IR 05000352/1985028
| ML20133P501 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/22/1985 |
| From: | Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133P494 | List: |
| References | |
| 50-352-85-28, IEB-79-19, NUDOCS 8511010036 | |
| Download: ML20133P501 (7) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/85-28 Docket No.
50-352 License No. NPF-39 Priority Category C
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Licensee: Philadelphia Electric Company 2301 Market Street Pniladelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station Inspection At:
Limerick, pennsylvania Inspection Conducted:
September 16-19, 1985 Inspectors:
gN 7/[iggt
/0 r f5" M.
. 11
, Rrdiation Specialist-d e
Approved by:
h (oIM 95
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V.' P a s~f ca k, C h i e f date BWR Radiological Protection Section Inspection Summary:
Inspection on September 16-19, 1985 (Report No. 50-352/85-28)
Areas Inspected: Routine, unannounced safety inspection of the status of the licensee's Radioactive Waste Management Program, two facility contamination events, and Radiation Protection Startup Testing.
The inspector involved 29 inspector hours onsite by one regionally-based inspector.
Results: No violations were identified.
8511010036 851023 PDR ADOCK 05000352 O
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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel
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- G. Leitch, Plant Manager
- W. Knapp, Director, Radiation Protection Section (Corp.)
- D. DuBiel, Senior Health Physicist
- J. Wiley, Senior Chemist
- J. Rubert, Quality Assurance Site Supervisor - EP
- C. Endriss, Regulatory Engineer
"J. McElwain, Auditor
- G. Murphy, Technical Support Health Physicist
- R. Titilo, Applied Health Physicist K. Walsh, Engineer L. Wells, Radwaste Physicist 1.2 Vendor Personnel
- J. Ferguson, Radwaste Consultant
- K. Folta, Quality Control Site Supervisor - OPS
- denotes attendance at the exit interview on September 19, 1985.
2.0 Purpose The purpose of this routine safety inspection during the start-up phase was to review the following areas:
Status of Previously Identified Items Concerning the Licensee's
Radioactive Waste Management Program.
Radiation Protection Start-up Testing.
- Follow-up of Corrective Actions Concerning the August 1, 1985 and
September 7, 1985 Upset Events.
3.0 Status of Previously Identified Itams 3.1 (0 pen) Inspector Follow-up Item (352/85-26-01): Develop the following Radioactive Waste Management Controls; administrative pro-cedure for conduct of operations; liquid radioactive waste volume and liquid discharge goals; and qualification of radwaste supervisor.
The inspector noted that the station administrative procedure to describe the responsibilities and interfaces of the Radwaste Manage-ment Organization had been drafted, and the water balance program would be initiated after Start-up Testing.
The inspector discussed the assignment of a new radwaste supervisor and changes to the
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Radwaste Management Organization chart. As a management control, i
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the individual did not assume this duty until completing a one week training course in Radwaste systems, packaging and shipping require-ments and a one week turnover period with the former supervisor.
The licensee stated that the radwaste supervisor would be qualified by the Radwaste Engineer, in the applicable radwaste procedures by November 1, 1985.
This item rrmains open, and will be reviewed during a subsequent inspection.
3.2 (Closed) Inspector Follow-up Item (352-85-26-02):
Improve radwaste handlers understanding of radiation protection requirements.
The license conducted ten safety meetings with the radsaste handlers to reinforce appropriate radiation protection practices, such as
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frisking, the RWP process, ALARA, Whole Body Counting, and Radwaste Volume Reduction.
In addition, in response to IE Bulletin 79-19, support personne.1 attended an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> training courst, on radaaste classification packaging and shipping; and the foremen attended an 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> training course on radwaste syste:ns, classification packaging and shipping.
The inspector noted that some individuals did not meet the 70 percent criteria.
The licensee stated that follow-up training, including review of incorrect answers would be completed within one month.
