IR 05000341/1998011

Insp Rept 50-341/98-11 on 980608-12.No Violations Noted. Major Areas Inspected:Radiological Controls for Spent Fuel Pool Clean Out Project

ML20249C502
Person / Time
Site:	Fermi
Issue date:	06/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20249C501	List: IR 05000341/1998011 ML20249C500
References
50-341-98-11, NUDOCS 9806300179
Download: ML20249C502 (13)

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!, U.S. NUCLEAR REGULATORY COMMISSION REGION 111 i

I Docket No: 50-341 I l

License No: NPF-43 Report No: 50-341/98011(DRS)

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Licensee: Detroit Edison Company (DECO)

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Facility: Enrico Fermi, Unit 2

Location: 6400 N. Dixie Hw l Newport, MI 4816S j l

L Dates: June 8-12,1998

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! Inspectors: R. Glinski, Radiation Specialist D. Nissen, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l

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EXECUTIVE SUMMARY Enrico Fermi, Unit 2 i NRC Inspection Report 50-341/98011 The radiological controls for the spent fuel pool clean out project effectively maintained a reasonable collective dose for this task. Recent initiatives significantly improved the overall performance of the Post Accident Sampling System. The program to handle, store, classify, and transport solid radioactive material continued to be wellimplemented. Thorough audits and reviews of vendor services identified significant problems which impacted radiation protection operation e The radiological controls effectively maintained a reasonable dose for the spent fuel pool clean out project. The radiation protection staff correctly anticipated and controlled airborne radioactivity to minimize the potential for intemal dose (Section R1.1).

• The training, procedures, and implementation of the radioactive materials transportation program remained effective, as shipping documentation and inspector observations confirmed that the plant met regulatory requirements (Section R1.2).

e The implementation of the solid radwaste program regarding radwaste processing, storage, and shipment continued to be effective. In particular, the dewatering equipment was highly reliable and the On Site Storage Facility surveillance were comprehensive (Section R1.3)

e The program to sample and analyze waste streams for the determination of radionuclides I scaling factors remained effective and enabled the staff to appropriately classify radwaste for shipment. However, issues with scaling factor determinations for two radionuclides were identified (Section R1.4).

• The training self-assessment was comprehensive and identified areas for improvemen The licensee's audits and reviews of vendor services were thorough, performance-based, and identified significant problems which impacted . shipping operations. The radiation protection staff's responses to these vendor problems were appropriate (Section R7.1). ]

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Report Details R1 Status of Radiation Protsction and Chemistry (RP&C) Controls R1.1 Radiation Protection Performance for the Soent Fuel Pool Cleanuo Project Insoection Scoce (IP 83750)

The inspectors reviewed radiation exposure and radiological control data, and interviewed radiation protection (RP) staff regarding the performance during the spent ;

fuel pool cleanup projec ' Observations and Findinas The RP staff initiated a project to dispose of control rod blades, low-power radiation monitors, velocity limiters, and Tri-Nuk filters from the spent fuel pool. The original dose estimate for this project was approximately 3200 millirem (mrem). During this project, the licenses added scope to include the repackaging of reactor water cleanup (RWCU)

impellers, control rod drive (CRD) filters, and CRD rebuild room sink filters. This added scope involved the opening, removal, and repackaging of highly contaminated dry materials. Because of the potential for generating airborne radioactivity by handling dry l materials, the crew members wore respiratory protection and there was a high efficiency j particulate air (HEPA) filter unit positioned near the shipping cask . There was only one air sample which exceeded 0.3 derived air concentrations (DAC), which was collected in response to a continuous air monitor alarm during the RWCU impeller loading. The sample showed 0.31 DAC, comprised almost exclusively of cobalt-60. After the alarm, the staff used tongs to handle the CRD filters and, as necessary, conducted work in a glove bo The current dose for this task was in excess of 3600 mrem and in accordance with procedure the RP staff conducted an in-Progress At. ARA review to determine the cause. The staff determined that the extra dose was due to: (1) the additional scope (500 mram), (2) higher than anticipated dose rates and dose for equipment setup (500-600 mrem), and (3) the fact that the licensee allowed the contractor to perform maintenance on the cutting equipment in preparation for work at another facility (100 mrem). The RP staff has also planned to dispose of double blade guides and reactor head shroud bolts from the spent fuel pool during this project, but the remainder of this work will not be conducted until after the upcoming refueling outage. The inspectors determined that the ALARA measures were effective and the radiation dose was reasonable for the work accomplishe Conclusions The inspectors concluded that the radiological controls effectively maintained a reasonable dose for the spent fuel pool cleanup project. The RP staff correctly anticipated and controlled airborne radioactivity to minimize the potential for intemal dos :

