to minimize worker exposures during operations and equipment repairs on Unit 2 were reviewed with respect to:

- commitments in FSAR Section 12.4,

- guidance in Regulatory Guides 8.8 and 8.10, and

- requirements in 10 CFR 2 Licensee performance was determined from:

- interviews with selected radiological engineers and supervisors, design and ALARA reviews,

- review of licensee's the architect / engineer ALARA (A/E)d policies an approval processes for Plant Change Requests to improve ALARA, and

- plant tour The inspector observed that many of the current state-of-the-art ALARA practices had not been implemented in the plant design. However, interviews with personnel involved in the early design process revealed the design occurred from the late 1960's through the mid-1970's. The design only incorporated the limited ALARA techniques available at that time. Plant construction which began in the 1970's was stopped in the early 1980's to allow completion of Unit I which began commercial operation in 1986. Thus, the long time interval between the design and completion of construction prevented incorporation of all the latest ALARA technique ALARA efforts by the A/E were acceptable considering the constraints of changing an old design while construction was in progress. ALARA reviews were conducted most recently in accordance with Specification 8031-G-40

" Specification for Review of Facility Equipment Design for As low As Is Reasonably Achievable (ALARA) In-Plant Radiation Exposures for Philadelphia Electric Company Limerick Generating Station Units 1 & 2", issued for use on 1/28/87. The appendix to this Specification contains a detailed ALARA checklist. Prior to use of this specification the A/E used generally accepted industry practices for ALARA desig Examples of design accomplishments include:

- Separate Control Rod Drive breakdown and rebuild rooms,

- A roll up door allowing easy removal of condensate pumps,

- A removable block shield wall to provide access to the turbine condenser i

air ejectors, and

- Monorails installed in the Drywell to reduce equipment rigging time.

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The A/E advised that there is a separate ALARA design specialist in each of the engineering discipline areas. There was also an onsite ALARA group that reviewed the as-built configurations. However this group was disbanded on completion of Unit I since the design of Unit 2 is identica The licensee has had a radiological engineer on site reviewing the A/E design and construction. The engineer has been particularly aggressive

initiating improvements arid correcting oversights. Significant changes include:

- Added shielding after determining that the Traversing Incore Probe (TIP)

room was too short to house the highly radioactive TIP cables, and

- Relocating the reactor building cooling water sample sink out of a high radiation are Additional licensee engineering reviews of Unit 1 experiences lead to the following citanges:

- Control Rod Drive pins and roller bearings were replaced with cobalt free material,

- Sight glasses were installed on valves useo for system filling and >

venting, and

- Worker access platforms were installed in the Regenerative Heat Exchanger Roo All changes initiated by the A/E or licensee were formally processed through a Plant Change kequest procedure. Each change was technically reviewed and a cost benefit analysis performed since most ALARA changes were outside the original design envelope and involved additional expens The inspector noted that the licensee was willing to accept the added cost for ALAR Within the scope of this review, the inspector determined that the licensee had met the FSAR commitments to ALARA to the extent feasible under existing conditions. No violations were observe .0 Exit Interview At the conclusion of this inspection on June 21, 1989, the inspector met with the licensee personnel denoted in Section 1. The scope and findings of the inspection were presented at that time.