ML102010505

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Independent Confirmatory Survey Project-Specific Plan for the Decommissioning of the Enrico Fermi Atomic Power Plant, Unit 1
ML102010505
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/08/2010
From: Bailey E
Oak Ridge Institute for Science & Education
To: Stephen Giebel
NRC/FSME/DWMEP/DURLD/RDB
References
DCN 2018-PL-01-0
Download: ML102010505 (10)


Text

July 8, 2010 Mr. Stephen Giebel U.S. Nuclear Regulatory Commission, Health Physicist

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ORISE OAK RIDGE INSTITUTE FOR SCIENCE AND EDUCATION Office of Federal and State Materials and Environmental Management Programs Reactor Decommissioning Branch, Mail Stop T8F5 Rockville, MD 20852

SUBJECT:

INDEPENDENT CONFIRMATORY SURVEY PROJECT -SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1, NEWPORT, MICHIGAN (DOCKET NOS. 50-16) DCN 2018-PL-01-0

Dear Mr. Giebel:

The Oak Ridge Institute for Science and Education (ORISE) is pleased to provide the enclosed Project-Specific Plan for conducting in-process reviews and confirmatory surveys of the fmal status survey activities of Unit 1 at the Enrico Fermi Atomic Power Plant located in Newport, Michigan.

You provided approval of the draft plan as written in a July 9, 2010 email. You may contact me at 865.576.6659 or Tim Vitkus at 865.576.5073 if you require any additional information.

Erika N. Bailey Health Physicist/ Project Manager Interim Associate Survey Projects Manager ENB:ds Enclosure c:

S. Roberts, ORISE/IEA V T. Vitkus, ORISE/IEA V T. Smith, NRC/TWFN 8F5 B. Snell, NRC/Region III B. Watson, NRC/TWFN 8F5 File/2018 Technical Management Team Member Telephone: 8Ci5.')"Ci.6659 Fax: SCiS.2.+ 1.3-197 J.:-mail: crika.baile\\.@orau.org P.O. Box 117 I Oak Ridge, TN 37831 I www.orise.orau.gov

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 Enrico Fermi Atomic Power Plant 1

2018-PL-01-0 INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1, NEWPORT, MICHIGAN INTRODUCTION Unit 1 of the Enrico Fermi Atomic Power Plant (Fermi 1) is a fast breeder reactor design that was cooled by sodium and operated at essentially atmospheric pressure. On May 10, 1963, the Atomic Energy Commission (AEC) granted an operating license, DPR-9, to the Power Reactor Development Company (PRDC), a consortium specifically formed to own and operate a nuclear reactor at the Fermi 1 site. The reactor was designed for a maximum capability of 430 Megawatt; however, the maximum reactor power with the first core loading (Core A) was 200 Megawatt. The primary system was filled with sodium in December 1960 and criticality was achieved in August 1963.

The reactor was tested at low power during the first couple years of operation. Power ascension testing above 1 Megawatt commenced in December 1965 immediately following receipt of a high-power operating license. In October 1966, during power ascension, zirconium plates at the bottom of the reactor vessel became loose and blocked sodium coolant flow to some fuel subassemblies.

Two subassemblies started to melt and the reactor was manually shut down. No abnormal releases to the environment occurred. Three years and nine months later after the cause had been determined, cleanup completed, and the fuel replaced, Fermi 1 was restarted. However, in November 1972 PRDC made the decision to decommission Fermi 1 since the core was approaching its burn-up limit. The fuel and blanket subassemblies were shipped off-site in 1973 and the secondary sodium system was drained and sent offsite. The radioactive primary sodium was stored onsite in storage tanks and 55-gal drums until it was shipped off-site in 1984. Decommissioning of Fermi 1 was originally completed in December of 1975. Effective January 23, 1976, DPR-9 was transferred to the Detroit Edison Company (DTE) as a possession only license. (DTE 2009).

SITE DESCRIPTION Fermi 1 is located in Monroe County near the town of Newport, Michigan and on the western shore of Lake Erie. Fermi 1 is located on the same site and within the same controlled area as Fermis Unit 2, although Unit 1 falls outside the protected operational area of Unit 2. The Fermi 1 License Termination boundary consists of 27,200 m2including roads, a railroad spur, buildings, and land areas, a portion of which is occupied by an oily waste basin (DTE 2009).

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 2

2018-PL-01-0 OBJECTIVES The objectives of the confirmatory surveys are to provide independent contractor field data reviews and to generate independent radiological data for use by the Nuclear Regulatory Commission (NRC) in evaluating the adequacy and accuracy of the licensees procedures and Final Status Survey (FSS) results.