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R1.2 Transportation of Radioactive Materials Insoection Scoce (IP 86750) )

The inspectors reviewed the training and qualifications of personnel authorized to make radioactive material (RAM) shipments, the applicable procedures which governed transportation of RAM, and shipping papers associated with specific RAM shipment Intentiews with plant personnel regarding the implementation of the RAM shipping prograrn were also conducte Observations and Findinas The inspectors noted that the licensee's training program addressed both Department of i Transportation (DOT) and NRC regulations, and the training was effectively implemented. Several members of the RP staff successfully completed both vendor-supplied and onsite training courses for the handling and shipping of RAM. The individuals authorized to conduct RAM shipments and to review shipping papers were l I

documented in a licensee memorandum dated June 1998. Overall, the RAM shipping personnel were very knowledgeable of transportation processes and federal regulation The inspectors reviewed the licensee's procedures for transporting radioactive waste and materials and noted that the procedures were clearly written and comprehensively addressed issues regarding the proper shipment of RA The inspectors reviewed several procedures regarding the preparation of shipments of radioactive materials and waste, as well as various shipping papers prepared by the ,

licensee. The inspectors verified the calculations for determining the proper .

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transportation designation and waste classification in shipping papers associated with representative LSA shipments. In addition, the shipping manifests and associated paperwork contained the proper information regarding waste classification, reportable quantity, physical and chemical form, radiation levels, emergency response information, volume, weight, total activity (in SI units), the 95% rule for listing nuclides, and were signed by authorized personnel. The activities of tritium, carbon-14, technetium-99, and lodine-129 for waste disposal shipments were listed as required by 10 CFR 20, Appendix G. And when applicable, the licensee utilized the equivalent of NRC Forms 540,540A, and 541 for RAM shipments. The RP staff maintained the current RAM licenses for all receivers of their RAM shipment The inspectors reviewed the shipping package and papers associated with the limited quantity shipment 98-032 and verified that this shipment was conducted in accordance with DOT regulations found in 49 CFR 173.421. The inspectors also noted that: (1) the RP staff had a current copy of the receiver's license which indicated the receiver was authorized for this RAM, (2) the checklist covered the appropriate requirements, (3) the shipping papers contained the proper information, (4) the required radiation surveys l were performed, (5) the appropriate scaling factors were used for the shipment, and 6)

l the package was signed out by an authorized shippe l l

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The inspectors determined that the training, procedures, and implementation for the j RAM transportation program remained effective, as licensee documentation and l inspector observations confirmed that the plant met regulatory requirement )

R1.3 Solid Radioactive Wage Management 1 Insoection Scoce (IP 86750)  !

