IR 05000341/1993026

Insp Rept 50-341/93-26 on 931206-10.No Violations or Deviations Noted.Major Areas Inspected:Mgt Organization, ALARA Program,External & Internal Exposure Control & Control of Radioactive Contamination

ML20058P937
Person / Time
Site:	Fermi
Issue date:	12/17/1993
From:	Mccormickbarge, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058P934	List: IR 05000341/1993026 ML20058P931
References
50-341-93-26, NUDOCS 9312280019
Download: ML20058P937 (10)

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L*,. -7 U.S. NUCLEAR REGULATORY COMMISSION I REGION III

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l Report No. 50-341/93026(DRSS) ,

Docket No. 50-341 License No. NPF-43 ,

Licensee: Detroit Edison Company i 6400 North Dixie Highway  !

Newport, MI 48166 a Facility Name: Fermi Nuclear Power Plant, Unit 2 l I

Inspection At: Fermi Site, Newport, Michigan Inspection Conducted: December 6-10, 1993  !

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Inspector: pu/[/d a/n/93 N. Shah Date-Approved By: 9. /2). 8)Iovnwl Ao /ah? /43 Date '

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64. W. McCormick-Barger, Chief Radiological Programs Section 1  ;

Inspection Summary Inspection on December 6-10. 1993 (Report No. 50-341/93026(DRSS))

Areas Inspected: Routine radiation protection inspection (inspection procedure (IP) 83750) including marogement organization, ALARA program, external and internal exposure control, and control of radioactive contamination. Also reviewed were the implementation of the revised 10 CFR Part 20 and the status of h leaking fuel element (IP 84750). ,

Results: No violations or deviations were identified. A recent management :

reorganization resulted in the nhming of the radiation protection manager -l (RPM) as superintendent of the radiation protection, chemistry, radwaste, and j industrial safety groups (section 3). The licensee effectively implemented i the new Part 20 on October 1, 1993 (section 5). Radiological performance (section 6) was excellent, owing to several ALARA and source term reduction ,

initiatives, and housekeeping (section 10) was good. Previously identified l deficiencies in radwaste processing (section 10) appear to be corrected, and -)

will be further reviewed in subsequent inspection ;

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9312280019 931217 PDR ADDCK 050003411 G PDR ' '

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DETAILS

, Per. sons Contacted D. R. Gipson, Senior Vice President-R. McKeon, Plant Manager W. E. Miller, Director, Nuclear Licensing J. Pendergast, Compliance Engineer J. Sweeney, Quality Assurance Specialist J. Walker, Director Plant Engineering D. Pettinari, General Supervisor, Radwaste R. R. Eberhardt, Superintendent, Radiation Protection E. F. Kokosky, General Supervisor, RP Operations L. Goodman, Director, Nuclear Quality Assurance J. P. Nolloth, Superintendent Maintenance R. Delong, Radiation Protection Manager S. Bartman, General Supervisor, Chemistry R. Baum, Supervisor, Radiological Engineering R. Gilmore, Dosimetry Supervisor L. Crane, Radiation Health Supervisor

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K. Riemer, NRC Resident Inspector The above personnel were present at the exit meeting on December 10, 199 The inspector also interviewed other licensee and contractor personne . Licensee Action on Previous Inspection Findinas (Closed) Insoection Followuo Item (IFI) 50-341/92008-01: The licensee was to analyze -a spiked liquid sample for tritium (H-3), Iron-55 (Fe-55), and Strontium-90 (Sr-90) activities and to report the activities to Region III for compariso The results of the analyses are presented in Table I with the criteria .

for agreement in Attachment I. The licensee's Fe-55 and H-3 results were in good agreement with the NRC results. However, the' licensee's Sr-90 activity value was a nonconservative disagreement. The licensee ,

reviewed the analysis provided by its contract laboratory and had the ,

laboratory analyze duplicate samples. The licensee reanalyzed the liquid for Sr-90, the results of which was in agreement with the NRC -

value. The licensee also reviewed interlaboratory results for Sr-89 and Sr-90 in liquid samples; no biases were observed in the contract laboratory's results. The inspector and licensee discussed the results and attributed the initial Sr-90 activity to an isolated personnel error, probably in the preparation of the strontium carrie (0 pen) IFI 50-341/92020-01: Inspector review of licensee critique of 1992 refueling outage (RF0).

