IR 05000016/1986001
| ML20211E340 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/04/1986 |
| From: | Greger L, Hueter L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211E304 | List: |
| References | |
| 50-016-86-01, 50-16-86-1, 50-341-86-15, NUDOCS 8606130323 | |
| Download: ML20211E340 (15) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-341/86015(ORSS); 50-016/86001(DRSS)
Docket No. 50-341;50-016
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i Licensee:
Detroit Edison Company 2000 Second Avenue
i Detroit, MI 48226
Facility Name:
Enrico Fermi Nuclear Power Station, Units 1 and 2 l
Inspection At:
Fermi Site, Monroe, MI Inspection Conducted: April 21-24, 1986 j
Inspectors:
d-Y-80 Date
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Date
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Approved By:
L. R. Greger, Chief 6-/-6(a j
Facilities Radiation Date i
Protection Section i
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Inspection Summary
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Inspection on April 21-24, 1986 (Reports No. 50-341/86015(DRSS);
50-016/86001(ORSS))
Areas Inspected:
Special unannounced inspection regarding allegations
concerning the radiological protection program.
The inspection also included l
the review of startup test surveys, the circumstances concerning the
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termination of a radiation protection technician, and an incident concerning the whole body count program.
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l Results: One violation was identified (failure to follow a procedure requiring j
a whole body recount when an action point is exceeded - Section 6).
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i 8606130323 860604 PDR ADOCK 05000016 G
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DETAILS 1.
Persons Contacted
- L. Baumgart, Workleader - Training J. Bobba, Assistant Radiation Protection / Chemical Engineer and General Supervisor, Health Physics
- S. Bump, Health Physics Supervisor - Dosimetry
- J. Cohen, Engineer - Licensing
- R. Eberhardt, Radiation Protection Chemical Engineer
- H. Higgins, Health Physics Supervisor - Operations
- S. Latone, Director - Nuclear Training
- R. Lenart, Plant Manager
- W. Lipton, Senior Engineer
- M. Prystupa, General Supervisor - Chemistry
- J. Tozser, Senior Engineer W. Rogers, Senior Resident Inspector
- Denotes those present at the exit meeting.
The inspectors also contacted several other members of the licensee's staff.
2.
General This inspection, which began about 1:00 p.m. on April 21, 1986, was conducted to review anonymous allegations concerning the radiological protection program, and certain aspects of the startup and whole body count programs.
Several tours of the facility were made during the inspection.
3.
Allegations Several allegations regarding the radiological controls program at Fermi Nuclear Station were received at Region III by telephone on March 21, 1986.
The allegations were given anonymously.
In review of the allegations, the inspectors contacted department managers, health physicists, foremen, engineers, and technicians.
The inspectors reviewed administrative and radiation protection records; sections of the FSAR; survey, air sample, training, and personnel qualification records; and logs.
The inspectors noted that recent improvements concerning radiation protection technician training and experience level have addressed certain of the allegers concerns.
No violations related to the allegations were identified.
The allegations which are presented below have been paraphrased from the telephone conversation.
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Allegation a.
Sodium drumming (Fermi 1) was done without regard for radiation protection.
The operations people wanted the drumming completed as soon as possible and the drumming operation did not conform to good health physics principles, b.
Too many sodium filled drums were stacked in the Fermi 1 storage area and respiratory protection was not provided.
c.
The only personal protection equipment furnished were gloves and welders' eye shields.
No respirators were provided.
(Fermi i sodium drumming and storage area)
Discussion a.
The sodium filled drums have been shipped; essentially all sodium has been removed from Fermi 1.
The drum filling operation could not be observed by the inspector.
Radiation protection coverage was apparently provided during the drumming operation.
This coverage was confirmed by the inspector based on a selected review of survey records for the period August 1983 through September 1984.
b.
Although no sodium filled drums remained onsite, the drums were apparently stored four on a pallet, three pallets high, in the past.
No requirements concerning drum stacking were identified by the inspectors.
No known problems were identified to have resulted from the stacking used in the past, c.
Respiratory protection was not provided because air samples taken in the area indicated air concentrations were below levels which require respiratory protection.
The inspector reviewed selected air sample results taken in the drumming and storage area from August 1983 through September 1984, during the drumming operation. This review confirmed respiratory equipment was not required.