The inspectors reviewed the solid radioactive waste program including the storage, processing, implementation, and documentation of radwaste operations The inspectors conducted walkdowns and radiological surveys of the On Site Storage Facility (OSSF),

and temporary storage areas for low level RAM outside the Radiologically Restricted Area (RRA).' The inspectors also reviewed selected documents and interviewed various radwaste personne Observations and Findings The inspector observed that RAM stored in the OSSF was appropriately marked and labeled. Confirmatory surveys determined that radiation levels indicated on RAM tags were appropriate. Continuous air monitoring and filtered ventilation were used to detect and mitigate any airborne contamination. The RP staff has planned to reinstitute the use of their compactor to process high radiation Dry Active Waste (DAW) in order to reduce radworker radiation exposure and prevent RAM from shifting during transpor The staff has replaced the pre-filters and HEPA filters, and conducted other minor maintenance. However, because this unit continues to give a ruptured gauge indication additional repairs will be conducted before the licensee will use the compacto The radwaste staff conducted a weekly visualinspection of stored RAM using remote cameras mounted throughout the OSSF. In addition, radwaste staff conducted periodic inspections of drums and high integrity containers (HIC) for leaks and damage by lifting the containers with the overhead crane, accompanied by a close examination of the container with OSSF cameras. The inspectors observed an OSSF surveillance and noted that staff conducted the surveillance in accordance with procedure. This observed OSSF survey was effective since a previously unidentified high radiation RAM bag was located. The staff indicated that this bag was uncovered by the recent relocation of several containers from the storage bay to the refuel floor in support of the spent fuel clean out project. A radwaste supervisor retrieved the bag, verified that proper labels were attached, and placed the bag in an appropriate containe The Updated Final Safety Analysis Report (UFSAR) stated that resin could be

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dewatered or solidified on site. No solidification was occurring on site; however, the

! licensee possessed the equipment to conduct this process. A vendor representative operated the vendor-supplied dewatering equipment (RDS 1000-3) to prepare spent resin for shipment. The dewatering process was performed in accordance with vendor procedures, which were approved and controlled by the license l

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i-E,, The inspectors discussed the maintenance and operability of the RDS unit with a -

L vendor representative, as the plant has a vendor maintenance contract. The 1997 and l; 1998 RDS data showed that maintenance consisted of air and oil filter changes, and

! flushes of the moisture separator. The vendor repaired the RDS de-mister in January

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_1998, but the down time was minimal and did not affect waste processing. Therefore, l the RDS operability was high, the maintenance was routine, and the repairs were mino The inspectors did not identify any materiel condition issues with this equipment.

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The inspectors performed several walkdowns of the reactor and turbine buildings and noted that radiological postings and boundaries were well maintained and locked high radiation area doors were locked. No material condition or housekeeping problems -

were identified. In addition, the inspectors observed the collection of a grab sample

from the reactor building gaseous effluent stack as a compensatory measure due to a

pressure indicator failure of the reactor building noble gas detector. These samples were appropriately collected every eight hours, and no sampling issues were identifie i

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Conclusions

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. The inspectors determined that the implementation of the solid radwaste program regarding radwaste processing, storage, and shipment continued to be effective.' In particular, the dewatering equipment was highly reliable and the OSSF surveillance were comprehensiv R1.4 Sohd Radioa.ctive Waste Classification t Insoection Scone (IP 86750F I

The inspector interviewed staff, and reviewed the applich!e procedures and documentation regarding the sampling and analysis to ensure compliance with 10 CFR -

61 requirements for waste classificatio l

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The licensee's Process Control Program (PCP) involved the periodic collection of samples to characterize wet homogeneous solid wastes, DAW, filter media, and i

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irradiated hardware. The waste stream samples were taken annually, or when available, to coincide with the genemtion of a particular waste stream. Additionally, new samples woui1 be taken if changes in water chemistry occurred which could change the radiological content of the radwaste. The resin samples for 10 CFR 61 analysis were composites of various batches of a particular waste stream and the DAW samples were

. smears which were taken from a variety of contaminated areas throughout the plant.