The inspector noted that the review addressed root causes.an recommended good corrective actions. For example, the licensee created

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a the position of drywell coordinator (outage planning) to address RF0 housekeepir, and planning concerns. The inspector will review the effectiveness of these actions during the 1994 refueling outag (Closed) IFI 50-341/92020-02: Licensee to hydrolaze steam dryer /

separator pit drain line to reduce dose rate The licensee flushed the line on December 1,1992, and again on June 27, 1993. Contact dose rates were reduced from 8 rem /hr (80 milliSieverts ,

(mSv)/hr) to 0.2 - 26 millirem (mrem)/hr (0.002 to 0.26 mSv/hr) and, as *

a result, an associated radiation area was deposted. At the exit i meeting (section 11), the inspector commented on the licensee's good '

results from this initiativ l

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(Closed) IFI 50-341/92020-03: Inspector review of 10 CFR 50.59 report concerning radioactive material :,torage in an onsite warehous '

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Although the 10 CFR 50.59 report was completed, the licensee reported !

that it will not use the warehouse for storage. This item is closed, however, the inspector will review other licensee storage options during i'

future inspection No violations or deviations were identifie . Manaaement Oraanization (IP 83750) i

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The inspector reviewed the management organization of the radiation i protection progra The radiation protection manager (RPM) was promoted to superintendent of the radiation protection (RP), chemistry, radioactive waste (radwaste),

and industrial safety programs. The previous superintendent was 1 promoted to assistant to the plant manager and had only. overseen the RP, chemistry and radwaste groups (inspection report 50-341/93008(DRSS)).

Because the current superintendent remains the RPM, the inspector was concerned that the workload would adversely affect radiological performance. Station management had similar concerns, and will take I corrective actions if management problems arise. The inspector will review the effectiveness of the reorganization during routin inspection r

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No violations or deviations were identifie ,

4. Audits and Aooraisals (IPs 83750 and 84750) -

The inspector reviewed recent audits and surveillances conducted by the licensee since the last inspectio Recent audits of the radiological effluent and radwaste programs were found to be performance based with appropriate corrective actions taken for identified findings. Because these were recent audits, the inspector will review the licensee's response to audit findings in a subsequent inspection. The inspector also discussed an ongoing RP audit ,

with the auditors. Several minor administrative deficiencies and a ,

technical issue concerning calibration of radiation monitors were ,

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identified. The technical issue concerned a new technetium (Tc)-99 beta calibration source which had a different backing material-(nickel v stainless steel) than the old source. The auditors were concerned that the bremstrahlung contribution from the nickel backing may result in erroneous calibration settings. Preliminary findings by RP management indicated that the settings were accurate; however, the issue was still being evaluated. The licensee's followup and corrective actions on this item will be reviewed in a later inspection (IFI 50-341/93026-01).

No violations or deviations were identifie . Imolementation of the New 10 CFR Part 20 (IP 83750)

The licensee implemented the new 10 CFR Part 20 on October 1,199 While the overall change will be reviewed during routine inspe:tions, efforts to date are summarized belo Plannina and Preparation A licensee task force was created to review plant procedures and identify the bases for procedural requirements. These bases were evaluated for technical accuracy, collected into a central document, and then distributed to the RP group. The inspector .