These allegations were not substantiated.
Although respirators were not provided, no requirement for their use was identified.
Based on the inspectors' review it appears that sufficient radiological controls were provided during the drumming operation.
Allegation The Fermi 1 facility was improperly posted.
Also, a person could enter the contaminated drumming area from the turbine hallway and not know that he had entered a radiation area from the turbine hallway because the area was not posted at that hallway.
Discussion According to licensee personnel interviewed, during the time sodium filled drums were located in the facility, entrances were posted as Radiation Areas in accordance with their procedural requirements; however, this could not be verified by the inspectors since the sodium filled drums have
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been removed from the site.
During a walkdown of the facility the inspector noted that all facility entrances were currently posted in accordance with regulatory requirements for existing radiological conditions.
The licensee indicated there were no entrances from the turbine hallway into the drumming area; this was confirmed during the inspector's walkdown of the facility.
The allegation could not be substantiated.
It was determined that no entrance existed to the drumming area from the turbine hallway.
Allegation Fermi 1 facility was a mess and no one cared about cleanliness.
Discussion Discussions with licensee radiation protection personnel who worked in the facility indicated that contract workers and a custodian were assigned to maintain cleanliness and good housekeeping during the drumming operation.
The personnel interviewed did not indicate any significant housekeeping problems existed in the past in the Fermi 1 facility.
During a walkdown of the current facility the inspector did not note any significant cleanliness or housekeeping problems in the drumming and storage area.
This allegation was not substantiated.
Allegation The Fermi 2 breathing air system was inadequate in the following respects.
The breathing air system shares much of the same piping with the
system used to "backflush spent resins" and no check valves were installed to prevent contamination of the breathing air.
The breathing air system did not have any in-line radiation monitors
installed.
The breathing air system was almost non-existent in many places and
contained only a minimal amount of piping and a "few CARD 0X bottles."
Discussion The licensee currently does not have a dedicated, installed breathing air system.
Instead, the licensee has provision for using mobile systems utilizing bottled air or compressors.
The licensee has on several occasions provided breathing air by use of bottled air or mobile compressors while taking measures to ensure that standards for breathing quality are met.
The station air system, which does interface with two contaminated systems (radwaste system and reactor water cleanup system), has not been used to date for breathing air purposes.
Licensee personnel stated that station air may never be used for breathing air purposes, and in any case will not be used for breathing air purposes until appropriate monitors are
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installed on the station air system.
These monitors, which include locations near the interfaces with the contaminated systems, are currently scheduled to be installed during the first refueling outage. The station air system is designed to preclude contamination of the system.
A review of current drawings of both the radwaste system and the reactor water cleanup system verified the existence of both a check valve and at least one additional valve at the interfaces of these systems with the station air system.
Installation and testing of these monitors and valves will be reviewed during subsequent inspections, before the licensee utilizes the station air system for breathing air purposes.
(50-341/86015-02)
The CAR 00X system is a self contained system which provides carbon dioxide gas for fire extinguishment.
This system has no physical ties to the station air or mobile breathing air systems.
The allegation that the breathing air system is inadequate was not substantiated in that mobile systems currently are available and planned modifications of the station air system appear adequate to allow use of that system for breathing air purposes.
Allegation Five hundred radiation sources had been received at Fermi over the years; the alleger was assigned to inventory those sources and many were missing.
The alleger could not specify how many sources were missing and stated that some were controlled by 10 CFR 19 and 20.
The alleger indicated that many of the missing sources were from SPINGS and PINGS.
Discussion In June 1983, the licensee discovered that seven radioactive sources (six cesium-137 sources of up to nine microcuries each and one 22-millicurie cesium-137 source) could not be accounted for. The licensee initiated an investigation and found that the six sources had been disposed of in a radwaste shipment which was sent offsite on January 10, 1983; the sources were inadvertently omitted from the radioactive waste shipping papers.
The seventh source was still onsite in a radwaste barrel.
This matter was reported to the NRC on June 7, 1983, and is discussed in Inspection Report No. 50-16/83-01 and 50-341/83-26.
As a result of this matter, the licensee's procedures concerning radioactive material receipt, accounta-bility, and inventory were reviewed.
