ML102450371
| ML102450371 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/01/2010 |
| From: | Christine Lipa NRC/RGN-III/DNMS/DB |
| To: | Plona J Detroit Edison |
| References | |
| IR-10-009 | |
| Download: ML102450371 (11) | |
See also: IR 05000016/2010009
Text
September 1, 2010
Mr. Joseph Plona, Site Vice President
Nuclear Generation
The Detroit Edison Company
6400 North Dixie Highway
Newport, MI 48166
SUBJECT: NRC INSPECTION REPORT 050-00016/10-09(DNMS) - ENRICO
FERMI UNIT 1
Dear Mr. Plona:
On August 5, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
the Enrico Fermi Unit 1 facility. The purpose of the inspection was to determine whether
decommissioning activities were conducted safely and in accordance with NRC requirements.
At the conclusion of the inspection on August 5, 2010, the NRC inspector discussed the findings
with members of your staff.
The inspection consisted of an examination of activities at the facility as they relate to safety and
compliance with the Commissions rules and regulations. Areas examined during the inspection
included facility management and control, radiological safety and your implementation of the
Industry Ground Water Protection Voluntary Initiative. Within these areas, the inspection
consisted of a selective examination of procedures and representative records, field
observations of activities in progress, and interviews with personnel.
Based on the results of this inspection, the NRC did not identify any violations.
In accordance with Title 10 Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of
Practice," a copy of this letter and its enclosure will be available electronically for public
inspection in the NRC Public Document Room or from the NRC's Agencywide Document
Access and Management system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
J. Plona -2-
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
/RA/
Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Docket No. 050-00016
License No. DPR-9
Enclosure:
Inspection Report 050-00016/10-09(DNMS)
cc w/encl: L. Goodman, Manager, Fermi 1
W. Colonnello, Director, Nuclear Support
Michigan Department of Environmental Quality,
Waste and Hazardous Materials Division
K. Yale, Chief, State Liaison Officer, State of Michigan
Supervisor - Electric Operators,
Wayne County Emergency Management Division
cc w/encl: Distribution via ListServ
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No. 050-00016
License No. DPR-9
Report No. 050-00016/10-09(DNMS)
Licensee: Detroit Edison Company
Facility: Enrico Fermi Unit 1
Location: 6400 North Dixie Highway
Newport, MI 48166
Inspection Dates: June 10, 2010 (Ground Water
Protection Initiative)
August 4 and 5, 2010 (Decommissioning)
Inspector: Peter J. Lee, Ph.D., CHP, Health Physicist
Mark Mitchell, Health Physicist
Approved by: Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Division of Nuclear Materials Safety
Enclosure
EXECUTIVE SUMMARY
Enrico Fermi Unit 1
NRC Inspection Report 050-00016/10-09(DNMS)
This routine decommissioning inspection included reviews of facility management and control,
and radiological safety. A region-based inspector also completed an on-site review of the
implementation of the Industry Ground Water Protection Initiative.
Facility Management and Control
The inspector determined that the licensees safety evaluation of cutting the reactor
vessel was in compliance with the requirements of Title 10 Code of Federal Regulations
(CFR) Part 50.59 and the dose to the general public is bounded by the licensees final
safety analysis report, accident analyses of airborne release. (Section 1.1)
The inspector determined that the licensee maintained adequate staffing levels and
training to effectively continue the decommissioning process. (Section 1.2)
The inspector concluded that the conditions of the facility and equipment were adequate
and capable of supporting the decommissioning activities. (Section 1.3)
The inspector determined that the licensee adequately implemented the audits of
radiation protection in accordance with its Quality Assurance Program. (Section 1.4)
Radiological Safety
The inspector determined that the licensee continued to be effective in preventing the
spread of contamination and in maintaining dose to workers well below the regulatory
limits. (Section 2.1)
Industry Ground Water Protection Voluntary Initiative
The inspectors verified that the licensee implemented the Industry Ground Water
Protection Voluntary Initiative. No findings or violations were identified.
2 Enclosure
Report Details1
Summary of Plant Activities
During the inspection period, the licensee was performing decommissioning activities,
specifically cutting the upper section of reactor vessel and preparing for the removal of reactor
vessel segments.