RESPONSIBILITY Work described in this survey plan will be performed under the direction of Tim Vitkus, Survey Projects Manager and Erika Bailey, Project Manager of ORISE. The cognizant ORISE site supervisor has the authority to make appropriate changes to the survey procedures as deemed necessary, after consultation with NRC personnel. Changes to the scope of this survey plan or procedures will be documented in the site logbook.

DOCUMENT REVIEW ORISE will review the licensees FSS plans and procedures and final radiological survey data for adequacy and appropriateness taking into account the License Termination Plan, and Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) guidance (DTE 2010 and NRC 2000).

The purpose of these reviews are to ensure that the regulatory requirements are being met by the licensee. ORISE will submit findings and/or recommendations (if any) in a survey report to the NRC regarding the ongoing remediation and FSS activities following each site visit/in-process inspection.

PROCEDURES A survey team from ORISE will visit the Fermi 1 site to perform visual inspections and measurement and sampling activities. Survey activities will be conducted in accordance with the ORISE/IEAV Survey Procedures and Quality Program Manuals (ORISE 2008 and ORAU 2009).

HEALTH AND SAFETY A walk down of the areas to be surveyed will be performed in order to assess potential health and safety issues. Additionally, the proposed survey and sampling procedures will be evaluated to ensure that any hazards inherent to the procedures themselves are addressed in current Job Hazard Analyses (JHAs). Personnel will also adhere to the sites health and safety requirements. However, all requirements of the sites Radiation Protection Plan and ORISE Radiation Protection Manual shall apply if work in radiological areas is to be performed (ORISE 2005). Confirmatory activities may be conducted in areas that require radiation work permits but no special dosimetric considerations are expected.

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 3

2018-PL-01-0 BUILDING SURVEY PROCEDURES REFERENCE SYSTEM ORISE measurements and sampling locations will be referenced to the existing FSS grid system if possible. Otherwise, ORISE will reference survey information to specific X, Y coordinates from the southwest corner of the respective room. Information will also be plotted on site drawings. Specific areas may also be digitally photographed.

SURFACE SCANS Building scans will be performed on up to 100% of the accessible interior surfaces of the areas selected for confirmatory survey. If the scan coverage selected for a survey unit is less than 100%,

additional scans may be performed depending on findings and as necessary to delineate contamination boundaries if elevated radiation levels are detected. Particular attention will be given to cracks and joints in the floor and walls, ledges, and other horizontal surfaces where material may have accumulated. All detectors will be coupled to ratemeters or ratemeter-scalers with audible indicators. Locations of elevated direct radiation will be marked for further investigation.

Scans will be performed using NaI scintillation detectors for direct gamma radiation and gas proportional detectors and/or Geiger Mueller (GM) detectors for direct alpha and beta radiation, coupled to ratemeters or ratemeter-scalers with audible indicators. Locations of elevated direct radiation will be marked for further investigation.

SURFACE ACTIVITY MEASUREMENTS Construction material-specific background measurements will be collected as necessary from a nonimpacted area of the site for correcting gross activity measurements performed on structural survey units. Direct measurements for total alpha and beta activity will be performed at any locations of elevated surface activity identified by surface scans that potentially exceed unrestricted release limits established for the site. Dependent upon the ambient background in each area and also the FSS procedures being employed at the site, unshielded and shielded measurements may be performed at each location. The number of measurements performed will depend on findings as the survey progresses. Measurement locations may correspond to licensee locations for direct data comparison and/or the location(s) of elevated activity detected during scans. Measurements will be made using gas proportional or GM detectors, coupled to portable ratemeter-scalers.

MISCELLANEOUS MATERIAL SAMPLING At the discretion of the NRC site representative, samples of miscellaneous material such as concrete, paint, sediment, drain, and dust residues may be collected from locations that are not accessible for direct survey or from locations of elevated direct radiation detected by surface scans.

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 4

2018-PL-01-0 EXTERIOR SURVEY PROCEDURES REFERENCE SYSTEM ORISE will reference survey results using the reference system established by the licensee and/or Global Positioning System (GPS) coordinates and prominent site features. Measurement and sampling locations will be documented on detailed survey maps.

SURFACE SCANS Scans for gamma radiation will be performed within selected exterior FSS units as they become available. Judgmental scans may be performed if requested by the NRC. Scans will be performed using NaI scintillation detectors coupled to ratemeters with audible indicators. Detectors will be coupled to GPS systems that enable real-time gamma count rate and position data capture.