3.3 (0 pen) Inspector Follow-up Item (352/85-26-03):
Status of the licensee's program for implementation of their Process Control Program (PCP) and readiness for radwaste shipment. The inspector determined that the licensee'had undertaken a major rewrite of the radwaste prccedure to clarify the responsible department and to streamline the procedures to ensure implementation of the PCP.
This rewrite delayed the licensee's plans for radwaste shipment from July to October, 1985.
In addition, three surveillance test procedures to ensure compliance with Section 5.4 of the licensee's PCP were in draf t.
The inspector noted these procedures were not available during the previous inspection, and the radwaste operations procedures with regard to dewatered resin transfer to high integrity containers and resin sampling were not revised to clarify the options available to the operator or to address representative sampling.
The licensee stated that all procedures necessary for the implemen-tation of the PCP would be completed by October 21, 1985 with the first shipment to follow within that week.
The inspector noted that the lirensee was storing temporarily 700 barrels of dewatered resins in a posted and secured location.
However, the licensee had not performed a 50.59 safety evaluation of this temporary radwaste storage area.
The licensee stated an 50.59 review would be completed.
This item will be considered unresolved pending completion of the safety evaluation (352/85-28-01).
The inspector also reviewed the Site Acceptance Test (SAT) for the licensee's computer assisted progran to ensure compliance with 10 CFR 61 and 10 CFR 71.
This test was conducted August 6-9, 1985 to
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verify the correctness of the DOSCON and scaling factor libraries, and the related assumptions used within the code.
The inspector noted that the SAT was accurately performed and included quality control surveillances.
The licensee also stated that further enhancement of the PAK-RAD program was being developed including, entering all known isotopes, all DOT classifications, and specific container types labels and markings.
4.0 Start up Testing:
Radiation Surveys Documents Reviewed Final Safety Analysis Report (FSAR), Chapter 14, " Initial Test a
Program" Start-up Test Procedure STP 2.0, Revision 1, " Radiation Measurements
- Main Body", dated September 13, 1984 Start-up Test Procedure STP 2.1-4, Revision 1, " Start-up Radiation
Surveys-Prior to Fuel Load", dated August 23, 1985 ANSI /ANS-6.3.1, 1980, " Program for Testing Radiation Shields in
Light Water Reactors (LWR)"
Review of the test procedures and test data indicated that the licensee was conducting startup radiation surveys in accordance with FSAR commit-ments and procedures requirements.
No unexpected levels of radiation were encountered. All reading were less than 0.2 mr/hr gamma and/or less than 0.5 mrem /hr neutron. The licensee PORC reviewed these test results on
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September 18, 1985.
This test will be repeated under Test Condition 3 (60% power) and TC 6 (100% power).
5.0 Follow-up of Corrective Actions Regarding Two Recent Upset Events 5.1 Unit 1 Radwaste Discharge to Unit 2 Pipe Tunnel Access Room on August 1-2, 1985 The description of the upset event, clean-up activities, and initial
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corrective and preventive actions had been discussed in NRC Inspec-tion Report 50-352/85-30. Discussed below are the two licensee's corrective actions that previously were identified but not completed:
Licensee Action No. 1 A third independent review of all Unit 1/ Unit 2 interfaces in
l radwaste piping will be completed.
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Findings The inspector noted that a third review of radwaste system
piping and instrument drawings (i.e. Systems 53, 54, 61, 62 64, 66, 67, 69 and 70) was completed. A comparison to the Unit 2 Safety Boundary Review Log was completed to determine, if all valves were blocked and tagged in accordance with procedure A-97, " Isolation Tag Control" This review also included system walkdowns and some isometric drawing reviews.
Based on this independent review, approximately twelve valves were identified that should have been tagged.
Of these, the licensee's preliminary findings indicated that seven valves in the Liquid Waste Collection System were not tagged; and if opened, the liquid would go to a Unit 2 sump.
