IR 05000016/1987001

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Insp Repts 50-016/87-01 & 50-341/87-18 on 870406-10.No Violations or Deviations Noted.Major Areas Inspected: Organization & Mgt Control,Training & Qualification,Exposure Control & Control of Radioactive Matls & Contamination
ML20215L627
Person / Time
Site: Fermi  DTE Energy icon.png
Issue date: 05/07/1987
From: Greger L, Paul R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215L609 List:
References
50-016-87-01, 50-16-87-1, 50-341-87-18, NUDOCS 8705120306
Download: ML20215L627 (10)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

l Reports No. 50-016/87001(DRSS);No. 50-341/87018(DRSS)

Docket Nos.50-016;-50-341 Licenses No. DPR-9; NPF-33 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226

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Facility Name: Enrico Fermi Nuclear Power Station, Units 1 and 2 Inspection.-At: Fermi Site, Monroe, Michigan

'Inspecti.on Conducted:. A ri 6-10, 1987

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Inspector-P., A.'Pau '

5-7-67 Date Approved By:- L r

f S-7-87-

-Facilities Radiation Date Protection Section Inspection Summary Inspection during April 6-10, 1987 (Reports No. 50-016/87001(DRSS);

No. 50-341/87018(DRSS))

Areas Inspected: Routine, unannounced inspection of. radiation protection and transportation 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; and licensee's actions on previous inspection findings. The inspection report also includes documentation of an allegation'concerning unauthorized removal of radioactive waste from the site.

Results: No violations or deviations were identified.

8705120306 870507 PDR ADOCK 05000016 G

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DETAILS

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1.

Persons Contacted

  • F. Agosti, Vice President, Nuclear Operations o
  • R. Anderson, Supervisor, Radiological Engineer
  • J. Bobba, General Supervisor, Health Physics

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  • R. Eberhardt, Radiological Controls Engineer H. Higgins, Health Physics Supervisor, Operations R. Lennart, Plant Manager

'*F. Sondgeroth, Licening

  • W. Tucker, Superintendent Operations
  • C. Weber, General Supervisor, Rad-Waste

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  • M. Parker, Resident Inspector-
  • Denotes those present at the exit meeting. The inspector also contacted several other members of the licensee's staff.

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2.

General-This inspection, which began at 2:00 p.m. on April 6, 1987, was conducted to examine the routine aspects of the radiation protection and transportation activities. The inspection included tours of the reactor, turbine, and radwaste buildings and review of license records and reports.

General housekeeping was good.

B 3.

Licensee Action on Previously Identified Open Items a.

-(Closed) Open Item (341/86029-01): Dependence on contractor technicians for the major part of respiratory protection functions.-

The licensee has replaced all contractor personnel in the respiratory protection group with qualified licensee personnel.

b.

(Closed) Open-Item (341/86029-02):

Lack of specific mechanisms to ensure whole body counts are performed during out processing to meet

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procedural ~ requirements. The licensee revised the termination / layoff procedures for contractor personnel by allowing the licensee to hold up a workers' pay, and strengthened the out processing program for utility workers by issuing a monthly report to a Group, Vice President

identifying those workers who fail to adhere to the outprocessing-procedures so that the VP may take disciplinary action if necessary.

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The -licensee stated that from January through February 1987, no workers

failed to properly outprocess.

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'(Open) Open Item (341/86015-01): Extensive use of tygon tubing to.

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control: valve leak-off for contamination control. The licensee is'

continuing to' identify and log the valve leaks..Some valve leaks have been repaired and tygon tubing has been removed; however,-the

. use of the tygon will continue untti 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. See Section 12 of this report.

d.

(0 pen) Open Item (341/86002-01):

Followup / disposition of CST spill.

which occurred on November 17, 1985. -The status of this open ites-is discussed.in Inspection Reports No. 50-341/86002 and 50-341/86027.

A subsequent spill occurred in' November 1987, two weeks before the.

licensee installed an impermeable bottom to prevent leakage out of.

the diked area surrounding the CST. The released activity was below regulatory MPC limits and the dose effect was minimal. The licensee is currently discussir.g the disposition of soil from both spills with-NRR. This item. remains open.

4.

Oranization and Management Controls-The inspector reviewed'the licensee's organization and management controls.

for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.

The General Supervisor, Health Physics acts as the RPM.and reports to the Radiological Controls Engineer, who reports to the Plant Manager. -The current health physics staff consists of the RPM, one health physics supervisor, three health physics specialists,'six health physics senior technicians, and thirty-four health physics technicians.

