IR 05000016/1998006

Insp Rept 50-016/98-06 on 980324-26.No Violations Noted. Major Areas Inspected:Licensee Mgt & Control,Decommissioning Support Activities & Radiological Safety

ML20217D359
Person / Time
Site:	Fermi
Issue date:	04/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217D337	List: IR 05000016/1998006 ML20217D332
References
50-016-98-06, 50-16-98-6, NUDOCS 9804240287
Download: ML20217D359 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No.: 50-016 License No.: DPR-9 Report No.: 50-016/98006(DNMS)

Licensee: Detroit Edison Company Facility: Enrico Fermi Unit 1 Location: 6400 North Dixie Highway Newport, MI 48166 Dates: March 24-26,1998 Inspectors: John House, Senior Radiation Specialist Peter Lee, Radiation Specialist Approved by: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9804240287 980421 PDR ADOCK 05000016 G PDR

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EXECUTIVE SUMMARY Enrico Fermi Unit 1 NRC inspection Report 50-016/98006(DNMS)

This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, and radiological safet e Overall, the licensee has maintained the Fermi 1 facility in good condition. The facility 3 has been shut down for over 25 years and is in SAFESTOR. With the reactor defueled I and no fuel on site, radiological safety concerns are limite j Eacility Management and Control e The organizational structure and staffing levels of the facility appeared capable of conducting the decommissioning and industrial safety projects underway, o Planning and safety reviews for the asbestos abatement and sodium removal projects were very good. Outside consultants with expertise in these fields were brought in to manage these evolution e An effective self-assessment program was being implemente * Fire protection planning and support appeared to be well establishe Decommissioning Suncort Activities

• The licensee does not plan to decommission the site until the 2025 time frame. Minimal decommissioning work is underway. Some decommissioning work was done at shutdown in 1972. Current emphasis is on the asbestos and sodium removal project fladiological Safetv e Independent surveys by the NRC inspectors, and smear samples collected and analyzed by the NRC, confirmed dose-rates measured by the licensee and showed there was no removable activit e The Radiation Protection Program was effective in implementing the requirements of the decommissioning plan and the license. The Fermi 1 facility effectively uses portions of the Fermi 2 Radiation Protection Progra *

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Report Details Summarv of Plant Activities The Fermi i facility is in SAFESTOR, the reactor is defueled and no fuel is on site. Few radiological concerns exist for the licensee. The facility has been shut down for over 25 year In preparation for final decommissioning, two major industrial safety projects are underway, asbestos abatement and sodium removal. Licensee management appears to be expending adequate resources on the planning and execution of these project .0 Facility Management and Control General The Fermi i facility is presently in a SAFESTOR condition and final decommissioning will not occur until the 2025 time frame when the Fermi 2 facility is tentatively scheduled I'

for shutdown and decommissioning, Tne reactor is defueled and no fuel remains on site. The only radioactivity associated with the facility is contamination which resulted from the operating phase of the reactor. As the bulk of the contamination is sealed in the reactor vessel, the radiological issues at the Fermi 1 facility are relatively minor. The estimated total curie inventory at present is less than 300 Curies and by 2025 is expected to be less than 100 Curies based on decay, The inspectors reviewed ongoing as well as planned future plant activities and discussed these activities with licensee representatives in order to assess overall facility management and controls. Specific events and findings are detailed in the sections l belo .2 Organization. Management and Cost Controls Insoection Scope (36801)

The inspectors reviewed the licensee's systems for overall management and control of the decommissioning process. The licensee's organization, staffing, and qualifications, including those for the contracted workforce, were also reviewed and evaluated to verify that licensing commitments were being met. Reference was made to the requirements detailed in the Technical Specification Observations and Findings Design change proposals for the Fermi i facility can be proposed by any member in Nuclear Generation or on the Review Committee. All change proposals must have a safety evaluation (10 CFR 50.59 review)if they involve systems discussed in the licensing basis documents. Change proposals are first reviewed by the Custodian and Radiological Engineer, and are then submitted to the Review Committee for approva Following approval, the change proposal can be implemente The licensee has established a set of Excellence Goals for 1998 and has developed strategies for implementing these goals. The goals / strategies focus on employee safety, work planning and scheduling, employee performance in meeting regulatory requirements, cost control, minimizing impact on Fermi 2 and addressing public

