IR 05000352/1985013

Insp Rept 50-352/85-13 on 850226-28 & 0305-06.No Violation Noted.Major Areas Inspected:Chemistry Radiation Protection & Radwaste Mgt Programs During Startup

ML20128B819
Person / Time
Site:	Limerick
Issue date:	05/02/1985
From:	Cheung L, Mark Miller, Myers L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128B782	List: IR 05000352/1985013 ML20128B777
References
50-352-85-13, NUDOCS 8505280072
Download: ML20128B819 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No~. 50-352/85-13

Docket N License _N NPF-27 Priority -

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia Pennsylvania 19101 Facility Name: Limerick Generating Station Inspection At: Limerick, Pennsylvania Inspection. Conducted: February 26-28 and March 5-6, 1985 Inspectors: Y ty b w M f u n u ,

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4~ 2 b*95 erg Radiation Specialist ate Y AS &~1 +n/Y C'Cleung,ReactorEngineerf / date Y/1L4% Y%fw Y- 2b '$[

date L 'My(rsgl Radiation Speciali st Approved by: iQ! \ /( A9 CL w)6 (/ll2 I U-W.~ PasciaR, Chief, BW[ Radiation / da Safety Section Inspection Summary: Inspection on February 26-28 and March 5-6,1985,(Report IIo. 50-352/85-13).

Are'a s Ir.spected: Routine, announced inspection of the licensee's chemistry, radiation protection and radioactive waste management programs during start-up including review of the following areas: status of previously identified items and radiation protection start-up survey The inspection involved 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br /> onsite by three NRC region-based inspector Results: No violations were identifie $ $h0sy y PDR

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Details 1.0 -Persons Contacted

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1.1 Licensee Personnel

• J. Franz, Assistant Plant Superintendent

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• J.'Doering, Operations Engineer

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• D. Dubiel, Senior Health Physicist

• J. Wiley, Senior Chemist

• C. Endriss, Regulatory Engineer G. Gilbody, QA Engineer-

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C. Harmon, QA Engineer D. Helwig, Electrical Project Engineer W. Lewis, Test Engineer

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• J. Liza, QA Enginee G. Murphy, Support. Health Physicist C. O'Donnell Auditor, Quality Assurance (EPD) Titolo, Applied Health Physicist

• T. Yedock, Special Projects Chemist L. Wells, Physicist, Rad Material & Radwaste Shipping 1.2 Vendor Personnel C. Brown, GE Start-up J. Ferguson, Radwaste Consultant C. Griffith, Start-up Engineer U.S. Nuclear Regulatory Commission

• R. Borchardt, Reactor Engineer Other Itcensee or contractor personnel were' also contacted or interviewed during this inspectio * denotes attendance at the exit interview on March 6, 1985 2.0 Purpose

.The purpose of this routine safety inspection during the start-up phase was' to review the_ licensee's action taken on previously identified inspection findings for the following areas:

Chemistry - Post Accident Sampling Analysis and Monitoring

• Radiation Protection

• Pre-operation Test Exceptions In addition, the results of the licensee's radiation protection start-up test program were reviewed, t

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3.0 Status of Previously Identified Items 3.1 Chemistry - Post Accident Sampling Analysis and Monitoring (Closed) Follow-up Item (352/84-66-01): Improve the system design and operating procedure to assure that a timely and representative sample of rea-tor coolant can be obtaine The inspector reviewed EP-231, Revision 6, " Operation of Post-Accident Sampling Systems (PASS)," EP-241, Revision 6, " Sample Preparation and Handling of Highly Radioactive Liquid Samples," EP-242, Revision 4, " Sample Preparation and Handling of Highly Radioactive Particulate Filters and Iodine Cartridges," and EP-243, Revision 5, " Sample Preparation and Handling of Highly Radioactive Gas Samples," and determined that sufficient instructions were available for a trained individual to obtain the required PASS samples. The inspector also noted that Maintenance Request Forms were initiated and completed to resolve reactor coolant delivery system problems previously identifie The licensee calculated system purge times to meet representative sampling requirement These results were reviewed and found acceptable. The inspector noted that EP-231, Revision 6 included the revised purge time With regard to determining the error associated with the dilution of the 0.1m1 sample with 10ml of demineralized water, the licensee stated this action would be completed prior to completion of power ascension testing. The inspector stated the dilution error analysis would be reviewed during a future inspection (352/85-13-01).