In addition, the health physics cperations' group has twenty 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.

The licensee has decreased the size of the contractor health physics staff.

The most significant organizational change since the previous inspection (Inspection Report No. 50-341/86029)' consists of separating the administrative control of the Radiation Protection and the Chemistry Departments. The Radiological Controls Engineer no longer has responsibility for the Chemistry Department.

The Chemistry Department now reports to the operations group. This organizational change appears to'have strengthened the Radiation Protection Department in that the Radiological Controls Engineer can now dedicate more effort to the

. health physics: program.

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5.

Staffing All permanent technicians and senior contractor technicians reporting to health physics supervisors are ANSI N.18.1-1971 qualified. The licensee continues to maintain low staff turnover and experienced personnel. Since the previous inspection (Inspection Report No. 50-341/86029) there has been no permanent health physics staff turnover.

6.

Outage Planning and Preparation Operational health physics and radiological engineering personnel participated in preplanning meetings and were involved in major radiation jobs in advance of a recent maintainance outage. The person responsible for the ALARA program was involved in the planning of certain outage jobs, including the reactor water cleanup system work, snubber inspection and replacement, work in the steam tunnel, and replacement of welded steam taps. All outage work was accomplished on special RWP's; the senior lead technicians met with the shift supervisor at shift change; and according to licensee, shielding and other ALARA measures were taken during the outage.

7.

Radiation Startup Surveys Surveys were made to determine radiation levels in the plant with the reactor operating between 20 and 50 percent of rated core thermal power.

The inspector reviewed selected startup survey measurements made throughout the plant site; all measurements were found to be less than or equal to 0.2 mR/hr for gamma dose rate, except for 23 survey points in the reactor building and 17 in the turbine building.

The maximum dose rate in the reactor building was 100 mR/hr near the RWCU pumproom and the maximum dose rate in the turbine building was 12 mR/hr at the north access point to the East Reheater / Separator. The neutron dose rate in the reactor building was also measured and found to be less than 0.2 mR/hr except for one measurement of 0.5 mR/hr. The radiation dose rates found during these surveys are within the dose rates discussed in Seciton 12 of the FSAR.

This data, along with Area and Process Radiation monitoring data was reviewed by the health physics department and found acceptable according to their acceptance criteria.

8.

External Exposure Control The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including:

use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports and notifications.

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There have been no significant changes in the licensee's external exposure measurement and control program. The inspector selectively reviewed the exposure records for 1986 through April 1987, including TLD and self-reader dosimeter results and computer printout dose summaries. The records indicate that no persons exceeded regulatory requirements.

The occupational external dose totals for the station was 1.9 person-rem in 1986 and 2.7 person-rem in 1987 through April.

No violations or deviations were identified.

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Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and I

assessment programs, including:

changes in facilities, equipment,

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personnel, and procedures affecting internal exposure control and personal assessments; determination whether engineering controls, respiratory equipment, and assessment for 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 air sample and smear survey results taken during a recent maintenance outage; it appears that sufficient air samples were collected and analyzed during the outage. The inspector also selectively reviewed whole body count results for 1986 and 1987 to date; it appears no worker has exceeded the 40 MPC-hour control measure.

10. Audits The inspector reviewed an offsite audit of the radiation protection progran conducted in late 1986. The extent of the audit and the adequacy of corrective actions were reviewed with the licensee.

Based on the inspector's observations in those areas in which the audit identified some weaknesses, it appears the licensee's corrective actions have been adequate.

11. Facilities and Equipment The inspector reviewed the operation and calibration procedures for the Eberline Model PCM-1A whole body contamination frisker. The licensee demonstrated the use of the technician-99 (100 cm ) check source in

performing source checks for each zone of the frisker, no problems were identified. Calibrations have been performed and indicate that the efficiency of all detectors range from.05 cpm /dpm/100 cm to.09 cpm /dpm/

2 100 cm.

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12. Contamination Control During previous inspections (50-341/86015 and 50-341/86029) the inspector has expressed concern and cautioned the licensee about the extensive use of tygon tubing to control valve leak-off for contamination control. During this inspection the inspector observed an incident in which one of the I

tygon tubes connected to a feedwater valve in the north feedwater pump area in the turbine building became disconnected from one of several tygon " trees" in the area and released contaminated water ranging up to 100,000 dpm/100 cm onto the turbine building basement floor. The

tubing became disconnected, apparently due to the effect of higher temperature water flowing from the feedwater system causing the tubing connections to expand. No one was contaminated; however, if personnel were located in that area of the basement floor, they could have been severely contaminated. The leak was subsequently stopped and the basement was decontaminated.

