IR 05000352/1987004

Safety Insp Rept 50-352/87-04 on 870112-16.No Violation Noted.Major Areas Inspected:Radiation Protection Program, Including ALARA Planning for First Refueling Outage,Internal Exposure Control & General Employee Training

ML20211P087
Person / Time
Site:	Limerick
Issue date:	02/18/1987
From:	Dan Collins, Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211P073	List: IR 05000352/1987004 ML20211P069
References
50-352-87-04, 50-352-87-4, NUDOCS 8703020289
Download: ML20211P087 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-04 Docket N License No. NPF-39 Priority Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia Pennsylvania 19101 Facility Name: Limerick Generating Station Unit 1 Inspection At: Limerick Pennsylvania Inspection Conducted: January 12-16, 1987 Inspectors: u% _

E o Itps/ Radiat%ii Specialist date 1///

FacilitiM Radiation Protection Section Sn T. Drago M enior Radiation Specialist date L/iPh?

Facilities Radiation Protection Section

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Approved by: 9:V/. 67M/ ~

'2. // g k 7 M. Shanbaky,'Ch1Ef

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date Facilities Radiation Protection Section, EPRPB, DRSS Inspection Summary: Inspection on January 12-16, 1987(Report No. 50-352/87-04)

Areas Inspected: Routine unannounced safety inspection of the licensee's radiation protection program including: ALARA planning for the first refueling outage; internal exposure control; and general employee trainin Results: No violations were identifie DR 870219 ADOCK 05000352 PDR

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Details 1.0 Persons Contacted 1.1 Licensee Personnel

• J. Spencer, Superintendent-Plant Services R. Barclay, Physicist-Dosimetry and Bioassay

• B. Bolger, Physicist-Respiratory Protection

• R. Dubiel, Senior Health Physicist E. Firth, Site Training Coordinator P. Hetzner, Assistant Instructor K. Jeffers, Engireer R. Leddy, Physicist-Plant ALARA G. Matson, Outage Planning T. Mscisz, HP Supervisor <

• D. Neff, Compliance Engineer

• D. Rombold, Physicist-Radiation Protection

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• J. Rubert, QA Site Supervisor W. Lexter, Maintenance Supervising Engineer

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• Titolo, Applied Health Physicist 1.2 NRC Personnel

• E. Kelley, Senior Resident Inspector

Attended the exit interview on January 16, 1987 2.0 Purpose The purpose of the routine inspection was to review the licensee's radi-ation protection programn with respect to the following elements:

i ALARA Planning for the First Refueling Outage

Internal Exposure Controls

General Employee Training 3.0 ALARA Planning for the First Refueling Outage The status of the ALARA program and ALARA planning for the first refueling outage were reviewed with respect to criteria contained in:

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10 CFR 20.1 Purpose

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Regulatory Guides 8.8 and 8.10

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Station Procedures HP-301, HP-302 and A-83

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Corporate Radiation Protection Manual, revision 1 The licensee's performance relative to these criteria was determined from:

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Discussions with the Senior Health Physicist, Physicist-Plant ALARA, Outage Planning Engineer, Maintenance Super-vising Engineer, and Applied Health Physicis Review of Status reports and an itemized list of ALARA projects.

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Within the scope of this review no violations were identified. Weaknesses in the ALARA program were identified previously during inspection 86-1 These weaknesses are generally associated with poorly defined interdepart-mental ALARA responsibility and a lack of aggressive support by top man-agement. Additional weakness noted during this inspection includes a failure to comply with guidelines provided by the Corporate Radiation Protection Manual and assignment of full responsibility for ALARA review of Plant Design Modifications to the site ALARA Physicist and HP techni-cians. This is not good engineering practice nor does it meet the intent of NRC guidance. The licensee is aware of these problems and advised that a recent corporate reorganization will result in increased attention to resolving some of these weaknesses in the near future. This matter will be reviewed in a future inspection (87-04-01)

Licensee strengths were also noted as follows:

The Senior Health Physicist and his staff have been very active in con-tacting other departments on site to arrange briefings for workers and supervisors regarding the site HP program. This has been effective in achieving cooperation and support from these departments for ALARA and other program The tentative exposure goal for 1987 has been set at 150 man-rem. This goal includes exposure from the Spring Refueling Outage and operations during the remainder of the year. Achieving this goal would indicate excellent ALARA performance. Outage planning is proceeding satisfactor-ily. Job tracking is accomplished by a computer program ("PREMS") with data access controlled by the outage planning group. Approximately 1/2 of the outage tasks have been entered thus far. However, no information will be relayed to the HP department until a sort of tasks requiring an RWP is completed. The inspector discussed with the licensee the need for the HP department be provided read-only access to the outage data to allow better preplannin .0 Internal Exposure Controls The licensees internal exposure controls program was reviewed with respect to criteria contained in:

