IR 05000016/1999001

Insp Rept 50-016/99-01 on 990614-17.No Violations Noted. Major Areas Inspected:Mgt & Control,Decommissioning Support Activities,Industry Safety & Radiological Safety

ML20209F009
Person / Time
Site:	Fermi
Issue date:	06/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209F003	List: IR 05000016/1999001 ML20209E999
References
50-016-99-01, 50-16-99-1, NUDOCS 9907150200
Download: ML20209F009 (9)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50-016 License No: DPR-9 Report No: 50-016/99001(DNMS)

Licensee: Detroit Edison Company i

f'acility: Enrico Fermi Unit 1 l

Location: 6400 North Dixie Highway t Newport, MI 48166 Dates: June 14-17,1999

- Inspectors: Peter J. Lee, Ph.D., CHP, Radiation Specialist Ed Kulzer, C!H, CSP, Radiation Specialist l

' Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division af Nuclear Materials Safety

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l 9907150200 990630 PDR ADOCK 05000016 G PDR

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EXECUTIVE SUMMARY i

. . Enrico Fermi Unit 1 NRC inspection Report 50 016/99001(DNMS)

~ This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, industrial safety, and radiological safet * Overall, the licensee's performance during decommissioning activities was very goo All activities inspected were conducted in compliance with the Administrative Controls and Surveillance Procedures Manua Facility Manaaement and Control e The organizational structure and staffing levels of the facility appeared capable of conducting the ongoing decommissioning and industrial safety project '

e Self-assessments for the asbestos abatement and sodium removal projects were goo e A Quality Assurance vendor audit of the offsite laboratory performing 10 CFR 61 isotopic analyses indicated good management involvement in the radioactive waste j progra e The Y2K computer issue had been examined and addresse ,

'1 e Potential onsite personnel exposure to airbome effluent from the sodium removal operation needs to be assessed and controlle Decommissionino Sucoort Activities e One concem was identified related to repetitive events where concentrations of asbestos exceeded the excursion limit established by the Occupational Safety and Health Administratio e Facility and equipment conditions were good and were ready to support sodium <

removal activitie Radioloalcal 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 appeared effective in implementing the requirements of the licens e To evaluate potential offsite dose from the planned sodium removal project, which will release effluents near the ground, the value of X/Q stated in the Offiste Dose Calculation Manual needs to be re-established considering the building wake effec L m. _

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Report Details Summary of Plant Activiting -

At the time of the inspection, asbestos abatement was in progress in the lower level of the reactor vessel containment building. The sodium cleanup project was in its initial stages of implementatio .0 Facility Management and Control General The inspectors reviewed ongoing as well as planned future plant activities and discussed thes' activities with licensee representatives in order to assess overall facility management aind controls. Specific events and findings are detailed in the sections belo . (Closed) Licensee Event Reoort (LER) 50-16/99001(DNMS)

On June 4,1999, the licensee reported that the Protected Area access gate was found unlocked. Upon discovery, the licensee immediately reported the finding to NRC i Region Ill, walked down the Protected Area and verified that there were no unauthorized I personnel within. No damaged or missing equipment was identifie Corrective action, which involved independent verification of access gate locking, was incorporated into the Fermi i procedures on June 15,1999. The inspectors reviewed ,

the corrective actions and discussed them with Fermi i staff during the license's Review Committee meeting. The inspectors concluded that the corrective actions were adequate. This LER is close .3 Oraanization. Manacement and Cost Controls Jnsoection 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 me Observations and Findinos As of the NRC Inspection on June 14,1999, no lost-time accidents had occurre Several non-lost time accidents were noted and no trends were found that would indicate potential problem areas, interviews with two sodium workers indicated that they were knowledgeable in the use and requirements of working with sodium and had been monitored while cutting pipe containing sodium. One of these workers was experienced in lead abatement and indicated that he had sufficient experience and knowledge in this area, understood the lead standard, and was aware of the lead monitoring results and their significanc .3 o .. .. . . . .

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c. Conclusions l

The licensee's organization appeared to be effectively structumd for planning and !

managing those activities that contribute to the overall decommissioning of the facilit !

No concems were note .4 Safety Reviews. Desian Chanaes and Modifications a. Inspection Scope (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 b. Observations and Findinas The inspectors examined the draft safety reviews which addressed sodium removal by I injecting steam into the pipes and secondary storage tanks containing residual sodiu !

