IR 05000016/1986002
| ML20210Q822 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/24/1986 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20210Q796 | List: |
| References | |
| 50-016-86-02, 50-16-86-2, 50-341-86-29, NUDOCS 8610070038 | |
| Download: ML20210Q822 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-016/86002(DPSS);50-341/86029(DRSS)
Docket Nos.50-016; 50-341 License No. DPR-9; NPF-33 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Enrico Fermi Nuclear Power Station, Units 1 and 2 Inspection At:
Fermi Site, Monroe, MI Inspection Conducted: August 25 through September 14, 1986 n
Inspector:
R. A. Paul
[-@b8d
Date s?
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f Approved By:
L. R. Greger, Chief Facilities Radiation Protection Section Date Inspection Summary Inspection during August 25 through September 14, 1986 (Reports No. 50-016/86002(DRSS); 50-341/86029(DRSS))
Areas Inspected:
Routine, unannounced inspection of radiation protection and solid radwaste activities including: organization and management control; training and qualification; exposure control; control of radioactive materials and contamination, surveys, and monitoring; facilities'and equipment; maintaining occupational exposures ALARA; solid radwaste; IE Information Notices; and licensee's actions on previous inspection findings. The inspection also included a review of allegations concerning unauthorized removal of radioactive waste from the site and weaknesses in the radiation protection program.
Results:
No violations or deviations were identified.
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8610070038 860925 PDR ADOCK0500g6 n
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L DETAILS
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1.
Persons Contacted
- R. Anderson, Supervisor, Radiological Engineer
- 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
- D. Graedinger, QA Specialist H. Higgins, Health Physics Supervisor - Operations
- S. Kremer, Supervisor - Nuclear Processing
- R. Lenart, Plant Manager
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W. Rogers, Senior Resident Inspector
- Denotes those present at the exit meeting.
The inspector also contacted several other members of the licensee's i
staff.
2.
General This inspection, which began at 1:00 p.m. on August 25, 1986, was conducted to examine the routine aspects of the radiation protection
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and solid radwaste activities during normal operations, and to review
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anonymous allegations concerning unauthorized removal of radioactive material from the site.
The inspection included tours of the reactor,
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turbine and radwaste buildings, and review of license records and reports.
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General housekeeping was good.
i 3.
Licensee Action on Previously Identified Open Items i
a.
(Closed) Open Item (341/85029-02):
No shielding provided in the
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radwaste barrel readout area nor provisions for remote readout.
The
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licensee has installed a system designed to remotely read and smear
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DAW barreled radioactive waste.
The. inspector verified the system was installed.
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(0 pen) Open Item (341/86015-02):
Installation and testing of b.
radiation monitors for the installed breathing air system.
The licensee has not, and does not, intend to use the station air system for breathing air purposes.
The licensee intends to install the monitors at the first refueling outage, currently scheduled for 1988.
c.
(Closed) Violation (341/86015-03):
Failure to follow procedures concerning whole body count requirements. The licensee's corrective action is documented in Inspection Report No. 50-341/86015 and is
considered adequate by the inspector.
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d.
(0 pen) Open Item (341/86015-01):
Extensive use of tygon tubing to control valve leak-off for contamination control.
The licensee has identified and logged the valve. leaks.
Some valve leaks have been repaired and tygon tubing has been removed; however, the use of the tygon will continue until the reactor system is under more pressure to determine if the repaired valves resume leaking.
The licensee's objective is to reduce the use of tygon tubing. This will be an ongoing program.
e.
(0 pen) Open Item (341/86002-01):
Followup / disposition of CST spill which occurred on November 17, 1985. The status of this open item is discussed in Inspection Reports No. 50-341/86002 and 50-341/86027.
During this inspection it was noted that an unmonitored and unplanned release of approximately 2400 microcuries of tritium occurred into the environment, and that approximately 200 microcuries of cobalt 58 and 60, chromium 51.and manganese 54 were found in the top four inches of soil due to the release. The licensee is currently discussing with NRR the disposition of the soil and is considering recovering and stor:ng the contaminated soil until final disposition is determined.
