IR 05000352/1989005

Safety Insp Repts 50-352/89-05 & 50-353/89-08 on 890130- 0203.No Violations Noted.Major Areas Inspected:Licensee Radiological Controls Program,Including Unit 1 Outage Activities & Changes to Health Physics Organization

ML20235Y545
Person / Time
Site:	Limerick
Issue date:	03/02/1989
From:	Shanbaky M, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235Y544	List: IR 05000352/1989005 ML20235Y541
References
50-352-89-05, 50-352-89-5, 50-353-89-08, 50-353-89-8, NUDOCS 8903140303
Download: ML20235Y545 (5)

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I-U$S.'NUCLEARREGULATORYCOMMISSION

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REGION I

w-Report Nos..89-05, 89-08-

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Docket Nos.-50-352, 50-353

.NPF-27-License Nos,

-CPPR-107-

. Priority

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Category C

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Licensee:

Philadelphia Electric Company

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2301 Market Street-.

' Philadelphia,-PA 19101 Facility Name:

Limerick Generating Station Unit 1 and Unit 2 Inspection Ati Limerick' Pennsylvania.

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' Inspection. Conducted: January 30, - February 3,;1989

. Ins'pectors: /

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W. Thomas, Radiation-Spec 44116t, Fac lities

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Radiation Protection.Section Approved by:

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M.Shanbaky, Chief,FacKtiesRadiation

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Protection Section

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Inspection' Summary:

Inspection on January 30 - February 3,1989 (Report

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- Fos.-50-352/89-05, 50-353/89-08 L

Areas Inspected: Routine, unannounced safety inspection of the licensee's radiological. controls program including Unit-1 outage activities, audits'and

' appraisals,_ changes to the health physics organization, external cxposure l

control, ALARA program, and status of previously identified items.

'Results: No violations were observed ar.d it was concluded that the radiological controls activities for the Unit-1 outage were being conducted in

.an appropriate manner.

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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company

• J. Burke, Nuclear Quality Assurance, Senior Auditor i

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• R. Dubiel, Superintendent, Plant Services

• G. Leitch, Vice President, Limerick Generating Station

• M. McCormick Jr., Plant Manager

• G. Murphy, Radiation Protection Manager

• W. Sakso, Licensing 1.2 NRC Personnel

• L. Scholl, Resident Inspector

• W. Thomas, Radiation Specialist, Region I

• Denotes attendance at the Exit Interview on February 3, 1989.

During the course of this inspection additional personnel were contacted or interviewed.

2.0 Purpose The purpose of this routine inspection was to review the licensee's radiological controls program with respect to the following elements:

Unit-1 Outage Activities l

• HP Audits and Appraisals

• Changes in the Health Physics Organization

• External Exposure Control and ALARA Program

• Status of Previously Identified Items.

3.0 Status of Previously Identified Items 3.1 (Closed) Inspector Followup Item (88-25-01) Completion of efforts to reduce or preclude iodine problems during the 1989 refueling outage j

will be reviewed in a future inspection.

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Prior to any system breaches, a period of two weeks was taken to allow for iodine decay, in addition air-line respirators were used for all initial system breaches as required by procedures. GMRI canisters (iodine absorbant) continue to be used when there is a possibility for iodine exposure, and all workers have been briefed regarding additional iodine precautions. This item is closed.

3.2 (Closed) Inspector Followup Item (88-25-02) Revise Procedure HP-109 to assure that high radiation areas are properly designated, and that doors are locked after use.

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Procedure HP-109,.High Radia' tion Area Key control,.was revised,

' dated. January 27,'1989, assigning the responsibility for designation-of. locked high radiation areas to the-Health Physics Supervisor, and the responsibility for ensuring the door is locked after use to the

. individual issued the high radiation area key.

4.0 Unit 1 Outage Activities-The major radiological activities which were reviewed.during this

, inspection were:

• steam separator move to the spent fuel pool-

• replacement of the bellows on the cross around relief valves removal of 14 main steam relief valves (MSRVs)-

• low pressure' turbine disassembly and inspection

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• feed water nozzle inservice inspection

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• hydraulic control unit environmental qualifications.and overhaul'

The licensee's efforts in advance planning and preparation _for the 1989 Unit I refueling outage have proven to'be effective in the areas of Airborne' Radioactive Iodine Control, reduction of area dose rates, and

'overall control of contamination throughout the plant.

The Radiation Protection Manager receives a daily print-out from the Nuclear Personnel and Radiation Work Permit (RWP) Tracking System, which gives the current Direct Reading Dosimeter (DRD) exposure summary...The fifteen

. ercent highest exposures by job group are highlighted for review by the p

Radiation Protection Manager. The inspector determined, through review

.of Personnel dosimetry records that, as of January 31, 1989, all plant l

personnel exoosures were within the Quarterly limits.

