IR 05000016/1998007

Insp Rept 50-016/98-07 on 980909-11.No Violations Noted. Major Areas Inspected:Licensee Mgt & Control,Decommissioning Support Activities,Industrial Safety & Radiological Safety

ML20154C727
Person / Time
Site:	Fermi
Issue date:	09/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154C721	List: IR 05000016/1998007 ML20154C718
References
50-016-98-07, 50-16-98-7, NUDOCS 9810070010
Download: ML20154C727 (9)

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, U.S. NUCLEAR REGULATORY COMMISSION REGIONlil Docket No: 50-016 License No: DPR-9

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Report No: 50-016/98007(DNMS)

Licensee: Detroit Edison Company Facility: Enrico Fermi Unit 1 Location: 6400 North Dixie Highway Newport, MI 48166 Octes: September 9-11,1998 Inspectors: Peter Lee, Ph.D., Radiation Specialist Ed Kulzer, ClH, CSP, Radiation Specialist Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9810070010 980930 PDR ADOCK 05000016 Q PM ,

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- EXECUTIVE SUMMARY Enrico Fermi Unit 1

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NRC Inspection Report 50-016/98007(DNMS)

This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, industrial safety, and :adiological safet o Overall, the licensee's gf smance during decommissioning activities was very good.

All activities inspected were conducted in compliance with the Administrative Controls

'and Surveillance Procedures Manual.

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. Facility Manaaement and Control ,

a f e The organizational structure and staffing levels of the facility appeared capable of conducting the ongoing decommissioning and industrial safety project e Planning and safety reviews for the asbestos abatement and sodium removal projects were good. Outside consultants with expertise in these fields were brought in to manage these evolution 0. More than 26,000 bags of asbestos waste have already been remove e 'An effective self-assessmmt program has been implemente Decommissionino Suooort Activities The current emphasis is on the asbestos and sodium removal projects. Confined space entry procedures and training have been initiated to handle some of the decommissioning activities. Training on the hazards of sodium and how to safely work with it has also been initiated. Procedures for working with sodium are being develope Lead monitoring has been perform i Fermi 1 is in compliance with both the lead and asbestos abatement standards being ma!ntaine * Air sampling volumes were not consistently large enough to assure needed accuracy in asbestos monitorin Radioloolcal Safety e Independent measurements by the NRC inspectors confirmed no spread of contamination in the Reactor Building or the Fuel and Repair Buildin * The Radiation Protection Program appesred effective in implementing the requirements of thelicens e Quality assurance oversight of an offsite laboratory had lapsed and needed to be re-establishe , _ _ _ . _ - . --- - -- -

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Report Details Summarv of Plant Activities l In preparation for final decommissioning, two major industrial safety projects are underway, I

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asbestos abatement and sodium removal. Licensee management appears to be expending i adequate resources on the planning and execution of these project l

! Facility Management and Control i General '

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

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belo .2 Oraanization. Manaaement and Cost Controls Insoection ScoDe (36801) l The inspectors reviewed the licensee's systems for overall management and control of the decommissioning process. The lice.nsee's organization, staffing, and qualifications, including those for the contracted workforce, were also reviewed and evaluated to verify that licensing commitments were being me Observations and Findinas l As of the NRC inspection on September 9-11,1998, only four non-lost-time accidents have occurred. These accidents were reviewed by the NRC inspectors and no trends were found that would indicate potential problem area A contractor, Rand Corporation, has been employed to conduct the asbestos abatement. Interviews with members of the Boiler House workers indicated that they were kr.owledgeable in the use and requirements of respiratory protection and asbestos recognition. An interview with the worker experienced in lead abatement indicated that he had sufficient expericace and knowledge in this area, understood the lead standard, and was aware of the lead monitoring results and their significanc 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 No concams were note , 3

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, Safety Reviews. Desian Chanaes and Modifications Insoection Scooe (37801)

The inspectors examined the licensee's safety review program to ascertain whether or not the program was effective at identifying potential unreviewed safety questions in accordance with 10 CFR 50.5 Observations and Findinas I

The inspectors reviewed two safety reviews that had been completed since the last

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inspection. These safety reviews addressed the cutting of secondary pipe containing i residual sodium and the potential radiological hazard from the release of the tritium in a . j secondary sodium storage tan j The inspectors evaluated the tritium monitor and determined that it will be able to detect  :

the concentration specified in Appendix B,10 CFR 20. The inspectors also reviewed the draft procedure for tritium monitoring and discussed the sampling and analytical procedures with the licensee health physics staf I The inspectors reviewed a training video on the hazards of sodium that was developed by the consultant and found that it adequately covered the hazards of working with sodium. This training involved employees who will be working in the sodium removal projec Conclusions The licensee had performed adequate e afety reviews and was conservative in the planning of major facility changes. No concerns were note .4 Self-Assessment. Auditina and Corrective Actions