This item will remain open pending resolution of this issue.
4.
Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including changes in
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the organizational structure and staffing, effectiveness of procedures and other r.ianagement techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.
The Assistant Radiation Protection / Chemical Engineer and General Supervisor, Health Physics acts as the RPM and reports to the Supervisor / Radiological Engineer, who reports to the Plant Manager. The current health physics staff consists of the RPM, two health physics supervisors, five health physics lead technicians, and twenty-four health physics technicians.
In addition, the health physics operations group has thirty contractor persons who provide job coverage including routine and special surveys; the contractor personnel are integrated into the licensee's staff performing the same functions.
The health physics staff also receives support from the radiological engineering and radiological health sections of the staff, both of whom report to the RPM in his function as Assistant Radiation Protection / Chemical Engineer. The licensee intends to decrease the size i
j of the contractor health physics staff after the required startup surveys
are completed and plant operations achieve stable conditions.
i The RPM has one management position between himself and the plant manager;
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however, the RPM also has organizationally an alternate direct reporting
line to the plant manager.
The RPM and plant manager have direct communications when either person considers it necessary or expedient. The RPM's concerns are given due consideration and plant manager access is
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utilized when necessary.
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During the inspection it was noted that twelve contractor technicians are assigned to the dosimetry and respiratory protection sections of the health physics organization.
It was further noted that, under the supervision of-a licensee supervisor, the major part of the respiratory protection functions (fit testing, mask repair, etc.) are performed by these contrac-tor technicians, who the licensee has sent for additional offsite training.
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The inspector cautioned the licensee that inordinate dependence on contract personnel to perform radiation protection functions may prevent license staff members from developing needed experience and skill levels to perform these tasks. This matter was discussed with the licensee at the exit meeting and will be reviewed at a future inspection (50-341/86029-01).
The-licensee recently fonned a radiation protection committee to increase radiological awareness and to initiate radiological control in the plant by i
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implementing the " Radiological Control Improvement Plan." The effective i
use of this comittee, and the improvement plan should alert the licensee -
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to identified real and potential radiological control problems, and provides i
a mechanism to correct the problems / weaknesses to sustain a good program.
As part of the committee's responsibilities, radiological incidents /
j deficiencies will be reviewed. Minutes of the first comittee meeting j
were reviewed by the inspector.
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5.
Staffing All permanent technicians and senior contractor technicians reporting to
.the health physics supervisors are ANSI N.18.1-1971 qualified. To date, the licensee has had a low staff turnover rate, which has resulted in what appears to be strong staff stability.
6.
Training and Qualifications The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and methods; qualifications of radiation protection personnel; and provisions for appropriate radiation protection training for station personnel. Also
reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
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The current " General Employee Training - Radiation Protection" training
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I program at Fermi was certified by the Institute of Nuclear Power Operations (INP0' on June 14, 1984. Radiation protection technicians are additionally requ' red to complete training in position and task oriented courses.
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Selected portions and course material were reviewed by the inspector during
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an inspection performed in April 1984 (Inspection Report No. 50-341/86015).
Based on this review, it appears the program meets the intent of
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Section 12.15 of the FSAR which states that " company personnel will be
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i trained in radiation protection procedures and techniques that are i
applicable to their job function."
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Although the technicians who perform only external exposure evaluations have not received any formal off-site training in the Panasonic TLD systems, they are required to satisfactorily perform practical factor
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applications before they are qualified to operate the system. The licensee is considering formal training to be accomplished in the near future.
These technicians are ANSI N.18.1-1971' qualified.
Training for technicians who perform only whole body count and internal
' dosimetry evaluations have received in-house training and are required to satisfactorily perform operation of the whole body count systems and to make internal dosimetry assessments.
The licensee has intensified. training for these technicians as a corrective action for a problem which occurred in' January 1986 and which was discussed in Inspection Report No. 50-341/86015. These technicians are ANSI N.18.1-1971 qualified.
7.
External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.