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concerns. The two industrial safety projects that are currently underway, asbestos abatement and sodium removal, are part of this pla The organizational structure of Fermi 1 is headed by a Custodian, who is responsible for management of the Fermi i facility and serves as the leader of the clean up projec The Custodian reports to the Nuclear Assessment Manager for the Fermi 2 site. The facility staff is composed of a Field Engineer, a Radiation Protection Engineer, a Consultant for the Sodium Removal Project, a Consultant for the Asbestos Removal Project, a Technician who worked at Fermi 1 when it was operating, a Licensing and information Specialist, clerical support, and trained Radiation Worker Discussions with members of the cleanup team indicsi'd that they were very knowledgeable in their subject areas. Two of the team members had extensive work experience with the Fermi 1 facility when it was operationa c. Conclusions The licensee's organization appeared to be effectively structured for planning and managing those activities that contribute to the overall decommissioning of the facilit The presence of two staff members with Fermi 1 operational knowledge provides important background information (corporate memory). No concerns were note .3 Safety Reviews. Design Changes and Modifications a. Inspection Scope (37801)

The inspectors examined the licensee's safety review program to ascertain that the '

program was effective at identifying potential unreviewed safety questions in accordance with 10 CFR 50.59. The licensee is working on two major industrial safety projects. The first project is asbestos removal from reactor system components, which is underwa The second project is in the planning stages and involves removal of residual sodium and sodium / potassium metal from tanks and piping systems. The inspectors reviewed the sodium project in some detail; this is an unusual and chemically hazardous evolution which also presents a small radiation release risk but is much more significant as a fire or explosion hazard. The asbestos project poses no major safety risk to plant systems and is commonly performed in industr b. Observations and Findings The Fermi 1 reactor was cooled using liquid sodium as the heat transfer medium. Part of the final shutdown process involved draining the sodium and sodium / potassium from the primary and secondary systems, supporting systems and the sodium / potassium systems. The bulk of the sodium and sodium / potassium metal was removed from the site. Not all of the metal could be removed from the reactor vessel, tanks and piping systems because of their design. The licensee is estimating the amount of sodium and sodium / potassium that remains in the various systems and plans to remove it chemically under controlled conditions. From a review of project documents and discussions with I licensee representatives, including the consultant retained to oversee the project, the licensee's safety review was conservative and had addressed the safety hazards expected to be encountered. The major safety issue involves the evolution of hydrogen gas which would be vented to the atmosphere. The possibility of a hydrogen burn does exist, and could compromise system integrity resulting in a small release of radioactive

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material to the atmosphere or lake. As this project is still in the planning stage, progress will be followed in future inspection The major safety aspect of the asbestos removal project involves the medical hazards of asbestos to workers. Radiological contamination is of minor significance. The work is performed by asbestos trained workers under the Fermi 2 Radiation Work Permit system. The NRC does not regulate asbestos remova c. Conclusions The licensee had performed adequate safety reviews and was conservative in the planning of major facility changes. No concerns were note .4 Self-Assessment. Auditing _and Corrective Actions a. Inspection Scope (40801)

The licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were examined, including self-assessments, auditing, and corrective action b. Observations and Findings l

The inspectors reviewed an audit (#97-02) of the Fermi 1 facility which was conducted '

by the Audit Subcommittee in accordance with the Fermi 1 Administrative Controls and Surveillance Procedures Manual, Revision 11, Section 1.5.5.1. The audit covered the physical condition of the facility including the exterior portion of the restricted area and intemal areas of the site buildings. Cover gas pressure for sodium systems was reviewed, as were surveillance data for liquid waste tanks along with surveillance data required by the Technical Specifications. The audit was broad in scope and addressed the major nonradiological aspects of the facility. A separate assessment of the radiological program for Fermi 1 is discussed in Section 3.2. The inspectors discussed the audit findings with the facility Custodian and the corrective actions being taken to address those finding A Condition Assessment Resolution Document (CARD) was reviewed. The CARD system is a Fermi 2 corrective action program which was adopted by Fermi 1 and is a '

mechanism for employees to identify and pose solutions for problems. The CARD document was the result of an evaluation by Fermi 1 and 2 personnel of future radwaste shipments and concluded that Fermi i should have its own procedural guidance for low level radwaste shipments. The action taken was to draft procedures. This program appeared to be capable of addressing problems as they occu c. Conclusions The licensee's self-assessment program for the Fermi 1 facility appeared to be effective. No concerns were note I l

