IR 05000341/1994017

Insp Rept 50-341/94-17 on 941128-1202.No Violations Noted. Major Areas Inspected:Mgt Organization,Solid Radwaste & Implementation of Revised 10CFR20

ML20149J340
Person / Time
Site:	Fermi
Issue date:	12/23/1994
From:	Hague R, Mccormickbarge, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149J322	List: IR 05000341/1994017 ML20149J319
References
50-341-94-17, NUDOCS 9501050141
Download: ML20149J340 (6)

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U.S. NUCLEAR P.EGULATORY COMISSION l l

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REGION III i l

Report No. 50-341/94017(DRSS)

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

. Licensee: Detroit Edison Company 6400 North Dixie Highway Newport, MI_ 48166 Facility Name: Fermi Nuclear Power Plant, Unit 2 l

Inspection At: Fermi Site, Newport, Michigan l U

Inspection Conducted: November 28 - December 2, 1994  ;

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Inspector:

R. L. Hague 2h m /

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Inspector: c Rr Paul V

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Approved By: h /I Naw /.1/M/4t/

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p.W.McCormick-Barger, Chief Radiological Programs Section 4 Inspection Summary Insoection on November 28 - December 2. 1994 (Recort No. 50-341/94017(DRSS))

Areas Inspected: Routine radiation protection inspection (inspection procedures (IP) 83750, 86750, and TI 2515/123) including management organization, solid radioactive waste, and implementation of the revised 10 CFR Part 20. Also reviewed were the licensee's investigations into two potential willful wrongdoing incidents and corrective actions from previous inspection finding Results: No violations or deviations were identified. One unresolved item was identified in paragraph 6 concerning a potential willful violation of radiation protection procedures. Overall, the radiation protection program

continues to be well run by competent individual .

9501050141 941223 PDR ADOCK 05000341 G PDR

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DETAILS Persons Contacted

• P. Fessler, Plant Manager

• R. Delong, Superintendent Rad / Chem

• E. Kokosky, Radiation Protection Manager l * S. Bartman, General Supervisor, Chemistry

• D. Pettinari, General Supervisor, Radwaste

• J. Conen, Supervisor Compliance

• J. Pendergast, Compliance Engineer L. Craine, Supervisor, Rad. Health Engineering G. Macadam, Supervisor, Operational ALARA D. Craine, Acting Supervisor, Rad. Engineering K. Riemer, NRC Resident Inspector

• The above personnel were present at the exit meeting on December 2, 199 The inspector also interviewed other licensee and contractor personnel.

l l Licensee Action on Previous Insoection Findinas (Closed) Inspection Followuo Item (IFI) 50-341/92020-01: The licensee generated Deviation Event Report (DER) #92-0711 to follow corrective actions for a finding of deficiencies in housekeeping and tool control in the drywell during RF03. The licensee created a new position of Drywell Coordinator for RF04. Among'the duties of this new position was l having responsibility for drywell housekeeping and tool control. Tours c

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by NRC inspectors and a closecut audit for this DER by the licensee {

indicated that corrective actions were effective. This item is close j

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(Closed) IFI 50-341/93026-01: Effect of using Tc-99 calibration source l with nickel versus stainless steel backing. The licensee determined l

that although the nickel backing caused a higher count rate per unit activity on beta scintillators, the errors introduced were well within ,

the 20% tolerance allowed in the calibration procedure. This item is 1 close (Closed) IFI 50-341/94007-04: Contract radiation protection technician (RPT) falsified high radiation door lock checks. The licensee's

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investigation into a log discrepancy on two consecutive days concerning the status of locked high radiation area doors disclosed that a contract ,

RPT had incorrectly logged that the on-site storage facility (OSSF) bay-3 door was locked and posted as a high radiation area when in fact it had been de-posted and unlocked. When confronted with the discrepancy the contract RPT admitted that he had not actually verified the status of the door. Although a falsification of documentation occurred, there were no adverse radiological consequences because the purpose of the door checks was to ensure that areas required to be posted and locked

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were posted and locked; in this case, door OSSF bay-3 was de-posted and unlocked. The licensee terminated the individual's employment and reviewed other work accomplished by this individual and found no other discrepancies. This item is close No violations or deviations were identified.

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3. Manaaement Oraanization (IP 83750)

{ The inspectors reviewed the management organization of the radiation j protection progra Since the previous inspection (Inspection Report No. 50-341/93026 i (DRSS)), the most significant change was that the Rad Engineering ,

Supervisor, responsible for ALARA and other engineering functions j

transferred to the Operations Department. The licensee is currently

interviewing candidates for that position and in the interim had an

experienced as low as reasonably achievable (ALARA) engineer acting in i that role. Also, during that inspection, the inspector expressed 1 concern about whether or not the increased responsibilities and workload i of the Superintendent of the Radiation Protection Department would adversely affect radiological performance. This matter was reviewed i during this inspection and it did not appear that the effectiveness of

the radiation protection / chemistry /radwaste programs had been degraded i as result of the Superintendent's larger management role.

l No violations or deviations were identified.-

1 , l 4. Imolementation of the Revised 10 CFR Part 20 (TI 2515/123)

1 The inspectors reviewed the licensee's implementation of the revised 10

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CFR Part 20 regulations to ensure the establishment of effective programmatic controls with respect to high and very high radiation areas i (HRAs and VHRAs), declared pregnant worker (DPW) and dose to

! embryo / fetus, planned special exposures (PSEs), and maintaining total effective dose equivalent (TEDE) ALARA. The licensee implemented the !