The inspector observed another incident in the same area in which a radwaste worker was attempting to remove tape holding two pieces of tubing together at a connection so he could install a clamp to provide a more permanent and stable connection.

During this operation the tubing temporarily got out of the grasp of the worker and more contaminated water was spilled onto the grating, onto the shoes of the worker, and onto the basement floor. These observations were discussed with the licensee at the exit meeting and presented as examples of the kinds of incidents the licensee has been cautioned about and that are now occurring.

(341/86015-01)

13. Radiological Incident / Deficiency Report Radiological Incident Reports (RDR's) for 1987 to date were reviewed. The inspector noted that the licensee generally provides management attention to followup and review of investigations.

The RDR form provides for review l

by HP personnel, a designated reviewer, and the Onsite Review Organization (OSRO) for review and approval when applicable. Review of the RDR's indicated there was one significant incident involving HP and operations personnel that occurred off shift which resulted in an individual receiving unnecessary whole body exposure. The RDR indicated that the only review I

of this incident was performed by HP personnel and not by OSRO, even though the event was significant and both HP and operations personnel were invovled in the incident.

The RDR indicated that disciplinary actions were taken against a senior HP tech and proposed corrective action to prevent recurrence. However, because it was not sent to OSRO, it did not indicate that operations were apprised of the incident, and that the proper level of plant management was informed of the incident.

In discussing this matter with various licensee personnel it was determined that some management persons were aware of the incident, albeit not by use of the RDR, and that the operations personnel involved were cautioned

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concerning their actions during the incident.

After review of this matter, the inspector informed the licensee that a strong incident report system should be designed and used so as to ensure that cognizant management persons are aware of significant incidents and are involved in reviewing these incidents. This matter was discussed at the exit meeting.

(50-341/87018-01)

14.

Fermi Unit 1 With the exception of the shipment of the sodium drums in late 1984, the status of the Unit I reactor facility is essentially unchanged.

The inspector reviewed the Unit 1 procedures and annual report for the period July 1984 through June 1985, interviewed licensee personnel, reviewed survey results, and made a tour of the facility to assure radiological controls are maintained.

The results of this review indicated that required administrative and surveillance procedures are maintained and adhered to, and facility entrances and areas are posted and controlled in accordance with regulatory requirements for existing radiological conditions.

15. Transportation On April 2, 1987, the licensee identified and informed Region III that they failed to register as a user of an NRC radioactive material shipping cask (USA /9094/A) before they made a shipment of LSA waste on March 16, 1987. This was the first shipment of radwaste in this cask and the licensee was in compliance with all requirements of 10 CFR 71.12 with the exception of 10 CFR 71.12(c)(3) which requires the licensee to submit in writing to the NRC prior to the licensee's first use of the package the licensee's name and license number, and the package identification number specified in the package approval.

The licensee met the provisions of 10 CFR 71.12(c)(3) before the same cask was used for a second waste shipment on April 3, 1987.

The licensee identified their failure to comply with the requirements of 10 CFR 71.12 on April 2, 1987 during preparation of second shipment of waste (shipped on April 3, 1987) using the same cask.

Procedure "POMV95.000.34 - USA /9094/A Shipping Cask-User Checklist" is required for use in preparation for shipment of this cask to ensure adherence to 10 CFR 71 requirements. One of the procedure check-off activities includes verific'ation by the Radwaste Supervisor Shipping (RWSS) and the Radwaste Quality Control Examiner (RWQC) that the licensee is a registered user of the cask per 10 CFR 71.12(c)(3).

The licensee used the procedure in preparation for the first radwaste shipment on March 16, 1987; however, for that shipment the RWSS failed to physically verify that the letter of registration was on file, and he informed the RWQC that the cask was registered. Both individuals then initiated the check off sheet and the shipment was made.

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The inspector reviewed the Itcensee's investigation and actions related to the failure to comply with 10 CFR 71 requirements. The results of the L

review indicated-the licensee initiated a Deviation Event Report (DER)

which received appropriate management attention and required the-Radwaste Department to determine if the process for identifying problems is sufficient. The DER rates that the cause of the deviation was inattention to detail. Also, actions to prevent recurrence were taken, including strengthening the relevant shipping procedures, performing an audit to ensure the quality of the program, and instituting disciplinary action (written record of an oral warning).