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. The current DAW smears were collected from the turbine building basement floor drain sump, the radwaste basement floor drain, the OSSF compactor, and the RWCU sample L sink. The 10 CFR 61 samples were analyzed by a vendor laboratory to quantify the

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! radionuclides present and generate isotopic ratios'(scaling factors) for quantifying the

- difficult to measure isotopes. The RP staff determined the radwaste tritium content from E-BAR analysis in accordance with station procedure, p

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, The inspectors reviewed the 1997 scaling factor determination data and the licensee's memorandum which compared the results to the previous determination. In accordance with procedure, scaling factor changes greater than an order of magnitude were discussed. The strontium-90 (Sr-90) content for condensate resin increased by a factor of 10.8, which was due to an increase in Sr-90 content and a decrease in the key nuclide cesium-137 (Cs-137). This change in nuclide content was thought to be due to a recent fuel failure involving a relatively new fuel bundle. However, the inspectors noted that there was no Sr-89 in this waste stream. Because the plant had been in operation and Sr-89 would be expected, the inspectors discussed the apparent absence ,

of Sr-89 with site staff. Plant personnel reviewed past 10 CFR 61 data and found that a

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former vendor laboratory had regularly reported Sr-89 in plant waste streams. The cognizant RP staff then contacted the current vendor, who stated that Sr-89 analyses were not conducted because they were not specifically requested. The staff then revised their 10 CFR 61 requested analyses to include Sr-89. The Sr-89 content was not expected to significantly alter the scaling factors, as the Sr-90 scaling factor is relatively low. However, inclusion of Sr-89 would more accurately reflect the radiological content of the waste stream The inspector also noted that the carbon-14 (C-14) content of the condensate resin waste stream content increased over two orders of magnitude from the previous determination, from less than detectable (with no scaling factor) to approximately 6% of this waste stream. After discussions, site staff reviewed past data and found that previous 10 CFR 61 analyses had consistently quantified C-14 in radwaste. The staff indicated that this analytical problem may have been due to the use of a different vendor for the two most recent 10 CFR 61 analyses, and the fact that C-14 was a difficult radionuclides to measure. However, this scaling facto ci'ange was not addressed in the 10 CFR 61 comparison memorandum because it did nut constitute a change from a previous scaling factor. The inspector discussed with RP staff whether a change from zero to a significant scaling factor for a required 10 CFR 61 radionuclides should also be addressed in the 10 CFR 61 memorandum, and the staff indicated that this practice would be reviewed. In addition, the fuel pool resin cobalt-58 and the DAW cerium-144 scaling factors changed significantly; and these changes were attributed to radioactive decay and the recent fuel failure, respectively. Other than Sr-89 and C-14, the inspector determined that the licensee's assessment of scaling factor changes was appropriate The inspector reviewed the station program to determine the radioactivity content of RAM shipments. To determine the total radioactivity in spent resin for RAM shipments, samples were taken from each batch resin. The sample was obtained by the use of an isolok sampler which perforrned ten sampling cycles during the recirculation of a holding tank. The inspectors observed the recirculation pumps and the isolok sampler, and no materiel condition issues were identified. The gamma spectrometry was conducted by the chemistry laboratory and the key nuclides (cobalt-60, cesium-137, and cerium-144)

designated to establish scaling factors for difficult to measure nuclides were used to determine the activity of the various nuclides for each shipment. For DAW, the radwaste staff conducted a dose-to-curie analysis usiag commercial software and the DAW scaling factors. The inspector noted that this methodology was appropriat .

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, The inspectors also reviewed the lower limits of detection for the difficult to measure nuclides and determined that they met the guidance in the NRC's " Final Waste Classification and Waste Form Technical Position Papers."

I Conclusions Overall, the plant's program to sample and analyze waste streams for the determination of radionuclides scaling factors remained effective and enabled the staff to appropriately classify radwaste for shipment. However, issues with scaling factor determinations for two radionuclides were identifie R7 Quality Assurance in RP&C Activities l

R7.1 Self-Assessments and Audits of RP&C Performance Insoection Scoce (IP 86750)