Because of the August 1, 1985 event, all liquid collected at this Unit 2 sump would be pumped to Unit 1 for processing, therefore eliminating a potential for an unmonitored release pathway. However, the preventive action to pump any Unit 2 water to Unit 1 was a verbal administrative control.
At the time of the inspection, the result of this third piping /
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valve isolation review had not been evaluated by the PORC.
This item will be reviewed during a future inspection by the Senior Resident Inspector to review the actions taken by : e licensee, and to determine if a generic concern exists with agard to the other major system isolation / tagging reviews (352/El-28-02).
Licensee Action No. 2 All Unit 2 sumps will be sampled and analyzed prior to transfer.
- Findings The licensee was sampling all water from Unit 2 sumps prior to
transfer with the exception of water in Unit 2 systems that collected from hurricane Gloria.
The licensee in the future plans on collecting water from Unit 2 sumps into a Unit 2 tank where it could be recirculated for representative sampling.
This action will be review during a subsequent inspection (352/85-28-03).
5.2 Failure of the "A" RWCU Valve HV-1-07A and Resulting Resin Spill and Equipment Contamination on September 7, 1985 The description of the upset event and initial clean-up activities had been discussed in NRC Inspection Report 50-352/85-30.
Discussed below are the licensee's corrective and preventative actions, and status of recovery efforts:
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License Action No. 1
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i Prevent Filter /Demineralizer From Being Subject to Reactor
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Findings
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The inspector reviewed procedure S.45.8.A, Revision 2,
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" Regeneration of a Reactor Water Clean Up System (RWCU) Filter /
Demineralizer," dated September 11, 1985 and determined that the filter /demineralizer and upstream instruments and piping
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i would be isolated prior to RWCU pressurization.
The operator i
action now involves manually closing 45-1-39A and 45-1-39B
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The licensee preventative actions included review of the failure of HV-1-07A and similar system valves, and investigating
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the use of logic interlocks to ensure full closure before deisolatio1.
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In addition, the licensee submitted on September 19, 1985 a j
temporary procedure change which manually lifted PSV-1-67 for
three seconds to ensure that pressure relief valve PSV-1-67 had
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properly seated after lifting during the event.
The inspector noted that a safety review was performed for this procedure
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change. However, the inspector observed in the RW Control Room
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that a controlled copy of S.45.8.A, which did not have the
i attached temporary change notice, was revised inappropriately j
to reflect this procedural change.
The licensee stated they j
were unaware that the procedure was a controlled copy and had i
provided advance notice of the change to the operators for information only.
The licensee destroyed the procedure and drafted an administrative procedure for control of radwaste j
procedures. This item will be reviewed during a subsequent
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j inspection (352/85-28-04).
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j Licensee Action No. 2
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l Control Contamination and Decontaminate RWCU Frecoat Tank Area
I and the "A" Holding Pump Room
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Findings
The inspector reviewed Radiation Work Permits RWP Nos. 100-85-122
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and 100-85-123, which controlled the initial surveys and decon-tamination work on the 318' Reactor Building area around the
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l precoat tank. The inspector noted that the initial survey out-side the holding pump room indicated contamination levels in excess of 800 mrad /hr on September 7, 1985. There was no air-
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1 borne radioactivity measured with regard to the resin spill or clean up operation.
tion efforts averaged 20,000 dpm/100cm2, Contamination levels durin 1985, the area outside the holding pump room was reclaimed.and by Septem Decontamination of the holding pump room was to start the fol-lowing day.
The inspector noted contamination control measures included isolation of the 318 elevation followed by installation of a tent enclosure.
Although respirators were initially used, the majority of the decontamination was performed using beta shields 6.0 Exit Interview
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The inspector met with the licensee representatives (denoted in section 1.0) on September 19, 1985.
and findings of the inspection.The inspector summarized the purpose, scope At no time during the inspection was written material provided to the licensee by the inspector.
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