IR 05000016/1989001

Insp Repts 50-016/89-01 & 50-341/89-14 on 890522-26.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Program at Unit 2 During Operation, Including Training & Qualifications

ML20245L051
Person / Time
Site:	Fermi
Issue date:	06/27/1989
From:	Grant W, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245L038	List: IR 05000016/1989001 ML20245L034
References
50-016-89-01, 50-16-89-1, 50-341-89-14, GL-82-12, IEIN-88-022, IEIN-88-22, NUDOCS 8907050356
Download: ML20245L051 (9)

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a - U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-341/89014(DRSS); 50-16/89001(DRSS) Docket Nos. 50-341; 50-16 Licences No. NPF- 13; DRP-9 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Enrico Fermi Nuclear Power Station, Units 1 and 2

 ;InspectionAt: Fermi Site, Monroe, Michigan Inspection Conducted: May 22-26, 1989 E
 . Inspectors: R. A. Paul   S/ )I//fY l Date fr)Y W. B. Grant   0"l Date b), f. N &

Approved By: M. C. Schumacher, Chief />b/ 7/7 Radiological Controls Date and Chemistry Section Inspection Summary Inspection on May 22-26, 1989-(Reports No. 50-341/89014(DRSS); 50-16/89001(DRSS)) Areas Inspected: Routine, unannounced inspection of the radiation protection program at Fermi Unit 2 during power operation including: audits and appraisals; changes in the organization, training and qualifications; external

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exposure control; control of radioactive materials and contamination, and maintenance of occupational exposures ALARA (IP 83750,83724,83726); licensee action of previous inspection findings (IP 92701). The inspectors also reviewed licensee radiological and environmental surveillance of Fermi Unit Results: No violations or deviations were identified. The licensee's radiological control program appears effective in controlling and reducing personnel exposures and controlling contaminatio ^ a

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DETAILS Persons Contacted

*R. Anderson, Radiation Protection Manager
*P. Anthony, Licensing Engineer R. Baum, Radiation Protection Engineer
*S. Bartman, Principle Engineer, Rad Effluents
*S. Bump, Principle Engineer, Rad Health
*R. Eberhardt, Superintendent, Radiation Protection-
*P. Fessler, Director, Plant Safety D. Gipson, Plant Manager
* Higgins, General Supervisor, Radiation Protection
*E. Kokosky, Radiation Protection Supervisor
*R. McKeon, Superintendent, Operations W. Ruttenberg, Radiation Protection Technician
*G. Trahey, Director Special Projects
*W. Tucker, Assistant to the Vice President, Nuclear Operations
*P. Pelke, NRC Project Inspector
*S. Stasek, NRC Resident Inspector
*Denctes those present at the exit meeting. The inspectors also contacted several other members of the licensee's staf . General This inspection, which began on May 22, 1989, was conducted to review the radiation protection program during power operation, including: licensee action on previous inspection items, control of radioactive materials and contamination, surveys, and monitoring, external exposure control, and ALARA considerations. Several tours of the reactor and radwaste buildings were mad . L_icensee Action on Previously Inspection Findings (IP 92701)
(Closed) Open Item (341/86015-02): Installation and testing of radiation monitors in the station air system before it is used for breathing ai The station air system will not be used for breathing air and therefore the proposed breathing air radiation monitor system will not be installe (Closed) Open Item (341/87037-01): Develop a program which meets the objectives of TI 2500/23 Radiological Controls for Drywell Access During Spent Fuel movemen The licensee has developed what appears to be an effective program for radiological control in the drywell during fuel movement (see Section 11).

i (Closed) Open Item (341/88009-02): Reevaluate the automated laundry monitor's alarm setpoint, and protective clothing (PC) monitoring methods to ensure that a hot particle on the inside of PCs would alarm the monitor. The licensee has revised the PC monitoring method, recalibrates the laundry monitor and lowered the alarm setpoint (see Section 8).

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 -(Closed) Open Item (341/88009-03): Revise personnel decontamination procedure to address hot particle issues. including dose assessment, laundry monitoring, and a training program for personnel. . The license appears to now have a viable hot particle program (see Section 12).

(Closed) Open Item (341/88020-02): Corrective action concerning 1 ~

 . weaknesses identified during the reactor' building contamination-event on May 28,'1988. Identified weaknesses were addressed and corrective actions taken. A.similar event in July 1988 wasLhandled exceptionally well (see l*. Section 9).

