IR 05000352/1988005

Insp Repts 50-352/88-05 & 50-353/88-03 on 880208-12.No Violations Noted.Major Areas Inspected:Radiological Environ Monitoring Program,Including Mgt Controls for Implementation of Meteorological Monitoring Program

ML20148C488
Person / Time
Site:	Limerick
Issue date:	03/16/1988
From:	Bell J, Kottan J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20148C461	List: IR 05000352/1988005 ML20148C455
References
50-352-88-05, 50-352-88-5, 50-353-88-03, 50-353-88-3, NUDOCS 8803220408
Download: ML20148C488 (8)

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t U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-352/88-05 50-35S/88-03, Docket No.

50-352 50-353 License No.

NPF-29 Priority

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Category C

CPPR-107

Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

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Facility Name:

Limerick Generating Station, Units 1 & 2 Inspection At:

Limerick, Pennsylvania and Philadelphia, Pennsylvania Inspection Conducted:

February 8-12, 1988 Inspector Yn -

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. S////98 11, Sen'mr Radiation Specialist crate

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'f 3 ~/ '/ ' ?? 6 J. J. Kottan, Radiation Laboratory date

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Approved by:

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sciak, Chief I dite'

F W. J. (P)ts Radiation Protection Section Effluen t

FRSSB, DRSS Inspection Summary:

Inspection on February 8-12, 1988 (Combined Inspection Report Nos. 50-352/88-05; 50-353/88-03 Areas Inspected:

Routine. announced inspection of radiological environmental

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monitoring program, including: management controls for these programs; the licensee's program for quality control of analytical measurements; imple-mentation of the radiological environmental monitoring program and the meteorological monitoring program; training and qualifications of personnel involved with these programs; and licensee action on previously identified items.

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Results: Within the areas inspected, no violations were found.

8803220408 880318

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Details 1.

Individuals Contacted Limerick Generating Staticn J. Sabados, Sr. Chemist R. Dubiel, Plant Services Superintendent J. Rubert, QA Site Supervisor K. Folta, QA Engineer D. Neff, Compliance Engineer F. Roak, Supervising Engineer Technician G. O'Donnel, Technician Testing and Laboratories Division (King of Prussia)

J. Smerke, Sr, Engineer Philadlephia Electric Company (PECO) Corporate Office

• G. Rombold, Engineer

• K. Mandl, Supervisor NQA A. Diederich, Supervising Engineer

• A. Marie, Supervising Engineer J. Ballantine, Engineer

• G. Hunger, Jr. Manager Mechanical Engineering

• W. Baxter, Supervisor NQA R. Smith, QA Lead Auditor Contractor Individuah

• D. Wahl, Environmental Consultant J. Kostige, Environmental Consultant J. Moreland, Lead Auditor B. Kirkpatrick, Lead Auditor

• Denotes those present at the exit interview.

2.

Licensee Action on Previously Identified Items (Closed) Follow-up Item (352/86-08-01): Audit of the radiological environmental monitoring program (REMP). Audit No. AL 86-29PL was performed on April 10-23, 1986 which is within the 12 month 25%

Technical Specification (TS) requirement for oudits of the REMP.

The previous audit was performed in October 2, 1984 to January 18, 1985.

(Closed) Follow-up Item (352/86-08-02): Teledyne Isotopes retest of TLDs for compliance to ANSI N545-1975, paragraph 4.3.3, dependence of exposure interpretation on the length of field cycle.

The retest was commenced on October 21, 1986 and all test results were within the requirements of ANSI N547-1975, paragraph 4.3.3.

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(Closed) Follow-up Item (352/86-08-03): Maintenance of REMP training records in the Nuclear Records Management System (NRMS).

The inspector reviewed data indicating that the appropriate records were maintained as req"ired.

3.

Management Controls The inspector reviewed the licensee's management controls for the radiological environmental monitoring program (REMP) including assignment of responsibility, program audits, and corrective actions for identified inadequ.cies and problem areas in the program.

3.1 Assignment of Responsibility The inspector reviewed the organization and administration of the REMP.

The program is conducted by licensee contractors and a PECO engineer is responsible for oversight and review of the contractors'

performance.

Currently, a corporate reorganization is taking place.

The REMP was administered from the Mechanical Engineering Division of the Engineering and Research Department, but will now be administered by the newly created Nuclear Engineering Department.

Within the Nuclear Engineering Department the REMP will reside in the Engineering Division, Nuclear and Environmental Section.

REMP Samples are collected by one contractor, Radiation Management Corporation (RMC), and the samples are analyzed by another contractor, Teledyne Isotopes.