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. Decommissioning Performance and Status Review at Permanently Shut Down Reactors a. IDSpection Scope (71801)

The inspectors toured the facility and evaluated the fire protection syste .

b. Observations and Findings All areas were generally clean and well maintained for a facility that had been shut down for about 25 years. The areas were adequately posted and controlled. No combustible materials were observed. Fire protection is under the Fermi 2 program including fire extinguisher inspections and hydrant testing. At present there is no formal program for Fermi 1. Additional Class D extinguishers have been added to the Steam Generator building, the Na/K building, and at the entrance to the Fuel and Repair Buildin Extemal hydrants which are part of the Fermi 1 general service water system would provide water for fighting fire. Two electrical pumps and a diesel backup pump provide water pressure. The Fermi 2 fire brigade responds to the Fermi 1 facility. Backup fire protection is available from the Frenchtown Fire Departmen c. Conclusions i The licensee's fire protection program appeared well developed and established to meet the existing hazards given the lack of combustible materials in the facilit .0 Decommissioning Support Activities Maintenance and Surveillance (62801)

With the facility in a SAFESTOR condition, maintenance activities are at a minimum and are generally being conducted in connection with the asbestos abatement and sodium removal projects. See Section 1.3. Surveillances are primarily radiologicalin scope and are discussed in Section .2 Cold weather Preparations (71714)

The inspector determined that most of the buildings are unheated; however, there are no water lines in the protected portion of the facilit .0 Radiological Safety 3.1 Radiological Safety Staffing Inspection Scope (83750)

Staffing levels along with the organizational structure (See Section 1.2.b) for the Fermi 1 facility were reviewe b. Observations and Findings The Radiological Safety program is managed by a radiological engineer who has extensive experience and a degree in Health Physics. Radiation protection job coverage is provided by the Fermi 2 Radiation Protection (RP) Staff which provides

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general RP support for the Fermi 1 facility. Organization and staffing met the needs of the facilit .2 Radiological Safety Audits a. Inspection Scope (83750)

The inspectors reviewed the results of the 1997 audit of the Radiation Safety progra b. OhseIyations and Findings The audit scope covered those areas of interest for the limited radiological hazards present in the Fermi 1 facility including radiation postings, survey instrument calibration and radiation work permits (RWP). No concerns were note .3 External and Internal Exposure Control a. Inspection Scope (83750)

The inspectors reviewed the dosimetry program and worker dose history records to determine the extent of radiation exposure to worker b. Observations and Findings All dosimetry is controlled through the Fermi 2 dosimetry program. The dosimetry program includes both thermoluminescent dosimeters (TLDs) and self-reading ,

dosimeters. TLDs are issued quarterly and the program is NVLAP certified. A review of dosimetry records for the past year indicated that workers received approximately 2 millirem, which indicated that the source term for the Fermi 1 facility is small. The low dose also indicated good job planning, work practices and attention to the ALARA program. There was no evidence of intemal exposures due to intakes of radioactive material during the past yea .4 Surveys and Monitoring a. Inspection Scone (83Z50)

The inspectors reviewed selected direct radiation survey and smear results for the past year. The inspectors also performed general area dose rate measurements and prepared three smears in selected locations to determine if any loose contamination was present, b. Observations and Findings Facility surveys had been performed quarterly as required. A review of selected records from the past year indicated that area dose rates were minimal and were on the order of .

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a few millirem per hour or less. Contamination levels were very low, less than 500 I

disintegrations per minute (dpm) per 100 square centimeters of beta / gamma activit The smears taken by the NRC showed no activity, and general area dose rates I l

measured by the inspectors were consistent with the licensee's measurement l 7 l I

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All personnel leaving potentially contaminated areas were required to survey themselves at the exit points using survey instruments brought into the area for this purpose. The inspectors observed individuals using the exit point survey instruments and performed exit surveys on themselves when exiting the restricted area. No problems were note .5 As-Low-As-Reasonably-Achievable ALARA) Inspection Scope (83750)

The inspectors discussed the ALARA program for the Fermi 1 facility with licensee representative Observations and Findings The Fermi 2 ALARA program is used for Fermi 1. Radiation work permits (RWP) are reviewed by the Fermi 2 Radiation Protection ALARA supervisor. Two RWPs are in routine use for Fermi 1, General and Routine Specific. These RWPs cover routine tours surveillances, escorting, inspections and minor equipment repairs. Other, more complex job's performed in the restricted area would be performed on a special RWP which would be reviewed by the Fermi 2 RP ALARA supervisor. These two RWPs were reviewed by the inspectors and appeared to be adequate for their intended us .6 Environmental Monitoring Inspection Scope (84750)