, Insoection Scooe (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 Findinas The inspectors reviewed an audit (98-01) conducted by the Audit Subcommittee. The audit indicated that the physical conditions at Fermi 1 were acceptable and improving, and that compliance with Technical Specifications, Administrative Procedures and Surveillance Procedures was demonstrated. The inspectors reviewed comments from two individual self-assessm,ent audits of the asbestos abatement project. One was conducted by the Fermi 2 Industrial Hygienist and the second by the Fermi 2 Environmental Engineer. The NRC inspectors also reviewed a self-assessnient audit of the Steam Generator Building and Sodium Building conducted on January 12,199 The NRC inspectors found these audits to be thorough and recommendations in the audit had been followe . - - - - -

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L Conclusions l L The licensee's self-assessment program for the Fermi i facility appeared to be l effective. No concerns were note i Decommissionina Performance and Status Review at Permanentiv Shut Down Reactors Insoection Scope (71801)

The inspectors toured the facility and observed the asbestos containment, asbestos l

abatement and waste storage areas, Observations and Findinos j

- All areas were generally clean and well maintained. Asbestos containment areas were provided as required for large asbestos removal projects. These containment areas are where workers change from their street clothes into the required level of asbestos protective clothing. These areas also are where the contaminated clothing, equipment,

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l and waste are removed prior to leaving the area. The workers are required to use showers, the equipment and waste is cleaned and waste is doubled bagged before l- removal. The areas were adequately posted and controlled. Further, they were ,

l inspected daily by the asbestos contractor (Rand) and by the asbestos consultan ..

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The licensee's facility appeared to be well maintained. No concerns were noted.

L , Decommissioning Support Activities , OSHA Interface Activities Insoection Scooe (33001)

i With the facility in a SAFESTOR condition, the asbestos abatement activities

' were reviewed in accordance with psbestos abatement regulations found in l

. 29 CFR 1926.58. Compliance with the Hazard Communication Standard l

. (29 CFR 1910.1200), Confined Space Entry Standards (29 CFR 1910.269 and 29 CFR 1910.146), and the permissible exposure levels for sodium as found in 29 CFR 1910.1000 were also reviewe i L - Observations and Findinas i

l The asbestos abatement has been performed by an asbestos contractor (Rand l Corporation). A list of asbestos removal workers was requested. The required medical monitoring and required respiratory ilt tests for these workers were reviewed and found

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to be in compliance. Personal air monitoring data (which included both the 30 minute F excursion and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> permissible exposure levels) was reviewed and found to have

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been monitored and M be within reasonable levels and to be in agreement with the

' protection factors of ue respiratory protection worn.

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The NRC inspectors interviewed the Rand representative who was onsite to oversee the asbestos containment areas. The Rand representative was found to be aware of all of l the asbestos requirements. The Rand representative and the Fermi 1 asbestos l consultant monitored the asbestos containment dai!y. Current asbestos removal areas are the following: the Sodium Storage Building, the North West Sodium Gallery, the North East Sodium Gailery, and the Middle East Sodium Gallery. Asbestos abatement has been completed in the Cold Trap Room, NaK Room, Inert Gas Building, Inert Gas :

Tunnel, Sodium Tunnel, West Sodium Gallery, Steam Generator Building, East Sodium l Gallery, and the South Eest Sodium Galler l Asbestos containment areas are required to be maintained under -0.02 inches of water (negative pressure) until they have passed an aggressive clearance testing. Perimeter monitoring is required to determine if the containments are leaking and releasing asbestos fibers. This monitoring is a requirement of the Environmental Protection i Agency Asbestos Hazard Emergency Act. The Act requires that the air outside of an I asbestos containment contains no asbestos fibers greater than background (0.01 fibers per cubic centimeter of air). For the method used to analyze these asbestos l samples (Phase Contrast Microscopy), about 1000 liters of air should be collected to l have 95 percent confidences of detecting 0.01 fibers per cubic centimeter of ai Currently the volumes of air being collected were ranging about from 450 to '