1.0 Facility Management and Control
1.1 Safety Reviews, Design Changes, and Modifications (IP 37801)
a. Inspection Scope
The inspector reviewed the licensees safety evaluation of cutting the reactor vessel
(RV) to verify that the completed evaluation was consistent with the requirements of
b. Observations and Findings
The licensee conducted the safety evaluation of cutting the reactor vessel against the
final safety analysis report (FSAR). There are two possible sources of the radioactivity
that could transfer from the RV to the HEPA filter; one is the internal surface
contamination of the RV and the other is the activation products in the fine particles
generated during the cutting. The postulated accident that would potentially release the
contamination activity and fines activity entrained in a HEPA filter would be a fire that
occurs and engulfs the filter. The calculated dose is based on the conservative
assumption that 100% of the activity would become airborne. Based on the above
assumptions, the calculated dose to the general public is below the current FSAR
accident analyses of airborne release. Since most of the cutting wont generate airborne
or respirable activity, the actual dose should be much lower.
c. Conclusions
The inspector determined that the licensees safety evaluation of cutting the reactor
vessel was in compliance with the requirements of 10 CFR Part 50.59 and the dose to
the general public is bounded by FSAR accident analyses of airborne release.
1.2 Organization, Management and Cost Controls (36801)
a. Inspection Scope
The inspector evaluated the licensees decommissioning staffing to determine whether
the licensee maintained adequate staffing levels to effectively conduct its
decommissioning activities. The inspector reviewed records of the required training for
the licensee personnel and contractor workers.
¹A list of acronyms used and all documents reviewed in these Details are provided at the end of the report.
3 Enclosure
b. Observations and Findings
The licensee conducted training for licensee personnel and contractor workers in
accordance with the provisions of the licensees training program. The training included
topics such as radiation protection, sodium handling safety, asbestos awareness, and
confined space safety.
c. Conclusions
The inspector determined that the licensee maintained adequate staffing levels and
training to effectively continue the decommissioning process.
1.3 Decommissioning Performance and Status Review at Permanently Shut Down Reactors
a. Inspection Scope (71801)
The inspector toured the plant to assess the working conditions during the
decommissioning activities.
b. Observations and Findings
During the inspection, contract workers were cutting the upper section of the reactor
vessel and preparing for the removal of reactor vessel segments. Workers wore
appropriate protective equipment and followed established procedures. The licensee
maintained the work location with adequate shielding, personnel barriers, and high
efficiency particulate air (HEPA) filter exhaust systems, all to minimize worker doses. All
radiological areas were adequately marked and posted.
c. Conclusions
The inspector concluded that the conditions of the facility and equipment were adequate
and capable of supporting the decommissioning activities.
1.4 Self-Assessment, Auditing, and Corrective Action (40801)
a. Inspection Scope
The inspector reviewed the licensees audit of its radiation protection program
(Audit 09-0112) conducted from October 26, through November 13, 2009. Selected
corrective action work orders associated with identified deficiencies were also reviewed.
b. Observations and Findings
The audit of the radiation protection program (Audit 09-0112) was appropriately focused
in both scope and level of detail, and the licensee initiated appropriate corrective actions
to resolve the audit findings.
c. Conclusions
The inspector determined that the licensee adequately implemented the audits of
radiation protection in accordance with its Quality Assurance Program.
4 Enclosure
2.0 Radiological Safety
2.1 Occupational Radiation Exposure (83750)
a. Inspection Scope
The inspector interviewed licensee personnel and reviewed the work request and the as-
low-as-reasonably-achievable review (ALARA) review for the cutting up and the removal
of the reactor vessel segments to evaluate the effectiveness of licensee controls to
minimize the potential radiation exposure to the workers.
b. Observations and Findings
The ALARA review provided the administrative controls to minimize or avoid
unnecessary dose to the workers. The engineering controls such as enclosures with
additional HEPA ventilation and shielding were effectively controlling the workers
internal and external exposures, and the spread of contamination.
Most of the contamination generated during the cutting operation would not be expected
to become airborne. There may be some airborne contaminants but most of them are
irrespirable. Therefore, there is no internal radiation exposure concerns for the worker.
The cutting operation is done through remote control via camera. Also a telemetry
system is currently in use in the reactor area to remotely control the workers exposures.
Because of that, the workers external exposures will be significantly reduced to levels
that are ALARA.
c. Conclusions
The inspector determined that the licensee continued to be effective in preventing the
spread of contamination and in maintaining dose to workers well below the regulatory
limits.
3.0 (Closed) NRC Temporary Instruction 2515/173 Review of the Industry Groundwater
Protection Voluntary Initiative for Fermi Unit 1 (The Fermi 2 program review was
previously completed and is documented in IR No. 050-00341/10-02)
a. Inspection Scope
An NRC assessment was performed on the licensees implementation of the Nuclear
Energy Institute - Ground Water Protection Initiative (NEI-GPI) (dated August 2007
(ML072610036)), at the Fermi Power Plant. Under the voluntary initiative, each nuclear
plant site was to have developed an effective, technically sound groundwater protection
program that aligned with the NEI initiative by August 2008.