Environmental thermoluminescent dosimeters (TLDs) are also provided by Teledyne Isotopes with exchanges performed by RMC.

3.2 Audits The inspector reviewed licensee audits of the REMP. Audits of the REMP implementation were performed by the Quality Assurance Division of the Electric Production Department.

This Department is separate from the Department (Engineering and Research) in wh.ch responsibility for the REMP was located.

The REMP implementation audits include both PECO and RMC. Audits of Teledyne Isotopes are carried out by the Quality Assurance Division of the Engineering and Research Department. Under the current reorganization the above departments, Electric Production and Engineering and Research, will be dissolved and their QA Divisions will become part of the Nuclear Quality Assurance Department.

The inspector reviewed the following REMP audits conducted by the QA Division of the Electric Production Department:

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Audit No. AL-86-29PL; April 10-23, 1986

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Audit No. AL-87-49PL; April 6-30, 1987 The inspector also reviewed the following audits of the Offsite Dose Calculation Manual (0DCM)/ Liquid and gaseous Effluent Release T

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Audit No. AL86-1850; March 17 - April 25, 1986

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Audit No. AL87-3450; March 9 - April 10, 1987 Audits of the REMP are required once per 12 months by the Limerick Technical Specifications (TS).

Procedure QADP-6, Quality Assurance Division Aud:t Program, Appendix A, contains the audit schedule

'hich implements this requirement.

In addition, Procedure NRB-3,

'.its, ensures that the Nuclear Review Board is made aware of the Qn audits, finding and resolutions as required by the Limerick TS.

The inspector reviewed the following audits of Teledyne Isotopes conducted by the QA Division of the Engineering and Research Department:

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AR#D-091, September 23-26, 1986

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AR#0-154, September 23-25, 1987 The above audits covered Teledyne Isotopes' QA/QC program and the implementation of the laboratory QA/QC program.

Through discussions with licensee personnel and a review of schedules, the inspector determined that Teledyne Isotopes was scheduled for annual audits.

The audits were performed by a qualified lead auditor.

However, the inspector discussed with the licensee the inclusion of a technical specialist in the audit so that the contractor laboratory's technical capabilities and performance as well as it's QA/QC program could be evaluated.

The inspector also noted that the contractor laboratory's TLD program was not included in the audit check list. The licensee stated that the TLD program would be included in future audits.

The inspector stated that the inclusion of the TLD program in future audits would be reviewed during a subsequent inspection.

(352/88-05-01; 353/88-03-01)

The inspector noted that the audits performed by both QA Divisions appeared to be both quite thorough and of sufficient technical depth to adequately assess capabilities and performance in the areas being audited.

In addition to audits, the engineer in the Mechanical Engineering Division who is responsible for the Lime-ick REMP also performs technical reviews of the contractor laboratory.

The responsible

engineer stated that these technical reviews are conducted as often as necessary to ensure that the contract laboratory is meeting PEC0 requirements.

The inspector reviewed the two most recent technical reviews:

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Performed December 3-4, 1984 Performed November 5-6, 1987

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The inspector had no further questions in this area.

No violations were identified.

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4.

Implementation of the Radiological Environmental Monitor Program The inspector reviewed the implementation of the licensee's REMP by discussions with the licensee, by review of reports and by direct observation.

The inspector concluded that the licensee has in place an effective REMP which conforms to TS requirements.

The inspector examined selected environmental monitoring stations including water sampling stations, air sampling stations for iodines and particulates, and TLD locations.

In addition, the inspector also witnessed a milk sample being taken. All equipment at these stations was operating at the time of the inspection with one exception, a water sampling station.

In this case, grab samples were being taken as required. The inspector also reviewed records for calibration and maintenance of the air sampler and vacuum gaJges, and found that these calibrations were performed as required by the licensee's procedures.

The inspector reviewed the Annual Radiological Environmental Operating Report for 1986.

The report provided a comprehensive summary of the results of the REMP around ti,e Limerick Gene ating Station, and met the TS reporting requirements.

Exceptions to the program, such as missing data, were noted and explained.

The inspector also reviewed the available new 1987 REMP data.

No violations were identified in this area.

5.

Meteorological Monitoring The inspector examined the licensee's meteorological monitoring including the primary meteorological towers, the recorder charts in the equipment house of the primary meteorological tower, and the recorder charts for both the primary and secondary :.eteorological towers in the control room. All instrumentation appeared to be operating properly at the time of this inspection.

The inspector reviewed the Surveillance Test Procedures for calibration of the wind sp?ed, wind direction, temperature and AT sensors on the two meteorological towers. The inspector reviewed selected records of those calibrations and determined that they had been performed as required by the procedures and at the frequency required by the TS.