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10 CFR 20.103 Exposure of individuals to concentrations of radioactive materials in air in restricted area TechnicalSpecification6.11RadiationPrjo'ectionProgram

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Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program"

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Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection" i

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Regulatory Guide 8.26, " Application of Bioassay for Fission and Activation Products"

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NUREG_0041, " Manual of Respiratory Protection Against Airborne Radioactives Materials"

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ANSI N343-1978, " Internal Dosimetry for Mixed Fission and Ac-tivation Products"

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Station Procedures: HP-213, HP-214, HP-512, HP-513, HP-514, HP-515, HP-518, HP-516, HP-649, HP-650, and HP-652

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Corporate Training Manual

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Corporate Radiation Protection Manua Licensee performance relative to these criteria was determined from:

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Interviews with supervisors, technicians, training instructors and medical personne bservation of classroom training and fit testin Review of training and qualification program for contracted

"Radwaste technicians" who inspect, repair and issue respir-ator Tour of facilities including: training center; medical exam facility; whole body counter; mask issue cage; respirator in-

, spection repair and storage traile Within the scope of this review, no violation was note Inspector observations are as follows:

4.1 Training of Respirator Users The lesson plans for training respirator use are technically thorough and formally issued with a mechanism to control changes. The major-ity of the instructors are contractors who are experienced and very knowledgeable. Training classrooms are located in a new building soon to be designated as the Personnel Processing Center. These tacilities are well equippe .2 Fit Testing Respirator fit testing is accomplished using a corn oil mist in a standard (Dynatech) booth. The equipment is operated and maintained by trained and qualified contract technicians (Bechtel National).

The methods used follow generally accepted industry practic _ _ _ - - _ _ _ _ _ _ _ _ _ _ _

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4.3 Medical Evaluation A medical evaluation of workers is provided onsite by a Physicians Assistant or Registered Nurse after completion of classroom trainin The pass / fail criteria are determined by the corporate physician. The parameters evaluated follow standard practice. The results are entered into a computer network that is accessed by the HP department to verify a workers status prior to issuing a respirato .4 Respirator Cleaning, Inspection and Repair Respirators are cleaned and disinfected at an offsite facility. On return, they are inspected, repaired, and stored ir, a special onsite facility by qualified Bechtel technicians. The proper repair parts and procedures are obtained from the manufacturer through the licen-sees controlled stock ordering system. All repaired respirators are tested on a special fixture prior to issu .5 Respirator Issue Respirators are issued only from the locked " respirator cage" located inside the power block by designated technicians. Workers names must appear on a computer generated list prior to receiving any respira-tory protection equipment. The control of equipment appeared to be very goo .6 Whole Body Counter The whole body counter (WBC) is a commercial moving bed design with a sodium iodide detector. The detected spectrum is fed to a multi-channel analyzer for isotope identification. However, the installed library is limited to 17 isotopes. A comparison with reactor water analysis shows that the isotope mix likely to be ingested by workers in the plant is significantly different from the isotopes screened by the WBC. The licensee stated that the WBC isotope library was re-viewed and approved based on an analysis of radiological hazard However, this justification could not be located during this inspec-tio This matter will be reviewed in a future inspection (87-04-03)

The WBC was calibrated in June 1985 using a mix of a isotope provid-ing a gamma photon spectrum from 88 Key to 1836 Kev. The activity conversion factors were determined by placing the isotope mix in a point source geometry inside a plastic body phantom. Since this calibration, the equipment is source checked prior to each shift using a Co-60/Cs-137 source. The licensee was requested to review the adequacy of infrequent (>l year) calibrations of the WBC. This matter will be reviewed in a future inspection (87-04-04)

4.7 Air Sampling The lapel air sampler (breathing zone sampler) is normally used to assess uptakes, determine protective actions, and determine if a whole body count is required. Each sample is analyzed for particu-i late and iodine activity, field counted and then laboratory counted if significant activity is detected. Intakes (MPC-hours) are cal-culated by technicians with any Intake exceeding 20 MPC-hours subject

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to a formal review. The air sampling program appears to be well controlle .0 General Employee Training The licensee's General Employee Training program (GET) was reviewed with respect to criteria contained in 10 CFR 19.12 Instruction to Workers. The adequacy of this program was determined from:

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Discussions with instructors and the Training Coordinator

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A review of lesson plans, instructor qualification program, quizzes and selected record Observation of classroom presentations and a tour of facilitie Within the scope of this review no violations were identified. A licensee strength was noted as follow All instructors must complete a formal qualification program and demonstrate technical knowledge as well as ability to teach prior to teaching a class alone. The licensee identified a need to increase the instructors level of technical knowledge to that equivalent to an experienced ANSI qualified HP technician. To accomplish this, an in-service training program for instructors was initiated with com-pletion scheduled for early 198 .0 Exit Interview The inspector met with the licensee representatives indicated in Section 1.1 at the conclusion of the inspection on January 16, 1987. The scope and findings of the inspection were presented at that time.