2000 liter The lead removal project involves the OSHA lead standard specified in 29 CFR 1910.1025. Fermi 1 has a consultant who deals with the lead shielding and lead paint at the facility. Baseline blood lead testing and the required lead monitoring had been performed. Persor. '! air samples have found lead levels to be below the action level of 30 micrograms of lead per cubic centimeter of air. At these lead levels no other requirements of the lead standard appl Rand Corporate procedures were reviewed. They included: the Rand Corporate l Safety Program, Lead Procedures, Confined SpaceNessel Entry, and Hazard Communication. These procedures were found in compliance with existing regulation The NRC inspectors also reviewed the training video prepared for the future sodium removal operations. Fermi 1 is presently developing a procedure for working with sodium. This procedure is in the draft stage and no pipes or material containing sodium has been remove c Conclusions One concern was noted involving the adequacy of environmental monitoring. The monitoring of workplace air conducted directly outside of the asbestos (.,ontainment areas was not consistent in collecting volumes of at least 1,000 liters of air in order to accurately determine air concentrations in these areas at levels of 0.01 fibers per cubic centimeter of air or les ,_ _ _ . _ _ _ . ._ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ . . _ . . _ . _ . . . . . . _ _ _ _ _ _ _ _ _ _ _ - _ _ _

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. Radiological Safety .1 General

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The inspectors conducted reviews of ongoing activities in order to assess the overall radiological safety program. Specific findings are detailed in the sections

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- Occuoational Radiation Exoosure (83750)

! l i jnsoection Scooe (83750)

i The' inspectors reviewed the dosimetry records and the quarterly radiological sur sy

resu!ts. .The inspectors also conducted gamma radiation measurements and 1

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contamination check !

, Observations and Findinas L  !

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The 1998 dosimetry records for workers under the Fermi 1 radiation work permit did not indicate any evidence of exposures.

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l The third quarter radiation survey results did not indicate that contamination was spreading in the reactor building or the fuel and repair building. The inspector's gamma radiation measurements were consistent with the licensee's third quarter surveys. Six wipe samples were collected by the inspectors for laboratory analysis. Licensee analysis of the wipe samples showed no detectable activity. Should NRC analyses show otherwise, they will be reported in an Addendum to this repor Conclusions i

Personnel exposures were minimal and contamination was limited and had not sprea !

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' Solid Radioactive Waste Manaaement and Transoortation Insoection Scope (83750)

The insractors reviewed the 10 CFR O Compliance Manual and shipping documents, and interviewed the individuals responsible for ensuring compliance with NRC and  :

Department of Transportation (DOT) regulation Observations and Findinas

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During the period from January 1,1998 to September 11,1998, the licensee made one shipment of contaminated asbestos on September 2,1998. The waste was shipped to a vendor for processing and eventual disposal. The records showed that the shiptr, ant hao been made in full compliance with the NRC and DOT requirement ' Waste characterization smears were collected from the Hot Sump and sent to an off site laboratory for isotopic analyses to determine the scaling factors. The scaling factors

.were to be used to quantify the concentration of hard-to-measure radionuclides in the waste, based on the licensee's analytical results of Cs-137 and Co-60 in the waste . . . _ . . _ _ .... _ _. .

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Review of the 10 CFR G1 Compliance Manualindicatc,d that the methodologies for the determination of the scaling factors were in compliance with 10 CFR 6 At the time of the inspection, the licensee was not providir g a quality assurance oversight of the progress to assure the accuracy of the isotopic analyses conducted by an off site laboratory. The last audit for the off site laboratory was conducted in 199 This lapse in quality assurance coverage was of concem to the inspector Conclusions Reviews of the shipping documents for a radioactive material shipment indicated that the shipment had been made in compliance with NRC and DOT requirements. The licensee agreed to re-establish the quality assurance program to assure the accuracy of the isotopic analyses performed by an offsite laborator .6 Environmental Monitorina (84750)

The liquid waste disposal system is currently used as a liquid waste holdup system. At present, there are no liquid waste releases from the Fermi i fccility. If a discharge is planned, environmental monitoring would be initiate .0 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 11,1998. The licensee acknowledged the findings presented. lhe lie.nsee did not identify any of the documents or processes reviewed by the inspectors as propiistary

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. c-PARTIAL LIST OF PERSONS CONTACTED K. Berry, Sodium Consultant, Fermi 1 D. Cates, Asbestos Consultant, Fermi 1

• J. Couillard, Radiological Engineer, Fermi 1

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

D. Janssens, Technician, Fermi 1

' *E. Kokosky, Superintendent, Radiation Protection and Chemistry

• E. Madsen, Licensing Special:st, Fermi 1 C. Nunn, Office Specialist, Fermi 1

. W. O'Connor, Manager Nuclear Assessment D. Swinie, Field Engineer, Fermi 1 B. Weber, Supervisor, Radwasie Shipping

• D. Williams, Assistant Radiation Protection Manager

• Denotes those attending the exit meeting on September 11,199 LIST OF PROCEDURES USED IP 36801: Organization, Management, and Cost Controls at Permaner% Shutdown Reactors IP 37801: Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 62801: Maintenance and Surveillance at Permanently Shutdown Reactors 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 IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials

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