., revised Part 20 in October, 199 l

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Control of HRAs and VHRAs l The inspectors reviewed the lesson plans and interviewed both RPTs ,

and other plant staff and verified they had adequate knowledge of

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j i the training material. The licensee's written procedures were j based on the guidance of Regulatory Guide 8.38, " Control of Access j to High and Very High Radiation Areas in Nuclear Power Plants."

l All procedures were in place and appropriate training was j completed prior to October 199 .

The licensee had identified two areas at the plant which were l controlled as very high radiation areas under certain conditions.

One was access to the drywell during power operation and the other i was the traversing incore probe room with the probes retracte ,

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L Access to these areas was controlled by the use of unique locks-requiring authorization of the Radiation Protection Manager for release of the keys which were kept in a lock box separate from 1 other high radiation area key The inspectors reviewed the administrative, refueling, and health physics procedures covering transient and potential high or very l high radiation areas. These procedures appeared to be adequate to prevent the inadvertent or undetected creation of such an are Declared Preanant Worker (DPW) and Dose to rmhrvo/ Fetus l The licensee's DPW procedures included a method to equalize dose over the gestation period under the control of the DPW's ,

supervisor and the Health Physics Manager, j I

The inspectors interviewed four women to ascertain what training they had received with regard to the revised Part 20, their rights i to declare and undeclare pregnancy, and the lower limits imposed

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for the embryo / fetus. All four remembered receiving the training and that it was their right to declare pregnancy voluntarily by notifying their supervisor. Knowledge of other specifics of the training varied among the four wome Planned Special Exoosures (PSEs)

The licensee's procedure for approval of PSEs paraphrased 10 CFR !

20.1206 and designated the Senior Vice President Nuclear as the l approving official. There were no PSEs authorized to date and the licensee did not foresee the need to utilize this procedure in the futur Maintainina Total Effective Dose Eauivalent ALARA  ;

During this refueling outage (RF04), the licensee took steps to reduce the TEDE by considerable use of engineering controls which allowed less use of respirators. As part of the TEDE evaluation, the licensee used historical and current air sample data (lapel and area) for similar work. The inspectors reviewed the licensee's air sample and analysis program, procedures, methodology to determine assigned derived air concentration hours (DAC-Hrs), and dose. It appeared the licensee's TEDE/ALARA review and air sample and analysis programs were sufficient to meet the revised Part 20 changes. Also, no doses in ucess of 1% of an annual limit of intake (ALI) were identifie ;

l No violations or deviations were identifie ,

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5. As low As Reasonably Achievable (ALARA) (IP 83750)

l The only major change in the overall station ALARA management program since the previous inspection was the transfer of the Supervisor, Rad Engineering who acted as the stations ALARA' coordinator. The inspectors reviewed ALARA program performance and initiatives implemented during RF04 including job progress and pre-job ALARA reviews, radiological planning checklist, dose estimate work sheets, job history and lessons learned for the decontamination of the reactor cavity and dryer separator walls and floors, _the reactor vessel dryer / separator reassembly in the cavity, and the reactor water cleanup (RWCU) pump l work. It appeared planning and scheduling activities for work to be performed during RF04 was effective. RP and ALARA personnel were sufficiently aware of those jobs which could result in emergent work, those where work scope changes were made, and those where unanticipated dose rates or other unexpected changing radiological conditions occurred. The inspectors noted that about 11 person-rem (0.11 person-Sv) to date was expended on RWCU pump work, some of which was the result of considerable rework caused by problems that were somewhat repetitive in nature. This matter was discussed with the licensee who acknowledged they were aware of the problem, and stated that they intended to evaluate the matter furthe To date, the station dose was about 209 person-res (2.09 person-Sv)

including about 190 person-rem (1.9 person-SV) from RF04, about 23 person-rem (0.23 person-SV) frem turbine recovery and non RF04 forced outage work and about 11 person-rem (0.11 person-Sv) from reactor water clean up (RWCU) pump work. The licensee estimated the yearly station dose will be about 220 person-rem (2.2 person-Sv), and if accomplished, the stations average three year dose will be about 160 person-rem ( person-SV) which includes two refueling outages, maintenance work, and the turbine recovery work.

! The inspectors reviewed the licensee's investigation of a potential

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willful violation of radiation protection (RP) procedures involving a contractor employee who entered the drywell after RP supervision denied him access and without being on a radiation work permit for drywell i work. This is considered an unresolved item 50-341/94017-01(DRSS).

No violations or deviations were identifie . Plant Tours (IPs 83750 and 86750)

The inspectors toured the RCA and noted that housekeeping was good for outage conditions. Discussions with some workers and station management indicated they felt the station took an aggressive approach in implementing ALARA and that there was a general willingness to work with the RP group. Radiological postings were consistent with Part 20 requirements and protective clothing storage areas were in good condition. Workers wore appropriate dosimetry and good radiological practices were also noted during observations of work activitie _ _ _

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l No violations or deviations were identifie . Exit Interview l

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The scope and findings of the inspection were reviewed with licensee  !

representatives (section 1) at the conclusion of the inspection on  !

December 2, 1994. No violations or deviations were identified. The  !

licensee did not identify any documents as proprietar I I

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