' Organization,- Management Controls, and Staffing (IP 83750) , . The' inspectors. reviewed the licensee's organization and management t

 . controls .for radiation protection, including changes -in the organizational structure and staffing, effectiveness of procedures ~and other management techniques used to implement the program, and experience concerning    !

self-identification and correction of program implementation weaknesse Since the previous inspection'(Inspection Report No. 341/88020), a Radiation Protection Manager (RPM) position was created and filled. The y RPM reports directly to the Superintendent, Radiation Protection and has direct access to the Plant Manager. ~ Reporting.to the RPM are four engineer / supervisors, each has been assigned responsibility for.the following specified functional areas; Rad Engineering, Rad Effluents, Rad Protection.and Rad Health. Reporting to the General. Supervisor for Rad-Protection are 12' supervisors, 40 technicians and 22 contract decontamination / laundry radwaste workers. The Rad Protection staff remains stable, appears qualified, and overall commercial plant experience has. increase The inspectors discussed the intent of Generic Letter (GL) 82-12 requirements for-limiting radiation protection staff hours of work to l assure that, to the extent practicable, personnel are not assigned to l shift duties while in a fatigued' condition that could reduce their mental alertness or decision making capability. Technical Specification i

 (TS) 6.2.2(f) requires adherence to GL 82-12. To meet TS 6.2.2(f), the l  licensee has implemented an administrative procedure to limit working hours of plant staff (including the radiation protection staff) who perform safety-related functions. The procedure's working hour limitations are consistent with GL 82-12 guidelines. The licensee stated that heavy use of overtime is not routine and that technical specification working hour limits are either complied with or plant manager permission    ;

is requested to exceed the l External Exposure Control and Personal Dosimetry (IP 83750, 83724) 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 technique used to implement

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these programs; and experience concerning self-identification and correction of program implementation weaknesse The licensee reads TLDs with an installed in-house Panasonic TLD system and is NAVLAP certified in all eight categories. There is a contractor TLD QA comparison program in plac The inspectors reviewed procedures for calibration of TLD readers. processing TLDs, TLD element correction factor determination, TLD dosimetry QC, and standardization of the TLD irradiator; no problems were note Exposure records of plant personnel were selectively reviewed for 1989 to dat No exposures greater than 10 CFR 20.101 limits were note Posting and labeling in the RCA were observed during plant tours; no problems were note Housekeeping appeared to be goo No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (IP 83750) The inspectors reviewed the licensee's program for maintaining occupational exposure ALARA including c.hanges in ALARA policy and I procedures; ALARA considerations for the maintenance and refueling outage, ' worker awareness and involvement in the ALARA program, and establishment of goals and objectives and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesse The 1988 total cumulative dose was about 100 person-re The 1989 total to date is about 24 person rem with a goal of 300 person-rem for the year l including the plant's first refueling outage scheduled for September.

About 100-150 jobs have been scheduled for the September 1989 refueling / maintenance outage; however, the full scope of outage work has not been determined. The ALARA group is reviewing engineering design work packages, modification work packages, and maintenance work packages that involve substantial person-rem exposure. The licensee has a substantial job history file of similar tasks which have been performed at Fermi and some similar tasks that have been performed at other facilities. As part l of outage planning and scheduling, the ALARA group, in concert with the ' planning and scheduling and maintenance groups, is identifying potentially high exposure jobs, determining shielding and decontamination requirements, establishing an interface between work groups, and developing outage and task person-rem projection The licensee has what appears to be a viable cobalt reduction program in place. Management support for the ALARA and employee ALARA proposal (suggestion) programs has been extensive. The effectiveness of that support and of the ALARA program will be determined during the upcoming outag A formal ALARA committee was formed in March 198 The committee includes representatives from plant departments, the RPM, and the plant manage __ ______ - __ - ________ __ _ -

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The committee's charter is to recommend ALARA goals for each department and monitor progress toward the goa Through March 1989 radiation protection personnel received abwt 40% of the station dose; considerably higher than expected. The licensee l determined that much of the exposure was due to RWP reverification surveys which are required if' radiological conditions may change from the time the initial surveys are performed until the RWP is used. During this period, ,. RWPs were frequently not used on the day / time scheduled. Considerable l reverification surveys were performed during temporary repair of steam L " leaks in the Turbine Building. To alleviate unnecessary exposures, the plant manager directed health physics not to perform resurveys until there is good reason to believe the RWP work will begi No violations or deviations were identifie . Control of Radioactive Material and Contamination (IP 83750; 83726) The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of _ methods of control of radioactive and contaminated material During previous 4,:,pections (341/86016; 341/86029 and 341/87018), the inspector expre.esed concern about the extensive use of tygon tubing to control valve laak off for contamination control, especially for leaks in the turbine bui Ming condenser bay area. During that period, the licensee had a significant valve leuk-off problem and was aware of the potential problems associated with using tygon tubing for contamination contro The licensee developed and implemented a major leak reduction program which significantly reduced the use of tygon tubing, and appears adequate to control leaks, mainly in areas outside the condenser ba During this inspection, it was noted the licensee is having recurring problems with valve leakage in the condenser bay. Several entries were made into the area during power operations to make temporary repairs. The leak problem has required increased radiological controls and personal radiation exposures. The Plant Manager considers this a significant problem, and plans to make permanent repairs as necessary during the j forthcoming refueling outage. This matter was discussed with the Plant