Procedure 67.000.21, " Accountability of Radioactive Sources", has been strengthened so that 100% inventory of licensed sources is required every six months and verification of five percent of these inventories is made by the HP Supervisor - Operations.
The latest radioactive source inventory indicates all 204 licensed sources are accounted for.
The inspector reviewed selected procedures to ensure there was adequate control and accountability of radioactive sources.
No problems were found.
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Each of the licensee's Eberline PING-3 units has provision for four small response sources; each SPING-3 unit has provision for five small response sources; and the one SPING-4 unit has provision for six small response sources.
Through review of inventory records, observations of labels on each unit, and selected observation of instrument response, the inspectors verified that all sources associated with these PING and SPING units were present and accounted for.
The allegation was not substantiated.
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Allegation l
The following concerns were identified with SPINGS/ PINGS.
The Fermi 2 SPINGS and PINGS were improperly piped (e.g., pipe runs
too long, pipe too narrow) to be able to obtain a "true reading."
Three-fourth inch diameter pipe was used in 300' to 400' runs between the collection point and the applicable SPING/ PING unit which is too long to obtain accurate readings.
Some of the SPINGS/ PINGS calibration technicians (not named) were
unqualified.
Many of the SPINGS/ PINGS devices were not properly calibrated because
the calibration devices were not calibrated.
The SPING/ PING calibration procedures did not adequately incorporate
NUREG guidance.
Discussion NUREG-0737 does provide guidance for calibrations of certain iodine, particulate, and noble gas monitors.
However, this guidance does not apply to the monitors in question (SPINGS/ PINGS), which are not " accident" monitors.
No specific guidance is provided by NRC for calibration of these monitors; their calibration therefore should be in accordance witn general calibration techniques.
The inspectors found that the licensee's SPING/ PING calibration procedures appear to meet calibration criteria specified in NUREG-0737 (even though not required to do so) as well as generally accepted calibration / transfer techniques.
To address the allegation that SPING/ PING were not properly calibrated because the calibration devices were not calibrated, the inspectors reviewed selected calibration records for SPING/ PING units for identifi-cation of gas and solid sources used as well as devices used during the calibration such as oscilloscopes, voltmeters, flow meters, and pulsers.
The inspectors' review of licensee records showed that all such sources were calibrated and traceable to NBS and that all other calibration devices used had not exceeded their respective calibration due dates.
To address the alleger's concern that some of the calibration technicians (not named) were unqualified, the inspectors reviewed licensee records of the initial calibrations performed in the Fall of 1984 for the SPING/ PING monitors and observed names of 13 individuals involved with the
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I calibrations.
Of these 13 individuals, only three were DECO personnel and of these three only one was classified as an instrument technician (a senior instrument technician); the other two were a Chemical Engineer and the General Supervisor of Chemistry (non-technicians).
The senior instrument technician had been hired from another nuclear utility where he had specialized in calibration of SPING/ PING units and met technician qualification specification in ANSI N18.1-1971.
The other ten individuals were contractor personnel (from KLM, ATLAN-TECH, and IMPEL) who were specifically hired for a period of several months to develop calibration procedures and to expedite initial calibration of the SPING/ PING monitors (as well as other plant monitors).
Although resumes of these ten contract individuals were not immediately available during the inspection, most were professional level people with bachelor or advanced degrees involving subjects as Chemistry, Physics, Engineering, and Radiation Protection, plus many years of experience in the health physics field (not technicians).
According to statements made by some of these ten individuals who still work at the facility, either as contract personnel or now as DECO employees, the few who did not have degrees were selected
for the job because of their previous experience and training and were stated to have met the technician qualifications specified in ANSI N18.1-1971.
Further, their work was reported to have been directly supervised by the more highly qualified individuals.
The alleger stated that 3/4" diameter pipe was used in 300' to 400' runs between the sample collection point in effluent ducts and the SPING/ PING
units, a distance which is too long to obtain accurate readings.
This is an apparent reference to puential sample line loss for radioiodine and radioactivity in particulate form.
The licensee calculated potential sample line loss in a similar sampling system for both trains of the standby gas treatrrent system (SGTS) in early 1985 based on published reports of iodine species in BWRs (nonaccident conditions) and on line
losses based on such factors as line material, line length and diameter, flow rate, relative humidity, etc.