The inspectors toured the facility where the sodium removal project will take place and evaluated the effluent release. The inspectors identified a potential weakness in the licensee's dose assessment of airbome effluen During the sodium removal process, there will be airbome effluent of tritium, hydrogen, and sodium hydroxide from the plant. The exhaust will be released through a vent in close proximity to other buildings. This will modify the flow pattern close to the source of release by introducing a downwash or a wake on the lee side of the building. The highest concentrations will be inside the wake recirculation zone, close to the release building at ground leve !

The licensee used dispersion formulas, which assume unobstructed dispersion in air, to .

assess offsite ground level concentration and calculate dose to the general publi l Because of the building wake effect these formulas will not provide accurate results. In addition, the potential onsite exposure should be taken into consideration, especially, for non-radiation workers, who require no monitorin c. Conclusions A potenttal weakness relating to not accounting for building wake effects, was noted in i the licensee's dose assessment of airbome effluent. The licensee agreed to assess the onsite and offsite potential exposures considering building wake effects and to control access around the release building during the operation to assure personnel exposures won't exceed the limits as specified' for the general publi .5 Self-Assessment. Auditina and Corrective Actions a. trisoed. tion Scone (40801)

The licensee's programs for identifying, resolving and preventing issues that degrade safety or quality were exarnined including self-assessments, auditing, and corrective actions.

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.. Observations and Findinas The inspectors reviewed Audits 98-02 and 99-01 conducted by the Audit Subcommitte The audit reports 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 NRC inspectors also reviewed a self-assessment audit and a third party audit of an offsite vendor performing 10 CFR 61 isotopic analyses. _ The inspectors also reviewed three self-assessments of asbestos abatement and one self-assessment of the sodium cleanup project. The NRC Inspectors found these audits to be thorough and recommendations in the audit had been followe Conclusions The licensee's self-assessment and audit program for the Fermi 1 facility appeared to be effective. No concems were note .5 . Decommissionina Performance and Status Review at Permanentiv Shut Down Reactors Inspection Scope (71801)

The inspectors toured the facility and observed the activities where asbestos removal and abatement were taking place and where the waste was stored. The inspectors also examined the equipment and discussed the system being developed for sodium removal from the pipes and tanks containing sodiu Observations and Findinas All areas were generally clean and well maintained. The inspectors toured the areas where the cutting of pipes containing residual sodium was done and checked the drums, which are under a nitrogen atmosphere, where these pipes are being stored. The inspectors toured the facility where the sodium removal project will take place and discussed the system operation with the licensee. The system operation appeared to be adequate. The exhaust from this system may pose some problems, as described in Section 1.4, above, Conclusions Facility and equipment conditions were good and were ready to support sodium removal activities. Some work may need to be done to characterize to potential concentrations

- of sodium removal project contaminants being generated at the exhaust or outfal .6 y2 Insoection Scope The inspectors interviewed the licensee staff to determine if the Y2K computer issue had been examined and addresse ,

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[ Observations and Findinas Most of the operations of the decommissioning activities are not computer based. On!y the personnel contamination and waste radiation level monitoring system are i computers-based operations. These will not be affected by computer failures due to 1 Y2K. In the sodium cleanup project, the hydrogen and oxygen sensors and the data recording PC are the only instruments which include programming which is date sensitive. Both the instruments and the PC have been tested and certified by the contractor for Y2K complianc l Conclusions ]

The Y2K computer issue had been examined and addressed. No concerns were note .0 Decommissioning Support Activities Occupational Safety and Health Administration interface Activities Insoection Scooe (93001)

With the facility in a Safe Storage condition, the asbestos abatement activities (29 CFR 1926.58 and 29 CFR 1910.1001), lead abatement activities (29 CF 1910.1025 and 29 CFR 1910.261), and the permissible exposure levels for sodium as found in 29 CFR 1910.1000 were also reviewe b. ~ Observations and Findinas The training records for asbestos and sodium were reviewed. The required medical monitoring and required respiratory fit tests for fourteen asbestos workers were found to be in compliance. Personal air monitoring data for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> permissible exposure levels for sodium and lead were reviewed and found to have been monitored and to be within the Occupational Safety and Health Administration (OSHA) limit Perimeter monitoring was identified as a previous concem. These records were reviewed. Perimeter monitoring is required to determine if the containments are leaking and releasing asbestos fibers to the outside atmosphere. This monitoring is a requirement of the Environmental Protection Agency Asbestos Hazard Emergency Ac The Act requires that the air outside of an 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 samples (Phase Contrast Microscopy), about 1000 liters of air should be collected to have 95 percent confidence of detecting 0.01 fibers per cubic centimeter of air. This previous concem has been correcte The records showed that the excursion asbestos exposure limit established by OSHA of 1 fiber per cubic centimeter of air (f/cc) averaged over a 30 minute period, had been ]