The licensee reads the TLD results with an installed in-house Panasonic TLD system, and is NAVLAP certified in six of eight categories; the other two categories pertaining to accident range response will be done in the near future.
Although there is currently no contractor TLD QA comparison program, the licensee intends to develop a QC program with the University of Michigan in the near future.
Procedures have been developed and approved for calibration of the TLD readers, processing TLDs'on the automatic and manual TLD reader, TLD element correction factor determina-tion, TLD dosimetry QC, and standardization of the TLD irradiator.
The procedures appear to sufficiently cover the scope of the external dosimetry program; several procedures were reviewed by the inspector with no problems found.
Based on the inspector's review, it appears the licensee has the necessary requirements to operate a good external dosimetry program.
The inspector verified that the licensee is using the NRC guidance-specifying that whole body dose should be determined using a maximum
absorberthicknessof1000mgm/cm when eye protection is provided.
Safety glasses (> 700 mgm/cm ) required for entry into the power block.
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The licensee's personnel dosimetry system uses an absorber thickness of
1000 mgm/cm for whole body dose determination.
No problems were noted.
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8.
Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including:
changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessments; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meets regulatory requirements; required records, reports, and notifications; and effectiveness of management techniques used to implement these programs.
The licensee's programs for controlling internal exposures include the use of protective clothing, respirators and equipment, and control of surface and airborne radioactivity.
The inspector selectively reviewed the licensee's relevant whole body count (WBC) procedures, the WBC facility and equipment, and discussed the WBC program with the HP Supervisor for dosimetry and the RPM. Based on this review, it appears the licensee has the necessary requirements to operate a good internal dosimetry program. Certain weaknesses were noted concerning lack of specific mechanisms to ensure that whole body counts are performed during out-processing to meet procedural requirements.
This matter was discussed with the RPM who stated the matter will be reviewed and corrections made where necessary (50-341/86029-02).
9.
Respiratory Protection Selected aspects of the licensee's respiratory protection program were reviewed.
In addition to an expiration date, workers' respiratory qualification cards indicate their qualifications related to respiratory protection. This includes their medical evaluation, proof they have received required training, and the type of respirators they are qualified to wear.
In order to receive a respirator, the workers turn in their qualification card at the respirator distribution location, the worker receives the card back when the respiratory is returned.
The inspector reviewed selective relevant respiratory protection procedures concerning the cleaning, drying, survey, storage, and distribution facilities, and discussed the general scope of the respiratory protection program with the health physics supervisor for internal dosimetry. No significant problems were noted.
10. Radiation Startup Surveys Startup surveys made in accordance with procedural requirements are discussed in Inspection Report No. 50-341/86015. Additional surveys were taken during power ascension for recent startup at approximately 3.5 percent. The surveys were perfcnned at locations where higher radiation
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fields would be expected; these areas included the feed nozzle platform, off-gas pump rooms, reactor water cleanup, pump rooms, steam tunnel and certain radwaste areas. These surveys were selectively reviewed by the
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inspector; no problems were noted.
The licensee will continue to perform the startup surveys required by startup procedures between five to
twenty percent power levels.
11.
Facilities and Equipment
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The inspector toured selected areas of the plant which are related to radiation protection and radwaste.
Toured were the access control area, laboratories, counting room, decontamination facilities, whole body count room, protective clothing and respirator cleaning facility, instrument calibration facility, office areas, and radwaste building.
It appears that the licensee has sufficient space to adequately conduct operations.
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Ample storage areas for protective clothing, respirators, and equipment
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have been provided.
Sufficient portal monitors, whole body friskers and
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portable friskers are available for use.
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t The licensee's principal ingress and egress control point to the radiologically controlled area (RCA) is located near the entrance to
.the auxiliary building from the service building.
Personal frisking
and equipment surveys, performed at the control point, can be observed
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from the radiation control station.
Another control point will be established during high traffic occasions.
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12.
High Radiation Area Access Control The licensee's primary method for controlling access to high radiation
areas (HRAs) consists of locked entrances with a procedural system for exercising positive control over individual entries by using specific
radiation work permits (RWPs) and health physics control of HRA door keys. With the exception of routine surveillance, the licensee does not F
l have a mechanism to ensure that HRA doors, gates, and barricades are closed upon worker egress.