(0 pen) Follow-up Item (352/84-66-02): Improve the system design and operating procedure to assure that a representative containment air sample can be obtaine The inspector detarmined the necessary procedures were revised to ensure adequate PASS containment sampling. The inspector also reviewed completed Maintenance Request Forms (MRFs) to verify that the identified design and/or maintenance problems were correcte These concerns included: installation of heat tracing for the sample line leading to the PASS station and inside the reactor building; provisions to prevent over insertion of the gas vial positioner; a mechanical stop to maintain integrity of the iodine filter drawer seal; and reversal of the flow path through the iodine cartridge so that the PASS radiation detector is appropriately located above the first filter in the series of four filter The inspector noted that the licensee had not completed the acceptance testing for the heat tracing on the containment air sample lin Since insufficient temperature control may cause condensation and iodine plate-out, containment samples may not be representative. This item remains open and will be reviewed prior to completion of low pewer testin (0 pen) Follow-up Item (352/84-66-03): Address on-site chloride analysis capabilities and assure detailed physical and L

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administrative arrangements exist for the shipment of samples to the off-site laborator The inspector reviewed a proposed change to the FSAR (LDCN-FS-858 dated January 24, 1985) describing the use of ion chromatography with an accuracy of at least i 10% over the NUREG-0737 prescribed for chloride analysis range. The licensee sr. ced the draf t FSAR change would be submitted to the NRC during Spring 1985. The inspector evaluated the results of the licensee's onsite chloride analysis using the ion chromatograph with certified chloride standards, and determined the licensee demonstrated on-site chloride analysi However, for a back up method, the licensee had not completed the i

physical and administrative arrangements for shipment of samples to

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an off-site laborator This item remains open and should be resolved prior to completion of power ascension testin (Closed) Follow-up Item (352/84-66-04): Address onsite boron analysis capability and demonstrate that elements in the standard test matrix do not significantly interfere with the baron analytical metho The inspector noted a proposed change to the FSAR (LDCN-FS-858 dated January 24, 1985) describing the use of direct current plasma spectroscopy with an accuracy of 110% between 50 and 1100 ppm for boron analysis in reactor coolant samples. The licensee stated the draft FSAR change would be submitted to the NRC during spring 1985. The inspector evaluated the results of the licensee's onsite boron analysis using the direct current plasma spectroscope with certified boron standards, and determined that the licensee's analysis capability to be adequate. With regard to possible chemical interferences with this boron analytical method, the licensee stated they provided the test results to NRC On August 24, 1982 for NRR review. This item is close (Closed) Follow-up Item (352/84-66-05): Demonstrate PH analysis for reactor coolant sample The inspector verified the licensee's capability to perform onsite pH analysis in a timely manner and within the exposure constraints of General Design Criterion 1 (Clo:ed) Follow-up Item (352/84-66-07): Evaluate the use of

" break-away" needles to prevent sample loss. The inspector observed that one piece needles were available for injecting dissolved gas samples into the gas chromatograph. This item is close (Closed) Follow-up Item (352/84-66-08): Other considerations for improved PASS capabilitie The inspector reviewed procedure EP-241, Revision 6, " Sample Preparation and Handling of Highly Radioactive Liquid Samples" and determined the method for obtaining a dilution factor of 100 was not correctly stated. The inspector also noted the basis for the dose analysis presented in the LGS FSAR Table 11.5-6 was developed by calculating the Limerick Unit 1 (site specific) post-accident source term and then used this source term in conjunction with the PASS sampling and analytical time and motion

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test results determined for Peach Bottom. The inspector determined the results were conservative and therefore the request to develop a site specific time and motion study was withdraw Concerning routine maintenance of the PASS system and stockpiling of spare parts, the licensee stated the PASS was included in the routine maintenance program, and a routine test procedure RT-5-030-800-0 was -

developed to address provisions for maintaining spare part The inspector noted that a maintenance request form (MRF) had not been completed which dealt with an erratic pressure indicgtor (P1-661). In addition, the -inspector was unable to discuss the method of calibration of the PASS radiation detectors because licensee personnel were in training (emergency drill). These items will be reviewed during a subsequent inspection (352/85-13-02).

(0 pen) Follow-up Item (352/84-66-09) Improve noble gas sampling capability of Wide Range Gas Monitor (WRGM), develop procedures for operation, maintenance and service of WRGM, and provide response factors as a function of time af ter shutdown. The licensee stated that improper positioning of a electronic board prevented displaying sample flow rates locally and remotely in the Control Roo This situation was resolved. With regard to detector sensitivity to post-accident background conditions, the high range noble gas monitor has a minimal detector response and therefore the instrument reading would not have to be compensated for ambient radiation levels. The inspector toured the Control Room and reviewed the vendor manuals regarding detector response to background radiation to verify the licensee statement The inspector also noted that the WRGM Procedures for operation, maintenance and to adjust the response factors for different isotopic mixtures were being developed. These procedures will be reviewed during a subsequent inspection prior to completion of low power testin (Closed) Follow-up Item (352/84-66-10): Improve post accident particulate and iodine effluent sampling capabilitie The inspector noted the licensee had adequately addressed the identified concerns to ensure the capability to retrieve representative iodine / particulate effluent samples from the North Stac The inspector also noted that the sample flow rate was displayed in the Control Room. This item is close (0 pen) Follow-up Item (352/84-66-11): Develop and implement a procedure for performing in-field analysis of radioiodine sampling cartridges. The inspector noted that the licensee had not completed developing a procedure to address in plant field analysi The licensee stated this procedure would be available prior to completion of low power testing. This item will be reviewed during a subsequent inspectio .________- _ - - - .