verified that the bases referenced appropriate industry guidance and were appropriately docume,ted in procedure In September 1993, workers attended a one hour training session summarizing new Part 20 requirements. Additional training was provided to RP technicians through continuing training. After k October 1, 1993, workers who had missed training were denied access to the radiological controlled area (RCA). The nuclear-general employee training (NGET) program was also revised to tailor training to the access desired. Unrestricted RCA access required completion of a twelve-hour, full radworker training course, while limited (no entry into radiologically posted areas)

access required an eight-hour, initial radworker course. The inspector verified that training materials were consistent with industry guidanc A pre-implementation audit performed by the licensee's quality assurance (QA) group concluded that, with the exception of minor administrative problems, preparations were good. While post-implementation will be reviewed through the surveillance program, the inspector commented on the desirability of performing a formal audi Implementation The aforementioned bases document contained guidance for monitoring occupational dose, which was implemented in lower tier procedures. Administrative limits were defined at 20% of the new Part 20 values, with the exception of declared pregnant women (DPW), who were limited to new Part 20 values. A daily summary of personnel exposures was generated for dose tracking, which highlighted those workers 180% of an administrative limit. These

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. individuals were excluded from the RCA'pending RP. approval, j

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Licensee policies concerning DPW and planned special exposures - '

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(PSEs) were mostly consistent with NRC guidance (section SC).-

Approval of the senior vice president was required to ' initiate a

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The licensee revised their ALARA planning to incorporate the total'

effective dose equivalent (TEDE) concept. -Although. external dose planning will continue as described in inspection report 50- j

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341/92020(DRSS), jobs where airborne activity was expected to '

exceed 0.3 derived air concentrations (DACs) required furthe j evaluation to determine whether respiratory or engineering  !

controls were necessary to maintain TEDE ALAR The licensee concluded that external dose monitoring was i unnecessary per 10 CFR 20.1502, but plan to continue monitoring i all workers qualified in full. radworker training (section 5A).  :

Workers qualified in limited radworker training were provided  ;

dosimetry but not considered monitored. Although a similar .

evaluation concluded that internal monitoring was also not '

required, annual and routine entrance / exit whole body counting l (WBCt) will continue. Investigational WBCts will occur for -

workers suspected of exceeding 4 DAC-hours (acuts or accumulated intake) or with-facial contamination. The_ inspector cautioned the licensee that measured exposures must be recorded regardless of" .,

monitoring status, i t Inspector Review  !

The inspector selectively reviewed plant procedures to verify that new Part 20 requirements were incorporated and that specific-program changes were based on current industry and NRC guidanc While no major problems were identified, the inspector commented j that licensee guidance incorrectly implied a DPW could receive a l PSE with associated fetal dose. This will be corrected by the  :

licensee. The inspector'also reviewed selected jobs using the  !

TEDE_ concept and verified through interviews that workers-were becoming attuned to.new Part 20 terminology. During plant tours (section 10), the inspector noted good posting and control of very i high radiation areas. Overall, the licensee appears to have made  :

a good transition to the new Part 2 t No violations or deviations were identifie . External Exposure Control and ALARA (IP 83750) .

The inspector reviewed the licensee's external dosimetry program, l radiological performance and the ALARA progra i

Thermoluminescent dosimeters (TLDs) were processed monthly onsite.for .;

beta, gamma, and neutron exposures. The licensee was recently - '

recertified by the national voluntary laboratory. accreditation program j (NVLAP) in categories I-VIII. Semi-annually, the licensee has an j offsite contractor perform a NVLAP proficiency test to supplement the  !

routine TLD spiking performed during monthly processing. The inspector j 5 ,

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reviewed the spiked TLD test results for adverse trends and also reviewed comparisons between TLDs and self-reading dosimeters; no problems were identifie I To date, station dose was 32 person-rem (0.32 person-Sv) . including about 2.2 person-rem (0.2 person-Sv) from forced outage work and about 10 ;

person-rem (0.10 person-Sv) from emergent work. Of the emergent work, ,

about 3.1 person-rem (0.03 person-Sv) occurred in the. steam tunne Significant activities included repair of the west gland steam exhauster bearing, repair of the #1 south feedwater heater, and replacement of the north condenser pump motor and #3 low pressure stop valve unit actuato ,

The low dose total was attributed to several good ALARA initiatives including power reductions, remote monitoring via cameras and increased use of temporary shielding. Altogether, over 5 person-rem (0.05 person-Sv) was save Other ALARA actions included installation of permanent shielding on the i reactor water clean up sample sink which reduced general area dose rates from 12 to 5 mrem /hr (0.12 to 0.05 mSv), and flushing of the chemical waste tank transfer line and the chemical waste tank, which reduced-contact dose rates from 5000 mrem /hr (50 mSv/hr) and 800 mrem /hr (8 mSv/hr), respectively, to 15 mrem /hr (0.15 mSv/hr) and 1 mrem /hr (0.01 mSv/hr), respectively. Several source term reduction initiatives were also taken, including removal of stellite from the south heater drain pump discharge check valve (seat and rib guides) and testing of a contract reverse osmosis unit to improve water chemistr .