The inspectors reviewed the most recent environmental survey Observations and Findings Radiological environmental monitoring for Fermi 1 was discontinued in 1996 as a result of the implementation of Amendment No.11 which was granted by the NRC. The change states that environmental surveillances are not required until discharge of liquid radiological effluents is commenced. At present, there are no liquid releases from the Fermi 1 facility. If a discharge is planned, environmental monitoring would be initiate Fermi 2 maintains an environmental monitoring program which can detect radiological releases from Fermi 1. A review of environmental data from late 1996 indicated that there had been no detectable releases of radioactive materials to the environment from the Fermi 1 facilit .7 Solid Radioactive Waste Inspection Scope (86750)

The inspectors toured the restricted area to determine if the licensee was storing j l

radioactive waste in accordance with the regulation Observations and Findings No radioactive waste was observed during the facility tour. A licensee representative i stated that very little rad waste had been generated since the last radwaste shipment in !

December 190 l l

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, Iransportation of Radioactive Materials Inspection Scope (86750)

The inspectors reviewed the shipping documentation for a recent radioactive shipment made by Fermi 1 in Deccmbe.- 1997. The inspectors also interviewed the individual responsible for ensLring that the shipments were made in compliance with NRC and DOT requiremer.ts, Observations and Findings The Fermi 1 facility makes radioactive waste shipments under the Fermi 2 radwaste transportation program. Documentation for the December 1997 radwaste shipment was reviewed and discussed with the Fermi 2 Supervisor of Radwaste Shipping. Waste samples had been sent to an off site laboratory for analyses and the waste had been shipped to a vendor for processing and eventual disposal. The vendor had provided the licensee (who was the shipper of record) with a letter stating that there were no discrepancies in the shipment. Shipping documentation was very good and indicated that the shipments had been made in compliance with the applicable NRC and Department of Transportation (DOT) requirements.

l fladiological Safety Conclusions The radiological safety program appeared to be effective in implementing the requirements for the Licensee's SAFESTOR program and the limited decommissioning / industrial safety work being undertaken. Portions of the Fermi 2 program were being effectively used. The inspectors had no concerns about the Fermi i radiological safety progra l l Exit Meeting Summary l The ins ctors presented the inspection results to members of licensee management at the conclusivi of the inspection on March 26,1998, and during a telephone call on April 16,199 The licensee acknowledged the findings presented. The licensee did not identify any of the documents or process reviewed by the inspectors as proprietar .

PARTIAL LIST OF PERSONS CONTACTED

• +L. Goodman, Director, Fermi 1 (Custodian)

• D. Williams, Assistant Radiation Protection Manager

• E. Kokosky, Superintendent, Radiation Protection and Chemistry

• C. Nunn, Office Specialist, Fermi 1

• J. Couillard, Radiological Engineer, Fermi 1

• D. Cates, Asbestos Consultant, Fermi 1

• E. Madsen, Licensing Specialist, Fermi 1

• W. O'Connor, Manager Nuclear Assessment K. Berry, Sodium Consultant, Fermi 1 D. Swindle, Field Engineer, Fermi 1 D. Janssens, Technician, Fermi 1 B. Weber, Supervisor, Radwaste Shipping

• Denotes those attending the exit meeting on March 26,199 + Denotes those present during the telephone call on April 16,199 LIST OF PROCEDURES USED IP 36801: Organization, Management, and Cost Controls at Permanently Shutdown l Reactors I IP 37801: Safety Reviews, Design Changes, and Modifications at Permanently Shutdown l Reactors j IP 62801: Maintenance and Surveillance at Permanently Shutdown Reactors i

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IP 71714: Cold Weather Preparations IP 71801: Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 40801: Self-Assessment, Auditing and Corrective Action at Permanently Shutdown Reactors IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent, and Environmental Monitoring

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IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable CFR Code of Federal Regulations EDG Emergency Diesel Generator IFl Inspection Follow up item IP Inspection Procedure IR Inspection Report LER Licensee Event Report Na/K NaK (Sodium / Potassium)

NRC Nuclear Regulatory Commission RP Radiation Protection URI Unresolved item VIO Violation WO Work Order i

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