The inspectors assessed whether the licensee evaluated work practices that could lead
to leaks, spills, and performed an evaluation of systems, structures, and components,
that contain licensed radioactive material to determine potential leak or spill
mechanisms.
5 Enclosure
The inspectors determined whether the licensee completed a site characterization of
geology and hydrology to determine the predominant ground water gradients and
potential pathways for ground water migration from onsite locations to offsite locations.
The inspectors also determined whether an onsite ground water monitoring program had
been implemented to monitor potential licensed radioactive leakage into groundwater
and whether the licensee had provisions for reporting its ground water monitoring
results. (See http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-
info.html)
The inspectors reviewed the licensees procedures for the decision making process for
potential remediation of leaks and spills, including consideration of the long term
decommissioning impacts. The inspectors also determined whether records of leaks
and spills were being recorded in the licensees decommissioning files in accordance
with 10 CFR 50.75(g).
The inspectors reviewed the licensees notification protocols to determine whether they
were consistent with the Groundwater Protection Initiative. The inspectors assessed
whether the licensee identified the appropriate local and state officials and conducted
briefings on the licensees ground water protection initiative. The inspectors also
assessed whether protocols were established for notification of the applicable local and
state officials regarding detection of leaks and spills.
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspectors verified that the licensee implemented the Industry Ground Water
Protection Voluntary Initiative. No findings or violations were identified.
4.0 Exit Meetings
- The inspector presented the inspection results to members of the licensees staff
at the conclusion of the inspection on August 5, 2010. The licensee did not
identify any of the documents or processes reviewed by the inspector as
proprietary.
- The results of Temporary Instruction 2515/173 Review of the Industry
Groundwater Protection Voluntary Initiative inspection were discussed with the
Manager, Fermi I, Ms. L. Goodman, on June 10, 2010. The inspectors confirmed
that none of the potential report input discussed was considered proprietary.
Proprietary material received during the inspection was returned to the licensee.
ATTACHMENT: SUPPLEMENTAL INFORMATION
6 Enclosure
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
- L. Goodman, Manager, Fermi 1
W. Colonnello, Director, Nuclear Support, Fermi 1
- S. Stasek, Chairman, Review Committee, Fermi 1
- M. Erickson, License Termination Manager
- K. Lindsey, Radiation Protection Supervisor
D. Breiding, Reactor Project Manager
D. Swindle, Sodium Project Manager
- C. Aldridge-Nunn, Office Administration
- L. Davis, Office Specialist
- Present at the August 5, 2010, exit meeting.
LIST OF PROCEDURES USED
IP 37801: Safety Reviews, Design Changes, and Modifications
IP 83750: Occupational Radiation Exposure
IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down
Reactors
IP 36801: Organization, Management and Cost Controls
IP 40801: Self-Assessment, Auditing, and Corrective Action
TI 2515/173 Review of the Industry Ground Water Protection Voluntary Initiative
LIST OF ACRONYMS USED
ADAMS Agency Document and Management System
ALARA As Low as is Reasonably Achievable
CFR Code of Federal Regulations
DAC Derived Air Concentrations
DNMS Division of Nuclear Materials Safety
FSAR Final Safety Analysis Report
HEPA High Efficiency Particulate Air
IP Inspection Procedure
NRC Nuclear Regulatory Commission
TI Temporary Instruction
LICENSEE DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Attachment
4OA5 Other Activities
EF 1-04-017, Work Request for Ground Water Environmental Sampling; February 2004
EF 1-10-002, Work Request Procedure; Revision 113
06-0059, 2006 Annual Environmental Report; dated August 28, 2006
07-0048, 2007 Annual Environmental Report; dated August 27, 2007
ITEMS OPENED, CLOSED, AND DISCUSSED
None
2 Attachment
J. Plona -2-
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
/RA/
Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Docket No. 050-00016
License No. DPR-9
Enclosure:
Inspection Report 050-00016/10-09(DNMS)
cc w/encl: L. Goodman, Manager, Fermi 1
W. Colonnello, Director, Nuclear Support
Michigan Department of Environmental Quality,
Waste and Hazardous Materials Division
K. Yale, Chief, State Liaison Officer, State of Michigan
Supervisor - Electric Operators,
Wayne County Emergency Management Division
cc w/encl: Distribution via ListServ
DISTRIBUTION:
Susan Bagley S. Orth C. Ariano
RidsNrrDorlLpl3-1 P. Louden L. Linn
Resource R. Orlikowski DRPIII
RidsNrrPMFermi2 M. Morris DRSIII
Resource M. Mitchell P. Buckley
RidsNrrDirsIrib Resource J. Giessner T. Tomczak
B. Watson B. Dickson ROPreports Resource
T. Smith M. Phillips MCID
S. Reynolds J. Heck
A. Barker
- See previous concurrence
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