No violations or deviations were identifie . Internal Exposure Control (IP 83750)

The inspector reviewed the licensee's internal dosimetry program including calibration of the whole body counter (WBC), respirator control and assessment of intake .

The licensee used two standup WBCs for routine WBCts and a sitdown WBC for investigational WBCts. A new phantom was recently purchased to standardize calibration of the standup and sitdown counter Previously, a separate phantom was used for each calibration. The calibration source was evenly distributed within the phantom and was replaced annually. The inspector verified the calibration source was traceable to the National Institute of Standards and Technology (NIST)

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and observed the calibration of a standup WBC. The RPT performing the calibration was knowledgeable of system operation and the calibration procedure. The inspector also noted that shiftly source checks i indicateo no decline in system performance. The licensee's measured l lower limits of detection were consistent with the 4 DAC-hour '

investigation sevel (section 58).

l The inspector noted that the respirator storage and issuance area was a clean and well maintained. Used respirators were cleaned by an offsite I contractor and surveyed by both contractor and licensee personne !

Respirators exceeding 100 disintegrations per minute (dpm)/100 cm* l smearabie, 20 dpm/100 cm' alpha, or 100 dpm/100 cm* fixed were l

considered contaminated. Stared respirators were inspected monthly, and j 6  !

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worker respirator qualifications were checked prior to issuance.- .

Overall, the respirator control program appeared goo !

No intakes above the licensee's administrative limits have occurred to dat No violations or deviations were identifie . Control of Radioactive Contamination (IP 83750) l The inspector reviewed the licensee's contamination control program including calibration of whole body friskers (WBFs) and portable .

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instrumentation, contaminated area recovery, and personnel contamination !

events (PCEs).

The licensee calibrated the WBFs semi-annually. and tracked the ,

calibration status monthly. A standard calibration geometry was used ,

and the calibration source activity corresponded to the licensee's ;

contamination limit of 100 counts per minute (cpm) above background ;

using a hand held frisker. The inspector roted that RPTs were knowledgeable of calibration procedures and WBF operation, and that workers appropriately used the WB ,

The licensee used a limit of 500 dpm/100 cm', compared to an industry average of 1000 dpm/100 cm', for posting contaminated areas. Through an

- aggressive decontamination program only 7% of the plant was considered ,

contaminated. The inspector observed that contaminated areas were well maintained, portable instrumentation was calibrated and readily ,

available, and workers used good contamination control practice To date, about 15 PCEs, mainly clothing contaminations, were recorded significantly below the licensee's goal of 40. Each event was well investigated. One skin dose assessment, attributed to a hot particle, l was performed by the licensee and was verified by the inspecto No violations or deviations were identifie . Fuel bak (IP 84750) I The inspector reviewed the licensee's identification of a fuel leak as described in inspection report 50-341/93013(DRP). .

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Between June and November 1993, offgas radiation levels increased from 5

_ mrem /hr -(0.05 mSv/hr) (normal reading) to 20 mrem /hr (0.2 mSv/hr), with >

a corresponding rise in released activity from 200 microcuries (uCi)/sec (7400 kilobecquerels (kBq)/sec) to 1400 uti/sec (51,800 kBq/sec). No significant changes were seen in reactor coolant chemistry and offsite doses remained well below technical specification limits. A " flux tilt" operation on August 8,1993, indicated a small leak in one fuel rod, which will be removed during the 1994 RFO. Currently, offgas radiation levels and released activity have declined to about 8 mrem /hr (0.08 mSv/hr) and 230 uCi/sec (7810 kBq/sec), respectively. Licensee actions to date to mitigate the fuel leak's effects appear good. This item will be reviewed during routine inspection ,