This evaluation showed negligible line losses for both iodine and particulates (less than 20%).
This conclusion appears reasonable for the nonaccident systems (SPINGS/ PINGS).
The allegations were not substantiated.
Allegation None of the plant's radiation protection instrumentation was properly calibrated since the calibration devices had never been calibrated to a
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l National Bureau of Standards standard.
Discussion The inspector reviewed calibration of the licensee's J. L. Shepherd and Associates Model 28.5 calibrator which has a nominal 100 mci Cs-137 source
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and is used extensively in calibration of radiation protection instrumentation.
The initial calibration was performed by the vendor on December 3, 1980.
The vendor's calibration data included a radiation
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source certificate which inicates that the calibration was directly
traceable to NBS.
Records reviewed show that this calibrator was subsequently calibrated at the licensee's facility on November 15, 1983,
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December 29, 1984, and on November 26, 1985.
All three calibrations were performed using a calibrated R chamber certified as traceable to NBS.
The allegation was not substantiated.
Allegation The air condition system for the Reacto'r Fuel Floor, the fifth floor, has never worked properly; 48-inch diametes portable fans were installed to circulate the air on a permanent basis.
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Discussion The reactor building vent system 'provides makeup and exhaust air for the refueling floor.
The system was not fully operable at the time of fuel receipt, and temporary fans mounted on the ceiling and on ductwork were used to circulate air for personal comfort. This system was operable
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before fuel load..Since fuel load, none of the temporary fans have been used, and the power supply and many of the temporary fans have been removed.
According to licensee personnel interviewed, the fans were never intended to be used permanently.
No prohibitions for the use of the temporary fans were found, nor were there any requirements for the operability of the HVAC system during fuel receipt.
Although temporary fans were used to augment the refuel floor ventilation, the allegation that this arrangement was needed on a permanent basis was not substantiated.
Allegation The Radiation Protection Superintendent for Operations (RPS0), was not qualified for his position.
According to the alleger, the RPS0 has six years of experience in the U.S. Navy and did not have any experience at a commercial power plant.
The alleger stated that the RPS0 was required to have two years of commercial power plant experience-to hold his position.
Discussion The position referred to by the alleger is that of Health Physics
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Supervisor - Operations (HPS0)..The FSAR requires that the person who fills the HPS0 position meet the criteria in Section 4 of ANSI N18.1
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(1971), " Selection and Training of Nuclear Personnel," at the time of the I
initial Fermi 2 core loading.
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An inspection review of the HP50 work experience indicates he meets the specified ANSI N18.1 requirements.
Although the FSAR does not specify requirements for experience at a'Eommercial power plant for the HPS0
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i position, the individual filling the HPSD position worked at an operating nuclear station for approximately sii weeks in 1984.
Although the HP50 does not have significant commercial nuclear power plant experience, the allegation that he requires two years cosmercial nuclear power plant experience and therefore is not qualified for his position was not substantiated.
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Allegation Nothing has ever been done to fix a leak in the drywell area.
According to the caller, the " circulating" water pumps leak and have never been repaired.
The only thing that has been done is to rope off the area and post it as a radiation area.
Discussion Although there are " circulating" water pumps located inside the drywell, according to the licensee there has not been a problem with radioactive leakage from these pump.
The NRC resident inspectors confirmed that their extensive plant tours have not identified leakage problems from "circulat-ing" water pumps in the drywell.
The licensee has identified some leaking valves on the Hydraulic Control Units (HCUs) outside the drywell on the main reactor floor.
In general, to prevent floor contamination from the leaking valves, tygon tubing is used to discharge the leakage into floor drains.
According to the licensee the HCU areas have never been roped off or posted for radiological conditions.
The inspectors selectively reviewed the results of routine surveys of HCU areas for 1985 and found no radiation reading which would have required the posting of a radiation area sign.
The inspectors verified that tygon tubing is used to transfer valve leakage to floor drains from the HCU valves and leaking valves from other systems located in the reactor building.
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The inspectors expressed concern about the extensive use of tygon tubing-to control valve leak-off for contamination control.
Licensee management stated they share this concern and have developed a dedicated and ongoing program to repair valve leaks. They also stated that many of the valves have been repaired, but cannot be tested until the systems are operable.