Locations of elevated direct gamma radiation will be marked for further investigation. Medium-to high-density surface scans shall be performed over 50-100% of the total surface area in each survey unit that is selected.

SOIL SAMPLING Surface soil and/or miscellaneous material samples will be collected from judgmental locations where elevated direct gamma radiation is detected above background. The number of samples will be determined as the survey progresses. Specific areas (e.g. the land area directly adjacent to the reactor building, specific roads, etc.) where there are no distinct indications of elevated radiation levels may be sampled at up to five judgmental locations based on factors such as migration pathways, low spots, or doorways.

SAMPLE ANALYSIS AND DATA INTERPRETATION All data collected onsite will be brought back to the ORISE facility for interpretation. Samples collected for radiological analysis will be delivered to the IEAV radiochemistry laboratory in Oak Ridge, Tennessee for analysis. Sample analyses will be performed in accordance with the ORISE Laboratory Procedures Manual (ORISE 2010). Soil and miscellaneous samples will be analyzed by gamma spectroscopy for gamma-emitting fission and activation products and results reported in units of picocuries per gram (pCi/g). Results will be presented in a report and provided to the NRC. Data collected as part of this survey will be archived by ORISE. All samples will be returned to the Fermi 1 site for disposal.

GUIDELINES The primary contaminants of concern for Fermi 1 are beta-gamma emittersfission and activation productsresulting from reactor operation. The building surface and soil Derived Concentration Guideline Levels (DCGLs) are listed below. The DCGL values will be used for FSS measurements

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 5

2018-PL-01-0 and samples to determine compliance with the 25 mrem/yr unrestricted use criterion. The average residual radioactivity above background must be less than or equal to the DCGL. For mixtures of radionuclides, the sum of the fractions of the contaminants concentration over the contaminants DCGLs must be less or equal to one (DTE 2010).

Radionuclide Building surfacea (dpm/100cm 2)

Soila (pCi/g)

Ag-108m 1.8E+04 7.8 Am-241 5.0E+03 130 C-14 1.0E+07 450 Cm-242 3.1 E+05 7,700 Cm-243 7.2E+03 78 Co-60 1.1 E+04 5.1 Cs-134 1.7E+04 8.3 Cs-137 3.9E+04 17 Eu-152 2.2E+04 11 Eu-154 2.0E+04 11 Eu-155 3.6E+05 400 Fe-55 4.1E+07 34,000 H-3 2.9E+08 31,000 Na-22 1.3E+04 6.2 Nb-94 1.5E+04 7.9 Ni-59 6.0E+05 11,000 Ni-63 3.6E+07 4,000 Pu-238 5.7E+03 160 Pu-239 5.0E+03 140 Pu-240 5.0E+03 140 Pu-241 2.7E+05 5,200 Sb-125 5.9E+04 34 Sr-90 1.4E+05 12 Tc-99 1.4E+07 120 aDCGL values correspond to an annual dose of 25 mrem.

IN-PROCESS INSPECTION PROCEDURES The following in-process inspection plan shall be used to evaluate the ongoing remediation and FSS activities of the Fermi 1 Decommissioning Project. The purpose of these evaluations is to ensure that the commitments contained in any FSS Plans and/or Work Packages are adequately implemented in the field.

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 6

2018-PL-01-0 The following plan should be used as a checklist. The major elements of this site-specific inspection plan include the following seven areas. However, only the inspection items deemed necessary by the NRC will be conducted.

General Identification of contaminants and remediation levels Soil unit classification Final status survey procedural implementation Analytical procedures and comparison activities In-process audit of radiological survey technicians Quality Assurance (QA)/Quality Control (QC) and data management procedures A detailed description of each area to be evaluated is described below:

1.0 General 1.1 Review past records of spills or other releases of radioactive materials and chemical contaminants and documentation of cleanup.

1.2 Tour site areas to obtain familiarity with the site, surrounding areas, and remediation work completed. Review the contractors plans and schedule for completing further remediation work and surveying of site areas.

2.0 Identification of Contaminants and Remediation Levels 2.1 Review previous measurement and analytical results to confirm the nature of the contaminants within the subject areas at the site.

2.2 Review the Radiological Levels (RLs) that the contractor will use to assure consistency with the requirements of the DCGLs.

2.3 Evaluate how the RLs will be mete.g., use of surrogate measurements and modified RLs, comparison of results with Maximum RLs, and implementation of the unity rule (as applicable).