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Manager at a pre-exit meeting and will be reviewed at a future inspection (0 pen Item 341/89014-01). Facilities / Equipment and Equipment Calibrations (IP 83727) The inspectors toured radiation protection facilities, observed equipment in use, and discussed recent improvements and future plans for facilitie The licensee's automated l'undry monitoring equipment calibration, use, and alarm setpoints procedures are discussed in Inspection Report No. 341/88009. In that report it was noted the monitor was set to alarm at an unattenuated activity of about 90 nanocuries, which means that a

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I g -laundered coverall containing a hot particle on its inside surfaces L ' equivalent to, or above the monitors alarm setpoint could'go undetected.

L Since then, the licensee has adjusted the monitor setpoint.to alarm at an

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unattenuated activity of 26 nCi, which is equivalent to about a 390 nCi cobalt-60 hot particle if located of the inside of the coveralls. A 390"nCi cobalt-60 hot particle if located on the skin has a dose rate of about 1.7 rems per hour. In addition, the licensee now monitors at least one set of the laundered batch on the inside. Currently, the iicensee does.not have a hot particle problem. :If a problem develops, PCs will be monitored on the inside at a greater frequenc The inspectors reviewed records and relevant calibration procedures for

 . the Eberline Model PCM-1A whole body friskers (WBF). Calibrations of the WBFs are performed semiannually using nominal 90 nCi technetium-99    i (100 cm2 area) standards. Detector. efficiencies are about 5%; the efficiency for the foot portion of the WBF is about 9L Frisker alarms are' nominally set at 4 nCi; a 5 nCi technetium check' source is used dNily to ensure the detectors of the WBF alarm at the established setpoint, The inspectors reviewed calibration' records for selected. monitors; no' problems were note . Deviation Event Reports (DERs) (IP 83750)

The inspectors selectively reviewed DERs written and completed since the last inspectio ~ DER No. 88-1348: .0n'May 28, 1988, a steam / water leak in the Reactor Water Cleanup System (RWCU) contaminated the first four floors of the reactor buildin During the inspector's initial review of this event, several weaknesses were identif_ied (0 pen Item 341/88020-02). The weaknesses concerned the failure to use respiratory protection during reactor building entries into wet, but very high, contamination areas,. failure to i -use the recorded information on the constant air monitor (CAM) strip l charts; failure to use the CAM filter samples to evaluate airborne concentrations, and failure to communicate properly with other groups causing a three day delay in the complete evaluation of the reactor building stack (SPING) sample. The licensee's corrective actions included

. compiling a complete list of lessons learned from this event, developing a L training lesson plan that addressed all the lessons learned, and providing training to the entire radiation protection staf The inspector reviewed I the training lesson plan; it appeared to adequately address the identified weakness h In addition, Procedure NPP-63.000.100, RWP Preparation and  ;

Issue, was revised to establish a contamination limit of 100,000 dpm/100 cm2 before respiratory protection is require The licensee's investigation was timely and thorough, and corrective i actions good. This open item is considered closed (341/88020-02). J DER No. 88-1877: On October 23, 1988, an unplanned exposure to radiation occurred when two workers were allowed to work on the reactor building equipment drain sump after it was drained (which removed the water shielding), without updating the survey. The expected 20 mrem exposure was actually 230 mrem; a contract radiation protection (RP) technician failed to resurvey the sumps after it was drained. The licensee's

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investigation identified two root causes: (1) the RP technician assigned-to-the job did not provide adequate. coverage, allowing the workers to enter the work area without a survey of existing conditions,-(2) there wa an-inadequate turnover between shifts resulting in the oncoming shift not

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O being aware that the work area had not been surveyed:in its current configuration-(completelydrained).'Thelicensee'scorrectiveaction included conduct.of a meeting between HP. management, HP lead technician,