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, I No violations or deviations were identifie . Plant Tours (IPs A 10 and 86750)

i The inspector toured the RCA and accompanied an operator during routine rounds. Housekeeping was good, and operators indicated that rounds were performed in street clothes. Discussions with workers and station management indicated a consistent message of ALARA and willingness to work with the RP group. Radiological postings were consistent with Part 20 requirements and protective clothing storage areas were in good condition. Confirmatory measurements taken by the inspector were in good agreement with licensee values.- Workers wore appropriate dosimetry and good radiological practices were also noted during observations of work activities. During tours of the radwaste processing areas, the inspector noted significant improvement in lighting and in maintenance i of doors. Corrective actions were also noted for radwaste deficiencies identified in inspection report 50-341/93008(DRSS), which will b further reviewed in a subsequent inspectio No violations or deviations were identifie . Exit Interview  !

The scope and findings of the inspection were reviewed rith licensee representatives (section 1) at the conclusion of the inspection on December 10, 1993. No violations or deviations were identified. The licensee did not identify any documents as proprietary. The following matters were specifically discussed by the inspector:

• Management reorganization (section 3)

• Implementation of new Part 20 (section 5)

• Radwaste improvements (section 10)

Attachments: Table 1, Interlaboratory Test Results, 4th Quarter 1993 Attachment 1, Criteria for Comparing Analytical Measurements

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TABLE 1 ,

U.S. NUCLEAR REGULATORY COMMISSION REGION III t CONFIRMATORY MEASUREMENTS PROGRAM

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FACILITY: Fermi 2

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FOR THE 4TH QUARTER OF 1993

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SAMPLE NUCLIDE NRC VAL.* NRC ERR.' LIC. VAL.2 LIC. ERR.2 RATI0' RES* RESULT * .[

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Spiked 5 H-3 1.11E-04 5.57E-06 1.10E-04 1.00E-05 0.99 20 A j Liquid SR-90 1.97E-05 9.87E-07 1.00E-05 1.00E-06 0.51 20 D !

. FE-55 1.08E-05 5.38E-07 9.50E-06 1.80E-06 0.88 20 A :

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Duplicate SR-90 1.97E-05 9.87E-07 2.00E-05 1.00E-06 1.02 20 A :

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i These are dimensionless quantities and are compared on a relative basis onl ' Ratio = Licensee Value / NRC Value ' Resolution - NRC Value / NRC Error (one standard deviation) Result : The result of the comparison is based on the criteria in Attachment 1 and is expressed by the following:

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A = Agreement * - Criter.ia Relaxed D - Disagreement NC - No Comparison * Liquid sample was prepared by the Radiological and Environmental  !

Sciences Laboratory at the Idaho Field Office of the US Department of Energy for the US Nuclear Regulatory Commissio .

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ATTACHMENT 1 l CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS'

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lnis attachment provides criteria for comparing results of capability tests !

and verification mea'surements. The criteria are based on an empirical  :

relationship which combines prior experience and the accuracy needs of this !

progra In these criteria, the judgement limits are variable in relation to comparisons of the NRC's value to its associated one sigma uncertainty. As -

that ratio, referred to in this program as " Resolution", increases, .the

acceptability of a licensee's measurement should be more selectiv Conversely, poorer agreement should be considered acceptable as the resolution l decreases. The values in the ratio criteria may be rounded to fewer  ;

significant figures reported by the NRC Reference Laboratory, unless such i rounding will result in a narrowed category of acceptanc *

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RESOLUTION' AGREEMENT CRITERIA ,

(RATIO * RANGE) *

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<4 NO COMPARISON l t

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4-7 0.5 - ;

8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33  !

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51 - 200 0.80 - 1.25 l

> 200 0.85 - 1.18 I i

.l . Resolution - NRC Value / NRC Error (one standard deviation)  !

2. Ratio - Licensee Value / NRC Value

Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance i criteria and identified on the data shee i i

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