3.0 SU Classification 3.1 Based on site tours and review of characterization and other survey/sample results, evaluate the contractors technical basis for the classification of the selected surveys units (Class 1, Class 2, or Class 3).

3.2 Review the available information and data used for initially classifying the Survey Unit (SU).

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 7

2018-PL-01-0 4.0 Final Status Survey Procedural Implementation 4.1 Field Survey Instrumentation 4.1.1 Review the calibration and performance check procedures. Ensure calibrations will account for any environmental or other factors that could potentially impact performance. Evaluate the appropriateness of the calibration source energies in determining instrument efficiencies and any applied weighting factors relative to the radionuclides of concern. Review the survey instrumentation operational checkout procedures and acceptance parameters.

4.1.2 Review the field Minimum Detectable Activity (MDA) calculations.

4.1.3 Review the procedures for field use of instrumentation and evaluate that any a priori factors that may impact use in the field have been accounted for, such as scan speed and background variability. Review training records of personnel who will operate survey instrumentation.

4.2 SU Design Review Review the SU design for the following:

4.2.1 Verify the adequacy of reference areas selected by the contractor for assessing background contributions to soil contaminant concentrations and other volumetric media (if applicable).

4.2.2 Review procedures for establishing SU boundaries. Review maps showing preliminary SU designations.

4.2.3 Review the determination of the required number of samples.

4.2.4 Review the required scan coverage based on SU classification.

4.2.5 Review methods for evaluating areas of elevated contamination/activity detected during scans.

4.2.6 Review proposed action levels and adequacy relative to the required and actual scan Minimum Detectable Concentrations (MDCs).

4.2.7 Review selection process for sample locations in the SU.

4.2.8 Review proposed procedures and any associated factors for sampling subsurface soils and other difficult to access or inaccessible areas.

4.2.9 Review sampling and chain-of-custody procedures.

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 8

2018-PL-01-0 5.0 Analytical Procedures and Comparison Activities 5.1 Review the laboratory instrumentation and analytical methods that will be used for radiological sample analysis, and assess the adequacy of the laboratorys quality assurance program when deemed appropriate. Determine appropriateness and sensitivity of the selected equipment for the contaminants of concern.

5.2 Review the sample collection, packaging, chain-of-custody, and shipping documentation.

5.3 Select a limited number of samples analyzed by the contractor for reanalysis at the ORISE laboratory (for radiological contaminants) for the purpose of interlaboratory comparison of results.

6.0 In-Process Audit of Radiological Survey Technicians Review radiological survey technicians implementation of their respective procedures. Specifically:

6.1 Understanding of the concepts of their survey/sampling procedures and associated documents and procedures as outlined in their training manuals.

6.2 Adherence to the specifications of the survey instructions generated by the contractor.

6.3 Performance of surface scans for radiological Contaminants of Concern (COC)evaluate the procedures/protocols for identifying areas of elevated radiation levels for investigation. Compare the procedures/protocols for adequacy relative to the a priori scan MDC determination.

7.0 QA/QC and Data Management Procedures Review the QA/QC and data management processes against the requirements of the respective procedures. Specifically:

7.1 Assure adherence to the personnel training requirements and data acceptance criteria.

7.2 Review the use of the contractors data management system that will be used to track field and analytical results.

INDEPENDENT CONFIRMATORY SURVEY PROJECT-SPECIFIC PLAN FOR THE DECOMMISSIONING OF THE ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 9

2018-PL-01-0 REFERENCES Detroit Edison Energy (DTE). Enrico Fermi Atomic Power Plant, Unit 1 License Termination Plan, Revision

2. Newport, MI; March 23, 2010.

Oak Ridge Associated Universities (ORAU). Quality Program Manual for the Independent Environmental Assessment and Verification Program. Oak Ridge, TN; June 30, 2009.

Oak Ridge Institute for Science and Education (ORISE). Radiation Protection Manual. Oak Ridge, TN; September 2005.

Oak Ridge Institute for Science and Education (ORISE). Survey Procedures Manual for the Independent Environmental Assessment and Verification Program. Oak Ridge, TN; May 1, 2008.

Oak Ridge Institute for Science and Education (ORISE). Laboratory Procedures Manual for the Independent Environmental Assessment and Verification Program. Oak Ridge, TN; May 28, 2010.

U.S. Nuclear Regulatory Commission (NRC). Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), NUREG-1575; Revision 1. Washington, DC; August 2000.