  -and the Plant. Manager to discuss the. event and. expected performance._ As a result, the' contract technician was' terminated; the event was discussed in the HP continuing' training sessions, including root causes and how the event could have.been prevented; and HP procedures were revised to-include further guidance on acceptable job coverage and shift turnover methodolog The licensee's investigation was timely and thorough and corrective actions good. This.m~atter, which was discussed at the exit meeting, is considered licensee identified and correcte No violations or deviations were identifie . 1 Fermi Unit 1 The status of'the Unit 1 reactor facility is essentially unchange The inspectors reviewed the Unit 1 procedures and annual report for 1988, interviewed. licensee personnel, reviewed radiological survey and radiological environmental monitoring records, and made a tour of the facility to assure radiological controls are maintaine The results.of.this review indicate that required administrative and surveillance' procedures are maintained and adhered to, and analytical results for. water and sediment were near the lower limits of detectio The facility entrances and areas are posted and controlled in accordance with regulatory requirements for existing radiological condition No violations or deviations were identifie . Radiological Controls for Drywell Access During Spent Fuel Movement (TI 2500/23)

To date, the licensee has not performed a fuel movement with irradiated fuel; the first spent fuel transfers are scheduled for September 198 According to the licensee, drywell access during spent fuel movement will be limited to areas at or below the 586 foot drywell elevation which is below the bottom of the reactor vessel. No access will be allowed above the 586 foot elevation until an evaluation of radiation levels is made during movement of a fuel bundle. The licensee intends to position area radiation monitors, ALNOR electronic dosimeters, and possibly TLDs, around the drywell during movement of the first fuel bundle. According to the licensee, the bundle would be lifted out of the core and rotated 360 around the edge of the reactor vessel, then through the shielded fuel chute into the spent fuel pool (SFP). After the first bundle is in the SFP, the dosimetry will be retrieved and an evaluation of dose and possible limitations of fuel movement will be made. Drywell workers will i

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be briefed concerning potential! hazards,. work restrictions and the evacuation plan required by the.RWP procedur ; No violations or deviations were identifie j 1 Hot Particle Program (IP 83750, 83726) ' The licensee has an action plan and procedure which include ' , identification of jobs with potential hot particles,' appropriate RWP i precautions, responsive. action if hot particles'are identified, methods for determining if the particlcs are. fuel fragments or activation d products,:and training for health physics and general plant staff. The -l licensee has revised the personnel decontamination procedure to address- j hot particles including dose assessment (VARSKIN). A commercial laundry o monitor has been purchased, installed, and calibrated to aid in.' hot l particle detection on laundered protective clothin No problems were { note No. violations or deviations were identified.

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 .1 NRC Information Notice Followup (IP 92701)

Notice No. 88-22: Disposal of Sludge.from 0nsite Sewage Treatment Facilities at Nuclear Power Station The licensee's sewage treatment is done by the' City of Monroe, Michiga There are no sewage treatment facilities onsite. Sewage is sampled onsite-annually; no contamination has been foun .. No violations or deviations were identifie . 1 Surveillance - Plant Tours During several tours of the plant, the inspectors observed that'(1) n persons were observed-violating procedural requirements, (2) radiation postings and controls were in accordance with requirements, (3) friskers were operable, and calibrated radiation detection equipment was used by HP personne The inspectors performed smear surveys of floor and horizontal surfaces on the second and third floors of the reactor building in the areas.where previous high contamination was caused by the 1988 RWCU leak; one smear out of about 70 collected showed removable. contamination greater than 1000 dpm/100cm2 Several hot spot postings were noted on an overhead equipment drain line located on the first floor of the reactor building; the radiation readings ranged from about 4 mr/hr at floor level to 1800 mr/hr at the surface of the line. The line carries RWCU pump room water, EECW, and chemical sample leakoff. The line had effectively been hydrolazed; however, the contamination levels have again risen. The licensee intends to re-hydrolaze the line before the 1989 outage, and is evaluating methods to permanently reduce radiation levels. This matter was discussed at the exit and will be reviewed during a future inspection (0 pen Item 341/89014-02).

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1 Exit Meeting The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection and summarized the scope and findings of the inspection activitie The inspectors also' discussed the likely informational contents 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 or processes as proprietar The following matters were discussed specifically by the inspector The significance of the DER concerning an unplanned radiation exposure (Section 9). The continued problem with valve steam leaks which result in increased radiological controls and personal exposure (Section 7). The elevated radiation fields in the basement of the reactor building caused by contamination in a equipment drain lines (Section 14).

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