This matter is considered licensee identified and corrected, and meets the criteria described in 10 CFR 2, Appendix C for not issuing a notice of violation. No additional regulatory concerns were noted during review of this matter. This matter was discussed at the exit meeting.

(50-341/87018-02)

i 16. Surveillance; Plant Tours

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During several tours of the plant the inspector observed the following.

(1) No persons were observed violating procedural requirements; this i

includes observation of workers performing activities under the requirements of several different RWPs.

(2) Radiation postings and controls were in accordance with requirements.

(3) Friskers were operable, and calibrated radiation detection equipment was used by HP personnel, a

17. Allegation Followup (Allegation No. RIII-86-A-0130) (Closed): Disposal of radioactive material from the Fermi Station in a Canton, Michigar, landfill.

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In review of the allegation, the inspector previously (Inspection Report No. 50-341/86029) contacted the plant manager, department managers, health physicists, Lan HP technician who was assigned to the Fermi Unit I reactor

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during the period the transfer was alleged to have occurred, and an

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individual who was alleged to have been involved in the transfer, and

i reviewed the disposal of radioactive waste from the Fermi Unit I reactor facility.

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This allegation was held open in Inspection Report No. 50-341/86029 pending attempts to contact an individual who, according to the alleger, could corroborate the allegation. Attempts to contact the individual i

were unsuccessful, as noted below, and the allegation was closed by

internal memorandum dated January 27, 1987.

Allegation:

In 1975 or 1976, Waste Management company removed material (55 gallon drums, boxes, discarded machinery parts, electrical transformers)

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with radioactive markings from an unfenced and unposted area near two big

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stacks at the Fermi site. The material was contained in three dumpsters

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e and was transported by three Waste Management Company trucks between 2:00 a.m. and 5:00 a.m. to the Hannon landfill located in Canton Township, Wayne County, Michigan. All the material in the shipment, the three dumpsters, the drivers' work clothing, and the tarps used to cover the dumpsters were deposited in a specially dug hole, approximately 30 to 40 feet deep. The hole was immediately backfilled.

Since the time of the burial, approximately two hundred feet of rubbish has been placed above the former ground level.

Discussion: The only radioactive material possessed by the licensee in 1975 and 1976 would have been under the Fermi Unit I license.

Licensee records, reviewed by the inspector, indicate that all radioactive waste and material relcased from the Fermi 1 site was disposed of by shipment to Argonne National Laboratory, an authorized recipient. According to licensee personnel, all Fermi 1 radioactive material was stored within the confines of a fenced (restricted) area which was posted to indicate the presence of radioactive materials, and no radioactive material was stored between the Fermi 2 cooling towers, which apparently are the two big stacks referred to by the alleger.

Inspections conducted by an NRC Radiation Specialist inspector in September 1974, November 1975, and April 1976 did not identify any radioactive material storage discrepancies, nor was any storage area meeting the description furnished by the alleger referenced in those inspection reports.

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At the inspector's request, the licensee reviewed purchase and contract records, purchase analysis reports, and cost accounting system records to determine if there had been contracts with Waste Management Company i

to transfer any materials during the period in question.

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contracts were reportedly identified.

The alleger supplied the names of two of the three truck drivers supposedly involved in the alleged disposal of radioactive material. One of these drivers was interviewed by the inspector. The individual stated he had no recollection of ever having been at the Fermi site. He also stated

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that he could not recall ever having picked up or dumped material between 2:00 a.m. and 5:00 a.m. during his employment with Waste Management Company.

He stated that his normal starting time in 1975 and 1976 was 5:30 a.m.,

t and that he could not recall ever having made a pickup before that time.

The second driver named could not be located.

The inspector contacted the alleger on September 2,1986, and informed him of his inspection findings. The inspector also informed the alleger that the inspector had been unsuccessful in locating the second driver allegedly involved in the incident. The inspector requested the alleger's assistance in locating this person. The alleger stated he would attempt to contact this individual and ask him to call the inspector.

During two subsequent discussions with the alleger, he stated he contacted the second driver and requested him to contact Region III; however, no contact was ever made.

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Findings: The allegation could not be substantiated.

18. Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the con:1usion of the inspection on April 10, 1987. 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:

a.

Stated that responsibility for the valve leak control program has been transferred from maintenance to operations, and that upper management intends to increase the effort to reduce leaks.

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Acknowledged the comments concerning the use and intent of the RDR system, and will review ways to strengthen the system such

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that cognizant management is aware of significant events.

c.

Stated that the relevant shipping procedures will be revised to ensure 10 CFR 71 requirements will be adhered to.

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