This weakness was discussed with the RPM who stated this matter would be reviewed.
13.
Solid Radwaste System
l The licensee uses a portable solid radwaste treatment system (NUS) to meet
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their technical specification requirements. The system, which is located
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in the radwaste building, is currently operable and is operated by NUS l
contractor personnel in accordance with approved licensee procedures.
The-inspector observed the system while processing mixed bed bead resins, r
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discussed the use of the system and the method of determining curie i
content and drum testing with radwaste personnel. Tours of the radwaste
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storage facility were also made; no problems were noted.
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14.
IE Information Notices
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l The inspectors reviewed licensee action in response to the following selected Information Notices. These actions are considered adequate.
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No. 85-81: Problems Resulting in Erroneously High Reading with Panasonic 800 Series Themoluminescent Dosimeters (TLD's). The licensee currently uses'Panasonic TLD's and has implemented QC procedures for receipt and inspection of each TLD to provide appropriate action in response to this Infomation Notice.
No. 85-42:
Loose Phosphor in Panasonic 800 Series Badge Themoluminescent Dosimeter Elements. Same response as to No. 85-81 above.
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No. 86-22: Under response of Radiation Survey Instrument to High Radiation Fields. The licensee does not use the Eberline Model ESP-1 with a MP-290 gamma probe.
No. 85-43:
Radiography Events at Power Reactors The licensee has implemented a procedure which requires additional health physics controls performed by the licensee during radiographic operations in the station.
15. Surveillance Plant Tours The inspector toured the plant with the health physics supervisor; several discrepancies were noted. The discrepancies included improper placement of personal dosimetry, improper labelling of material, uncontaminated protective equipment found in area controlled for contamination, and contaminated protective clothing in unauthorized receptacles. The inspector discussed this matter at the exit meeting and stressed the importance of management attention and support for a strong staff surveillance program to identify and correct observed radiological control problems.
16. Allegation Followup i
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(Allegation No. RIII-86-A-0130):
Disposal of radioactive material from the Fermi Station in a Canton, Michigan landfill.
j This allegation was reviewed during this inspection; however, further review is needed to resolve the matter.
Findings from this i
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and future inspection activities will be documented in a future i
inspection report.
b.
(Allegation No. RIII-86-A-0083): Radiation Protection program j
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l Allegation: On May 6, 1986, Region III received a telephone call from the licensee regarding a Safe Energy Coalition press conference held in Detroit, Michigan t'e same day at which a former Fermi n
health physics technician made allegations that the Fermi radiation
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frequent procedure changes, and had procedures written by unqualified
individuals.
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Discussion: After unsuccessfully attempting to obtain specific information to support the general allegations made at the press conference from the Safe Energy Coalition, a certified letter dated August 29, 1986, was sent to the former health physics technician stating that Region III was interested in discussing his concerns pertaining to deficiencies which exist in the radiation protection program at the Fenni site.
The August 29, 1986 letter was returned to the NRC Region III office on September 14, 1986 annotated " REFUSED".
NRC radiation specialist inspectors have made routine inspections of the Fermi 2 radiation protection program over the last several years in order to determine the licensee'.s preparedness for fuel load and power operation. Those inspections, which included a review of some similar allegations of radiological control problems in April 1986, have not identified any uncorrected problems which would significantly degrade the licensee's ability to implement an adequate radiation protection program to support fuel load and power operation.
Based on the lack of specific information from the Safe Energy Coalition or the former health physics technician to support the general allegations made at the May 6, 1986 press conference, and the previous NRC inspection findings in this area, this allegation is considered closed.
17. Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on August 28, 1986. The inspector summarized the scope and findings of the inspection. The inspector 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 certain items discussed by the inspector, the licensee:
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Acknowledged the comments concerning the use of contractor technicians for certain staff functions.
(Section 4)
b.
Stated their awareness of the need to support a strong identification and correction program for radiological control problems.
(Section 15)
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