exceeded (up to 4-6 f/cc) by several individuals. Each individual exceeded the excursion limits only once. Reportedly, their supervisor hsd spoken to them. These individuals were also reported to have been wearing powered air purifying respirators at the tim (Respiratory protection is not considered by OSHA in determining exposures).

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The lead removal project involves the OSHA lead standard as specified in 29 CFR 1910.1025. Baseline blood lead testing and the required lead monitoring had been performed and exposure records reviewed. Personal air samples have found lead levels to be below the action level of 30 micrograms of lead per cubic centimeter of air. At these low lead levels no other requirements of the lead standard apply, Conclusions One concem was noted involving several asbestos workers exceeding the 30 minute excursion limit established by OSHA. The licensee needs to consider preventive actions to reduce these events such as use of additional wetting agents or by controlling work more carefull I Radiological Safety General The inspectors conducted reviews of ongoing activities in order to assess the overall radiological safety program. Specific findings are detailed in the sections belo .2 Qccuoational Radiation Exoosure (83750) Insoection Scooe (83750)

i The inspectors reviewed the dosimetry records and the quarterly radiological survey results, and the tritium monitoring results. The inspectors also conducted contamination check Observations and Findinas ,

I The 1999 dosimetry records for workers under the Fermi 1 radiation work permit did not I indicate any evidence of exposure '

The forth quarter of 1998 and first quarter of 1999 radiation survey results did not indicate that contamination was spreading in the reactor building or the fuel and repair building. Ten wipe samples were collected by the inspectors for laboratory analysi 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 The inspectors reviewed the tritium sampling and analytical procedures and determined i that the minimum detectable concentration is well below the concentration specified in Appendix B,10 CFR 20. The sampling results during the cutting of secondary pipe containing residual sodium didn't indicate any significant exposur Conclusions

' Personnel exposures were minimal and contamination was limited and had not sprea . Solid Radioactive Waste Manaaement and Transoortation Inspection Scooe (83750)

The inspectors reviewed the 10 CFR 61 Compliance Manual and shipping documents, .

and interviewed the individuals responsible for ensuring compliance with NRC and I Department of Transportation (DOT) regulation Observations and Findinas Since the last inspection, the licensee made nine shipments of contaminated asbesto The waste was shipped to a vendor for processing and eventual disposal. The records showed that the shipment had been made in full compliance with the NRC and DOT requirement Since the last inspection, the licensee has re-established the quality assurance program to assure the accuracy of the 10 CFR 61 isotopic analyses performed by an offsite laboratory. The inspectors reviewed the self-assessment and the third party audit for the offsite laboratory. The audits had adequate range and depth and the corrective actions ;

appeared to adequately address the concern ; Conclusions Reviews of the shipping documents for a radioactive material shipment indicated that the ;

shipment had been made in compliance with NRC and DOT requirement .4 Environmental Monitorina (84750)

During the sodium removal process, airbome effluents containing tritium, hydrogen, and sodium hydroxide will be released from the plant. To evaluate the offsite dose, the value of x/Q stated in the Offiste Dose Calculation Manual needs to be re-established based on the building wake effect; see Section 1.4 for detail .0 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the

- conclusion of the inspection on June 17,1999. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietar .

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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 Specialist, Fermi 1 C. Nunn, Office Specialist, Fermi 1 W. O'Connor, Manager Nuclear Assessment D. Swindle, Field Engineer, Fermi 1-B. Weber, Supervisor, Radwaste Shipping

• D. Williams, Assistant Radiation Protection Manager

• Denotes those attending the exit meeting on June 17,199 LIST OF PROCEDURES USED IP 36801: Organization, Management, and Cost Controls at Permanently 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 l

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