This matter was discussed at the exit meeting and will be reviewed at a future inspection.
(50-341/86015-01)
Although the specific allegation was not verified, a need for additional attention to leakage from radioactive systems was identified.
Licensee response to this concern was acceptable.
Allegation l
Radiation protection personnel do not routinely monitor the dressing area.
l Therefore, many employees ignore requirements to " double bootee" or
" double glove." A " bad attitude" exists on the part of the employees when dressing.
Discussion While the licensee does not have a specific requirement to physically I
monitor workers dressing out, radiation protection personnel are l
instructed to ensure workers are adhering to RWP protective clothing and equipment requirements during their routine plant activities.
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inspectors spoke to several radiation protection technicians concerning l
workers' attitudes about protective clothing wear; in addition, the
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licensee has a mechanism (radiation occurrence report) for recording instances of poor radiation protection practices by workers.
No significant problems concerning protective clothing requirements were identified based on these discussions and selective review of radiation occurrence reports.
Although the licensee does not routinely monitor the protective clothing dress-out areas, no significant problems were identified concerning workers' utilization of protective clothing.
Allegation Fermi 2 does not have procedures or has inadequate procedures in the following areas:
No procedure to compare air monitoring results to MPC hours / minutes.
- No procedure to specify when nasal smears are to be taken.
- Inadequate procedure to specify when whole body counting should be
done.
No trend analysis program for air sampling.
- No procedure to specify when to use protective clothing and equipment
under the ALARA Program.
Discussion Health Physics Procedures 61.000.06, "MPC-Hour Determination," effective through January 1986, and 63.000.32, " Air Sample Collection, Analysis, and MPC Calculation", effective since January 1986, are used to determine MPC-hours from air sample results.
These procedures were reviewed by the inspector and found adequate.
Health Physics Procedure 63.000.21, " Contamination Survey Techniques, Personnel", approved March 1985 specifically designates when nasal smears should be taken.
The inspector reviewed this procedure and found it adequate.
Health Physics Procedure 61.000.07, " Bioassay Program", approved June 1985, specifically designates when whole body counts shall be taken.
The inspector noted the criteria for whole body count requirements were sufficient.
Tne licensee has not developed any procedures to require trend analysis for air sampling.
However, the licensee can observe air concentration trends at certain air sampling stations and computer print out terminals.
The licensee is considering developing an air sampling analysis program.
Although there is no specific ALARA program procedure to specify when to use protective clothing, Procedure 12.000.13, " Radiation Work Permit", is used to specify protective clothing and equipment requirements for existing radiological conditions.
This arrangement is satisfactory.
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Except for a lack of a defined air sampling trend analysis program, the allegations were not substantiated.
Although there is no requirement for a defined air sampling trend analysis program, it is a good practice and the licensee is evaluating implementation of such a program.
Allegation Operations personnel expect the radiation protection personnel to enter the Condenser Well to take radiation readings.
The alleger noted that based on his experience at other nuclear power plants, the Condenser Well will be an extremely high radiation area during operations and should not be entered.
Discussion Entry into the Condenser Hotwell Bay during operations, as well as other plant areas, will be governed in accordance with existing radiological conditions.
Routine surveys of plant areas with very high radiation levels will not be made if those areas are not expected to be routinely entered.
Instead, specific surveys will be made to support the entries.
Additionally, Procedure 63.000.10, " Radiological Survey Techniques",
cautions that if radiation protection personnel encounter radiation levels greater than five times those previously noted from other surveys, they are to exit the area immediately and consult health physics supervision.
This provision is intended to minimize exposures to radiation protection personnel due to significant changes in previously measured radiation fields.
No specific requirement for routine condenser hotwell surveys was found.
The allegation was not substantiated.
Allegation Many health physics technicians were hired without any prior experience.
Their inexperience was demonstrated in the low scores they achieved in their qualification examinations.
Also, Hydro Nuclear identified this problem during an audit and Detroit Edison did not take any corrective action.
Discussion There are no licensee aquirements to hire health physics technicians with previous commercial nu.;ar power plant experience.
Of the current radiation protection technician staff (twenty-six technicians), nine are without commercial nuclear power experience, two have six months or less of commercial experience, and 15 have greater than six months commercial experience.