During the previous outage the Licensee implemented the " Area HP L

Coordinator" concept, which was effective in ensuring good radiological L

controis and ALARA practices. This concept has been continued for the L

refueling outage. Additionally, a senior HP technician who is authorized to change RWPs has been assigned on a twenty-four hour basis to the drywell and refuel floor control points to monitor and control radiologi-I cal conditions. Additionally,. Radiological Engineers to plan and coordi-

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nate outage work have been assigned to the refuel floor, drywell, control rod drive rebuild facility, turbine hall, Unit-2 interfaces, and reactor building 283 foot elevation. Overall, the Unit 1 outage radiological controls activities are being conducted in an excellent manner to date.

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E.0 HP Audits and Appraisals The inspector reviewed the licensee's program for the conduct of audits and appraisals of HP activities through interviews with selected Nuclear Quality Assurance (NQA) auditors, plant personnel, and a review of the

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most recent NQA audit conducted during July and August, 1988 by the NQA Group.

The audit was comprehensive and detailed, and addressed program-matic weaknesses that could adversely affect the quality of the radiation protection program.

In reviewing the audit the inspector was concerned that the response to the audit proposed corrective action indicated for one of the audit findings, concerning assurance that personnel exiting the Radiologically Controlled Area (RCA) properly frisk all items removed from the RCA, was not fully implemented in a timely manner (within 90 days). The licensee stated that full implementation of the proposed corrective cction will be achieved by the end of February 1989.

The inspector indicated that this item would be reviewed in a subsequent insnection.

6.0 Changes in the Health Physics Organization During the past year there has been a change in personnel in the Health Physics Services Section.

The Applied Health Physics Supervisor termi-nated employment at Limerick. This position was filled by the Radio-logical Engineering Supervisor (RES).

The RES position was filled by a transfer fror. the corporate office.

The minimal impact of these personnel changes indicates a good depth of experience within the organization.

It was also determined that these changes will not adversely affect the licensee's program for the control of radioactive materials, or radiation exposures.

7.0 External Exposure Control and ALARA Program The personnel dosimetry program is NVLAP accredited. A review of the personnel annual whole body exposure records for 1988 and for the month of January 1989 indicated that all personnel exposures were within the limits of 10 CFR 20. Personnel contamination reports for 1988 and 1989 were also reviewed.

All personnel contamination report cases are reviewed by an HP Senior Technician.

If the contamination is considered minor and easily removed the incident is considered closed.

If the contamination is major or the contaminating event is considered non-routine the matter is reported to the Contamination Control Program Coordinator for appropriate action..The licensee has also implemented a hot particle program to minimize'the potential for the,pread of contamination.

To date only one hot particle.has been found on a contractor's fuel sipping machine and investigation indicates that it did not originate at Limerick.

There have been no instances where an individual has exceeded an administrative dose limit.

Dosimeter placement and use by Plant Personnel is considered proper and comparison of TLD readings with DRD

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readings is completed at the end of each badge period.

Radiation Work l

Permit (RWP) generation is accomplished by an HP Senior Technician

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after review of the work to be accomplished.

During the outage, daily l

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planning meetings (are held with the Superintendent of Plant Services to discuss outage activities and plant status.. During these planning meetings, discussions are held concerning worker's dose status by work group and plant location.

L The ALARA pbogram is sound and is considered a licensee strength.

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ALARA program was discussed with several employees who indicated they understood their roll in the program and were actively involved in the program. ALARA goals have been set both for the refueling outage and'for the year.

Progress toward the goals are tracked on a monthly basis and l3 in cases involving high exposure potential, progress towards ALARA goals

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is posted at-the plant work area. As of January 31, 1989 the station total-Man-Rem for HP and NQA were slightly higher than the projected.ALARA goal for that time period.

This is not considered to be a problem at this time since the-over-all Man-Rem exposure was reasonably low; this area will be followed throughout the outage.

8.0 Worker Allegation On February 2,.1989, the inspector received an allegation (RI-89-A-002)

from a carpenter employed by a contractor. The worker became concerned about airborne radioactivity while working in the drywell when he observed a few other workers in respirators. The worker questioned the HP technician inside the drywell and others but felt that he was not provided with adequate information regarding the radiological conditions.

The inspector interviewed selected HP technicians assigned inside the drywcil, the outside drywell control point, and selected workers. The inspector reviewed the~ drywell radiation survey data and various RWPs in effect at the time.

Within the scope of this review, the inspector determined that there was no razard to the worker in excess of regulatory requirements. The inspector determined that the radiological conditions did not require the use of respirators.

The RWP was overly conservative in requiring certain individuals in the drywell to use respiratory protection equipment at that time.

In addition, the information provided to the worker was proper and appropriate. The inspector concluded that the allegation is without merit.

9.0 Exit Interview The inspector met with the personnel listed in Section 1.0 on February 3,1989 to discuss the scope and findings of this inspection.

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