The inspectors reviewed a training self-assessment and an RP audit of vendor services regarding solid radwaste and transportation performance. The inspectors also interviewed staff concerning problems with vendor services that have been identified recently by plant personne Observations and Findinos The inspectors reviewed the recent audit of vendor services performed by the radwaste shipping supervisor. This vendor conducted waste processing for the licensee. Every two years the licensee performed an audit to ensure that the vendor complied with the regulations. The audit reviewed a shipment of 14 drums of processed waste packaged in a decertified cask; one of these drums contained RAM from the licensee. The audit was comprehensive and identified several significant findings. For example, improper manifesting of the shipment was identified. The shipment was manifested as 14 packages; however 6 of the drums exceeded the 1 R/hrlimit. In addition, the package contained less than 15 grams of fissile material which required that the wording " fissile exempt" be added to the proper shipping name, however this designation was not made. Also, improper classification of waste was identified, as waste that was actually Class B and C was classified by the vendor and shipped as Class A waste. Finally, the j vendor used a NRC package authorized for transporting greater than A2 quantity waste, i but the vendor was not a registered user as they did not have a NRC quality assurance j program. In response .the audit 6ncings, the licensee stopped shipping waste to this vendor and licensee personnel indicated that a Nuclear Quality Assurance audit was scheduled for later in 1998. Any further dealings with tnis vendor will be dependent on the findings of this planned audi During the spent fuel pool (SFP) cleanup project, the licensee required the usa of a specialized shipping cask, the TN-RAM USA /9223/B(U) cask. After receiving this cask q from the RAM disposal vendor the licensee conducted a thorough inspection before the staff would place the cask into the SFP. However, the RP staff identified the presence

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l, of a 4-inch piece from a control rod boron tube and other foreign material in the cask.

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Radiation surveys indicated that the boron tube was 40 Roentgen per hour on contac The licensee contacted the appropriate organizations, and the vendor performed oversight for the return of the cask to their facility. This failure caused the licensee to postpone shipment of RAM from the SFP until after the upcoming refueling outage. The inspectors determined that the licensee's thorough inspection and survey of the cask identified a significant weakness in the vendor's progra Also related to the SFP cleanup project, the vendor who performed the dose-to-curie waste characterization submitted incorrect information to the licensee. The RP staff reviewed the data and noted that the vendor listed the presence of fermium-254 in this irradiated hardware, but did not list iron-59 (Fe-59). The characterization of another set of radwaste also did not include Fe-59, which RP staff knew was present in this wast The licensee contacted the vendor, who acknowledged the mistakes and submitted a re-analysis of the waste. This failure to provide accurate information caused the licensee to postpone a Class B shipment for several days. The inspectors determined that the RP data review identified a significant problem with the vendor's analysi The licensee conducted a self-assessment of training for RP and chemistry technicians in April 1998. The assessment team consisted of supervisory and technical staff who performed a comprehensive examination of initial and continuing training. The team concluded that the program met accreditation objectives. The instruction reflected current practices, and the RP and chemistry organizations demonstrated ownership for on-the-job (OJT) training. However, the team identified the lack of incorporating fundamental knowledge, the failure to incorporate industrial safety practices or document OJT evaluation failures, and lack of Program Review Committee oversight as training weaknesses. Licensee staff initiated a Condition Assessment Resolution Document (CARD) to address these weaknesses, Conclusions The training self-assessment was comprehensive and identified areas for improvemen The licensee's audits and reviews of vendor services were thorough, performance-based, and identified significant problems which impacted shipping operations. The RP staff's responses to these vendor problems were appropriat R8 Miscellaneous RP&C lssues R8.1 (Closed) Insoection Followuo item 50-341/96006-10: inability to obtain a PASS sampl During the 1996 Emergency Preparedness (EP) exercise, chemistry staff were unable to obtain a sample from the Post Accident Sampling System (PASS). Since that time the licensee has experienced communication, procedural, and materiel condition problems 1 which precluded the PASS from functioning consistently. The licensee then assembled l

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a PASS Evaluation Team, enlisted new system engineers, and addressed several f materiel condition issues. The inspector reviewed 1998 PASS data, observed the j