All technicians are ANSI N.18.1-1971 qualified based upon a combination of their experience at Fermi and their previous health physics experience at other, non-commercial nuclear power facilities.
An audit of the licensee's radiological control program was performed by Hydro Nuclear Services in 1983.
One of the audit findings addressed radiation protection technician inexperience, and in part stated that although a number of health physics technicians meet the guidelines of
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ANSI N18.1, 1971, they do not have sufficient training and working knowledge of a commercial BWR to support a working shift.
In response to the audit finding, the licensee's corrective action included sending all health physics technicians to participate in a health physics program at an operating BWR. A selected review of technician resumes indicated this training was accomplished.
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The inspector could find no comment in the audit concerning low scores achieved by the technicians in their qualification examination.
Although the allegation was partially substantiated, subsequent licensee actions to correct the weakness were acceptable.
Allegation The only real training at Fermi is in reactor operations.
All other training is done by computer.
The computer method has built in problems, including the wrong answers in the programs for breathing air and MPC-hours.
The computer programs do not use the latest reference material, including Regulatory Guides and 10 CFR 20.
The whole emphasis is on self-teaching and it's not effective.
Discussion The current " General Employee Training - Radiation Protection" training program at Fermi was certified by the Institute of Nuclear Power Operations (INPO) on June 14, 1984.
Radiation protection technicians are additionally required to complete training in position and task oriented courses.
Selected portions of the licensee's current employee and technician training program and course material were reviewed by the inspector.
Based on this review it appears the program meets the intent of Section 12.15 of the FSAR which states that " company personnel will be trained in radiation protection procedures and techniques that are applicable to their job function."
The Hydro Nuclear Audit, conducted in 1983, concluded that inordinate emphasis was being placed on self-teaching, which included computer self taught instruction.
Licensee initiated changes to the rad / chem training program have resulted in less than 10% of the current nuclear rad / chem training being computer self teaching.
The inspector and licensee personnel reviewed all of the relevant computer program modules which concern breathing air and MPC-hours, and none contained information pertaining to the alleger's concern.
The following modules were reviewed:
Internal Dosimetry (Parts 1 and 2); Airborne Radioactivity Surveys; Respiratory Protection; 10 CFR 20; and ALARA.
The inspector reviewed certain computer program modules and did not find Reg Guides referenced in those selected for review.
Reference material was found in almost all modules reviewed, including module " Internal Dosimetry" (Part II), which referenced ICRP-2 (1959), ICRP-9 (1965),
ICRP-26 (1977), and ICRP-30 (1978).
One computer training module is completely dedicated to 10 CFR Part 20.
A review of this module indicated sufficient reference material.
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While this allegation was partially correct at one time, subsequent changes to the training program have reduced the licensee's reliance on computer self-teaching.
Allegation Fermi does not comply with FSAR in HP and Operations.
The alleger did not give specific examples.
Discussion Without specific examples the inspectors were unable to adequately review this allegation.
However, numerous inspections have been made by NRC inspectors over the past several years to ensure the licensee has met FSAR commitments.
In addition, the licensee has developed the Regulatory Action Commitment Tracking System (RACTS) to monitor FSAR commitments.
A review of this system was made by the inspector; it was found to be adequate for ensuring FSAR commitments are met.
The allegation could not be substantiated due to lack of specificity.
4.
Radiation Startup Surveys Surveys were made to determine radiation levels in the plant before fuel load, post fuel load, and after initial reactor startup to ensure protec-tion of personnel during plant operation and to meet FSAR and procedural commitments.
The surveys were made in accordance with startup test procedures STUT.000.100, STUT HUA.002, STUT.00.001, and radiation and radiation protection procedure 63.000.10T.
Selected startup survey measurements of various reactor building locations under heat up conditions and less than 5 percent reactor power were reviewed by the inspector. The results of the surveys indicated that with the exception of two locations all others were less than or equal to 0.2 mR/hr for gamma dose rate.
The neutron dose rate was less than or equal to 0.8 mR/hr.
These radiation fields were within the licensee's acceptance criteria.
5.
Review of Licensee Actions Concerning a Discharged Employee A radiation protection technician was terminated from employment on November 27, 1985, for falsifying routine drywell radiological surveys.