The inspector also reviewed Procedure RT-11-00449, Check Procedure for the Limerick Meteorolog cal System, which requires inspections of the meteorological systems twice par week. The inspector reviewed selected data 'adicating that the checks were performed as required by the procedures.

la violations were identified in this are.

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6.

Quality Assurance The licensee described the methods used by its contractor laboratory,

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Teledyne Isotopes, to assure the accuracy of its analytical measurements.

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.These include participation in the EPA crosscheck program, an intra-laboratory program for analysis of spiked, split, and blank samples, and a program for analysis of duplicate and replicate samples from various locations and sample media within the Limerick Generating Station radio-logical environmental monitoring program. The quality of environmental

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TLD measurements is supported by two programs: A study to demonstrate compliance with USNRC Regulatory Guide 4.13 ("Performance, Testing, and

' Procedural Specifications and Thermoluminescence Dosimetry: Environmental Applications"), and periodic participation in the International Environ-mental Dosimeter Intercomparison Project.

The inspector reviewed selected quality control data submitted to the licensee by its contractor. These data indicate that the contractor's results are for the most part, in agreement with the EPA values and that

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its intralaboratory results are normally in agreement with the actual l

values.

For those instances in which the results did not agree, reasons for the differences were investigated and the discrepancies were resolved.

Generally good agreement was noted among the licensee's duplicata and replicate samples.

The final data from the most recent International Environmental Dosimetry

Intercomparison Project (the eighth intercomparison) was not available at the time cf this inspection and will be reviewed during a subsequent inspection.

In addition, however, the NRC maintains a direct radiation

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l monitoring network around selected licensee facilities including power reactors.

Selected NRC TLDs are co-located with licensee TL0s.

The data from the co-located TL0s around the Limerick site for 1986 and 1987 are presented in Table I. The results of the comparisons between the NRC and th-licensee are generally in agreement.

No violations were identified in this area.

7.

Training

s The inspector discussed the training program for PECO personnel involved with the Limerisk REMP with the licensee.

Procedure NES 2.0, Procedure

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for Specification of Qualificatior s of Personnel in Radiological Envi-I ronmental Monitoring and Indoctrination and Training, delineates the specific training required for personnel associated with the Limerick REMP. A review of training records for 1986 and 1987 indicated that the appropriate personnel had received the training as required by the procedure.

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The inspector also reviewed the licensee's sample collection contractor, RMC, training procedures as well as selected training and retraining records for 1986 and 1987.

Procedure NQ-5, Employee Training and Certification, specifies the required training.

RMC is providing the training to sample collection personnel as required.

No violations were identified in this area.

8.

Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on February 12, 1988 at the PECO corporate offices.

The inspector summarized the purpose and scope of the inspection and discussed the inspection findings.

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l Table I Comparison of Co-located TLD'Results TLD Location Monitoring Period NRC Licensee 1986 1987 1st qtr 2nd qtr 3rd qtr 4th qtr 1st qtr 2nd qtr 3rd qtr

5.9 0.2 6.6 0.2 7.5 0.3 6.6 0.2 6.2 0.3 6.8 0.2 6.8 0.2 29El 6.3 0.5 7.8 0.3 6.1 0.2 6.8 U.1 6.2 0.1 6.7 0.1 6.210.2

'll 7.4 0.3 8.1 0.3 8.4 0.3 8.4 0.3 7.7 0.3 7.9 0.3 7.110.3 3101 8.6 0.7 9.8 0.3 7.6 0.4 9.1 0.3 7.810.1 8.6 0.3 8.110.3

6.0 0.2 6.9 0.2 7.2 0.3 6.9 0.3 6.710.3 6.7 0.2 6.510.2 35B1 6.8 0.4 8.0 0.4 6.4 0.3 7.4 0.4 6.3t0.2 7.110.4 6.7 0.1

6.6 0.2 7.3 0.2 7.6 0.3 7.6 0.3 6.7 0.3 5.910.2 7.2 0.3 1501 7.2 1.3 9.1 0.5 7.1 0.2 8.3 0.3 6.6 0.4 7.6 0.3 7.3t0.2

4.6 0.2 5.2 0.2 5.5 0.2 5.5 0.2 5.4 0.2 5.2 0.2 5.110.2 13C1 5.1 0.4 6.0 0.3 4.6 0.2 5.9 0.2 4.9 0.0 5.5 0.3 5.110.1 Notes:

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Results are in units of mR/std. mo.

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The NRC uncertainty is the random uncertainty at one standard deviation.

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The licensee uncertainty is two times the standard deviation of the mean result.

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