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sampling and analysis of a drywell gas PASS sample during the 1998 EP exercise, and j interviewed plant personnel regarding PASS issue i

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, The data for reactor coolant samples demonstrated that the chemistry staff successfully collected the sample.t and the radionuclides, pH, and conductivity results were well within the specified acceptance criteria. The drywell atmosphere samples for 1998 PASS operation and the EP exercise also showed that sampling and analysis were acceptabl The inspector did not observe any sampling, analysis, or materiel condition concerns regarding the PASS sampling station or control panel. This item is close l-X1 . Exit Meeting Summary J

The inspectors presented these inspection results to licensee representatives during an exit meeting on June 12,1998. The licensee did not indicate that any materials examined during the inspection should be considered proprietar ^I

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, PARTIAL LIST OF PERSONS CONTACTED Licensee J. Carter, Radwaste Supervisor L. Crissman, General Supervisor, Radwaste J. Davis, Training Director P. Fessler, Plant Manager R. Gaston, Compliance Supervisor K. Hansley, Compliance Englaeer E. Kokosky, Radiation Protection Manager G. Macadam, General Supervisor, Radiation Protection Operations M. Machlik, Supervisor ll M. Mulvaney, System Engineer J. Oetken, Radiological Engineer ]

B. Weber, Supervisor, Radwaste Shipping D. Willer, System Engineer i D. Williams, Radiological Engineering Supervisor j

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i G. Harris, Senior Resident Inspector, Fermi 2 C. O'Keefe, Resident inspector, Fermi 2 l

lNSPECTION PROCEDURES USED iP 83750, " Occupational Exposure"  ;

IP 86750," Solid Radioactive Waste Management and Transportation of Radioactive Materials"

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ITEMS OPENED, CLOSED, AND DISCUSSED CLOSED 50-341/96006-10 IFl Inability to obtain a PASS sampl l l

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, PARTIAL LISTING OF DOCUMENTS REVIEWED

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Updated Final Safety Analysis Report (UFSAR), Section 11.5 - Solid Radwaste System UFSAR Section 11.7 - On Site Storage Facility Self-Assessment of the Chemistry and Radiation Protection Accredited Training Program i Memorandum NPRC-97-0401, " Scaling Factor Comparisons".

Memorandum NPRC-98-0018, " Detroit Edison Radwaste Inspection of November 12,1997".

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Memorandum NPRC-98-0211," Radioactive Material Shipment".

Nuclear Production Operating Procedure (NPOP) 65.000.506, Rev.14, " Shipping Low Specific ,

Activity (LSA) Radioactive Material". l l

NPOP 65.000.520, Rev. 6," Scaling Factors for Radioactive Waste Assay".

NPOP 65.000.523, Rev. 2 "Radwaste Shipments".

MRP21, Rev.3, "Radwaste Shipping Operations" MRP19, Rav. 2, " Shipping Notifications".

Fermi 2 - 1997 Annual Radioactive Effluent Release and Radiological Environmental Operating Repor ,

Fermi 2 Process Control Program Manual, Rev.1 Fermi 210 CFR 61 Compliance Program Manual, Rev.1 Radwaste Shipment Packages98-032,98-014,98-013,98-007,98-024 Chemistry Specifications, CHS-AUX-09, Revision i

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, LIST OF ACRONYMS USED l

ALARA As Low As is Reasonably Achievable CARD Condition Assessment Resolution Document CRD Control Rod Drive DAW Dry Active Waste DOT Department of Transportation HEPA- High Efficiency Particulate Air HI High Integrity Container l LSA Low Specific Activity mrem millirem NQA Nuclear Quality Assurance i

OJT On-the-Job Training OSSF On Site Storage Facility l' RAM Radioactive Material i R Rsdiation Protection RRA Radiologically Restricted Area RWCU Reactor Water Cleanup Unit SCO Surface Contaminated Object St International System units SFP' Spent Fuel Pool TLD Thermoluminescent Dosimetry UFSAR Updated Final Safety Analysis Report l

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