The licensee informed an NRC Region III inspector of the incident and of the employee's termination.
The inspector advised the licensee that measures should be taken to ensure that no personnel were exposed to unknown radiation conditions as a result of the failure to perform the survey.
As a result, the licensee reviewed radiological surveys performed by other radiation protection technicians at the same locations as those surveyed by the discharged technician.
This review was performed for the period August through November 1985; the results indicated that the radio-logical conditions in the area had not changed substantially.
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6.
Incident Concerning a Whole Body Count of a Contract Worker On January 22, 1986, a dosimetry technician performed a required gain check on the Helgeson standup whole body counter (WBC) using a nominal 0.8 microcurie cobalt-60 check source.
The check was completed satisfactorily; however, the technician failed to remove the check source from the counter before a contract worker was subsequently whole body counted.
As a consequence, the worker's whole body count results were positive.
After the count, the technician realized the problem and removed the check source from the WBC; however, he failed to wait long enough for the counter to acquire a new background before counting the worker a second time.
The second count was also positive.
Because the technician was unable to explain the positive results from the second count, he requested assistance from another technician who instructed him to acquire a new background count and recount the worker.
By this time, the worker had left the office and recount was not taken.
On both occasions when the workers count results were positive, the WBC alarm
i sounded indicating an action point was exceeded.
Procedure 64.000.201, requires that when an action point on the standup WBC is exceeded, a count on the chair WBC be performed.
Failure to count the worker on the chair whole body counter, after an alarm on the standup WBC indicated an action point had been exceeded, is considered noncompliance with Technical
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Specification 6.11 and Procedure 64.000.201, Section 7.5.10 (violation).
To ensure that the worker's positive counts were the result of improper operation of the WBC, the licensee performed a test count on February 10, 1986.
The test included using a background count acquired with the check source in the counter, removing the source from the counter, counting an employee with the same approximate body structure as the contract worker, and comparing the results.
The results indicated that the positive counts for the contract worker could be attributed to the stored background acquired while the source was in the counter and not to actual contamination of the worker.
The inspector reviewed the test count results and found they were essentially the same as those for the contract employee.
During the week of February 17, 1986, the contract employee called the licensee and requested to speak to the Radiation Protection Manager (RPM).
The RPM was not on site and the designated RPM was unable to take the call.
A lead health physics technician spoke with the contract worker, took the worker's name and telephone number, and informed the dosimetry supervisor that an individual wanted to speak to someone about a whole body count.
The dosimetry supervisor then requested the internal dosimetry specialist to contact the worker, which he did.
The worker expressed concern about the way the whole body count was conducted and about a rash on the worker's skin which the worker suspected was caused by the check source on the WBC.
The specialist discussed the basic operation of the WBC and assured the worker that the rash could not have been caused by the source.
On March 18, 1986, the contract worker contacted NRC Region III to express concerns about the whole body count and the subsequent skin rash.
Region III then contacted the licensee's RPM and informed him of the contract workers' call and concerns.
The RPM had not previously been
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I aware of the incident.
On March 20, 1986, the RPM contacted the worker and set up an appointment for March 21, 1986, to discuss the worker's
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concerns and to perform a repeat whole body count.
The worker was unable to make the appointment and, to date, has not returned to the licensee's site for another whole body count.
The licensee's investigation of this incident revealed that the worker had never entered a radiologically controlled area and that the whole body dose received from the exposure to the 0.8 microcurie cobalt-60 source was less than 0.1 mrems.
Records of this dose assessment were reviewed by the inspector; the inspector agreed with the assessment.
The licensee has identified the rcot causes of the incident and has initiated corrective action to prevent recurrence.
The inspector reviewed the corrective actions and found them acceptable.
On May 2, 1986, the inspector contacted the contract worker and stated that the circumstances surrounding the incident had been reviewed by the NRC and that the licensee would discuss the incident with the worker and perform another whole body count, if so desired.
One violation was identified.
7.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on April 24, 1986.
Further discussions were held by telephone on May 15, 1986, informing the licensee of a violation.
The inspectors summarized the scope and findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as proprietary.
In response to items discussed by the inspectors, the licensee stated that a dedicated effort is being made to repair system valve leak (Section 3), and acknowledged the violation (Section 6).
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