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-(Closed) Follow-up Item- (352/84-66-12): - Jet pump sample source and possible premature closure of the excess flow check valve on the sample lin The licensee's Chemistry Group Leader stated that he had successfully obtained numerous samples from this point, which demonstrate its operabilit He - further stated -

that as part of the on going PASS training program, he expected to obtain samples from this point at least four or five times a year in ,

the future (this can serve as operability test on this sample point). The inspector reviewed the records of four sample collection operations (one dated February 22, 1985 and three dated February 27, 1985), and determined that proper representative samples were obtaine In an attempt to avoid inadvertent operation of the needle valve upstream of the solenoid value (thus altering the preset sample flow rate) the licensee removed the valve handle (verified by the -

inspector). The licensee stated that they are in the process of replacing this needle valve by a remotely operated throttle valve to

. increase operating flexibilit The inspector reviewed the licensee's document necessary for this valve replacement (Project '

Change Request No. 0603, approved on January 25,1984).

This item is close (Closed) Follow-up Item (352/84-66-14): Pertaining to unprotected sample tubing line in the RHR ' roo This 3/8" sample tubing downstream of air-operated-valve HV-199A had been rerouted in such a way that the possibility of being stepped upon is minimized. The inspector observed the rerouted tubing and found it acceptabl This item is close (Closed) Folicw-up Item (352/84-66-14): Pertaining to justification of inaccessible valves (after an accident) for their specified service environmen The inspector reviewed the licensee's justification in their internal memo (from D.B. petters to G. Leitch dated January 15, 1985, page 3). This document identified an acelyl resin disc holder was used in each of two pilot solenoid valves. This organic material has a qualified life of 8 years when exposed to normal plant operating dose plus 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> post LOCA dos The licensee committed to include in their preventive maintenance -

program the replacement of the disc holder every 8 years and in their operating procedure that these valves should be closed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after a LOC This item is close .2 Radiation protection (0 pen) Follow-up Item (352/84-45-13): Complete development and implement Respiratory Protection Program including use of engineering controls prior to exceeding five percent power. The licensee has

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established and implemented the majority of its respiratory protection procedures, including quality assurance procedures for oversight of vendor activities. However, the inspector noted that portable ventilation units were not available. This area will be reviewed prior to completion of power ascension testin (0 pen) Follow up Item (352/84-45-14): Develop a program to evaluate beta dosimetry and neutron dosimetry for routine plant operations and complete procedures which address guidance for exposure to minor The licensee has established its program to periodically review the adequacy of its beta and neutron dosimetry program. However, the inspector noted that procedure for neutron dosimetry stated the average neutron energy was known. The licensee stated this statement would be deleted from the procedure since energy spectrum character-istics studies would not be performed. This procedure revision will be reviewed during a subsequent inspection prior to completion of power ascension testin (Closed) Follow-up Item (352/84-45): Expand the routine radiological surveillance program to provide assurance that radioactive materials are not located in unauthorized areas. The inspector reviewed the licensee's routine surveillance program and noted that unauthorized areas were included in the radiological surveillance procedure and RWP coverage was specified in the

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Radiation Work Permit Procedur .3 Pre-operational Test Program -Test Exceptions (0 pen) Follow-up Item (352/84-57-02): Evaluate and resolve open test exceptions from procedure 1868.1A, " Solid Radwaste System."

Review of the licensee's resolution of the open test exceptions (i.e., (TE) 25 and 26) indicated adequate evaluation and resolution of TE 25. The inspector noted TE26 remains ope .0 Start-up Testing: Radiation Surveys Documents Reviewed a Final S4fety Analysis Report (FSAR), Chapter 14 " Initial Test Program"

• Startup Test , Procedure STP 2.0, Revision 1, " Radiation Measurements

- Main Body", dated September 13, 1984

• Startup Test Procedure STP 2.1, Revision 1, "Startup Radiation Surveys-Prior to Fuel Load", dated September 13, 1984

ANSI /ANS-6.3.1, 1980, " Program for Testing Radtation Shields in Light Water Reactors (LWR)"

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Finding Review of the test procedures and test data indicated that the licensee was conducting startup radiation surveys in accordance with FSAR commitments and procedure requirements. No unexpected levels of radiation were encountered. The calibration of the instruments used to conduct the radiation surveys was not reviewed. This area will be reviewed during a subsequent inspection (352/85-13-03).

No violations were identifie .0 Exit Interview The inspector met with the licensee representatives (denoted in section 1.0) on March 6, 198 The inspector summarized the purpose, scope and findings of the inspectio In addition, matters requiring resolution griortofuelloadwerespecificallyidentifie 'At no time during the inspection was written material provided to the license by the inspecto :

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