ML20247D451

Insp Rept 50-341/98-07 on 980406-09.Violations Noted.Major Areas Inspected:Plant Support

ML20247D451
Person / Time
Site:	Fermi
Issue date:	05/06/1998
From:	Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247D417	List: ML20247D410 ML20247D437 ML20247D451
References
50-341-98-07, 50-341-98-7, NUDOCS 9805150042
Download: ML20247D451 (13)

See also: IR 05000341/1998007

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lil

Docket No.: 50-341

i License No.: NPF-43

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Report No.: 50-341/98007(DRS)

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Licensee: Detroit Edison Company

Facility: Enrico Fermi, Unit 2

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Location: 6400 N. Dixie Hwy.

Newp6ft.MI 48166

Dates: April 6-9,1998

Inspector: R. Glinski, Radiation Specialist

Approved by

Gary L. Shear, Chief, Plant Support Branch 2

l Division of Reactor Safety

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9805150042 990506

PDR ADOCK 05000341

G PDR

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EXECUTIVE SUMMARY

Enrico Fermi, Unit 2

NRC inspection Report 50-341/98007

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This announced lespection included aspects of radiation protection (RP) performance regardina

the control of high radiation areas; radiological surveys, labels, and postings; hot spot tracking;

self-assessments and audits; and RP coverage of tasks to maintain radiation dose

l As-Low-As-is-Reasonably-Achievable (ALARA). Overall, the areas examined were v. ell

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managed and implemented. RP practices were observed to be appropriate. Howaver, one

violation and one Non-Cited Violation were identified.

e The program for control of access to high radiation and locked high radiation areas

(HRA/LHRA) was well implemented. All keys were controlled, issued, and accounted for

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appropriately by the RP staff. The locked doors were checked daily and RP staff

provided all the required controls for NRC inspector entries into HRA/LHRAs. No

materiel condition or housekeeping issues were !dentified in these areas (Section R1.1).

e The programs for radiological surveys, postings, and labeling were well implemented.

Controls of contamination, airborne radioactivity, radiation dose, radiation sources, and

radworker practices were effective. No radiological impediments, materiel condition, or

housekeeping issues were identified in any areas of the facility. One Non-Cited

Violation for the failure to place an access control gate at the entrance to a

contamir.ated radiation area was identified (Section R1.2).

• The low number and the remote location of hot spots throughout the facility indicated a

continuing strong ALARA emphasis. However, a number of hot spots which were either ,

de-posted over the past three years or which no longer existed were still listed in the hot  ;

spot database as open. Taken together with other documentation inconsistencies, the i

oversight of the hot spot database was weak (Section R13). j

e Two examples of a violation of Radiation Work Permit (RWP) requirements were  !

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identified. Both examples involved mechanical maintenance staff who did not comply

with basic RWP and RP requirements. Corrective actions included maintenance and

radiation protection supervisory staff conducting training sessions for the mechanical

maintenance department to address any misunderstandings of RP requirements

(Section R4.1).

• The RP program review met regulatory requirements, and effectively identified and

followed up issues to improve RP performance, in addition, station audits and the

Condition Assessment Resolution Document (CARD) process were utilized to identify

and resolve performance issues. The RP staff promptly addressed the issues and

implemented effective corrective actions (Section R7.1).

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Reoort Details

IV. Plant Suncort

R1 Status of Radiation Protection and Chemistry (RP&C) Controls

R1.1 Control of Access and Kevs to Hinh Radiation and Locked High Radiation Areas I

a. Insoection Scoce (IP 83750)

The inspector reviewed the applicable procedure, the high radiation key (HiRad key)

logbook, and interviewed radiation protection (RP) staff regarding the control of access

to high radiation (HRA) and locked high radiation (LHRA) areas. In addition, the

inspector conducted a walkdown of representative HRAs and LHRAs.

b. Observations and Findings

During general plant walkdowns conducted throughout this inspection, the inspector

noted that all HRA/LHRAs were locked. The HiRad keys were appropriately stored,

controlled, inventoried, and logged by RP staff. The inspector verified that the HiRad j

keys were accounted for as referenced by the key index. The HRAs were locked with a

door lock, while the LHRAs were controlled by having both a door lock and a dead-bolt

lock which required separate keys. The site maintained over 70 HRA/LHRAs that were i

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controlled by locks and a review of the daily door checks conducted by the RP staff

indicated excellent control of access to these areas. In addition, the inspector noted that i

the keys to the very high radiation areas were stored and controlled separately, in

accordance with procedure.

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The inspector signed-out HiRad keys and observed the following HRA/LHRAs: the

southwest turbine deck, the north entrance to the steam tunnel pipe chase, the south

turbine building steam tunnels, and the north reactor feedwater pump room. In

accordance with station procedure, the RP staff notified and received authorization for

these entries from the Nuclear Shift Supervisor, issued and sot rce checked the

arming dosimeters, and provided stay time tracking. The inspector exited these areas

without the need for a key and there were no means of preventing an individual from

easily leaving these areas, which was in accordance with both 10 CFR 70.1601(d) and

station procedure. The inspector did not identify any materiel condition or housekeeping

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c. Conclusions

The control of access to the HRA/LHRAs was excellent. All HiRad keys * are controlled,

issued, and accounted for appropriately by the RP staff. The locked doors were

l checked daily and RP staff provided all the required controls for entries into

j HRA/LHRAs. No materiel condition or housekeeping issues were identified.

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R1.2 Radioloalcal Survevs. Conditions, Practices. I mheling. and Postings.

a. Insoection Scone (IP 83750)

The inspector conducted several w' alkdowns of the reactor building, the turbine building,

the auxiliary building, the radwaste building, and the onsite storage facility (OSSF).

During these walkdowns, the inspector reviewed plant radiological posting and labeling,

control of contamination areas, RP job coverage of refuel floor activities, radiation

surveys, plant housekeeping, and materiel condition.

b. Observations and Findinas

The radiological surveys, postings, and labeling effectively informed plant workers of

radiological conditions and presented information in accordance with station procedure,

independent radiation surveys conducted by the inspector throughout the facility verified

that area postings and container labels were appropriate, with one exception. The

inspector identified contact dose rates of 40-45 milliroentgen per hour (mR/h) on one

radioactive inaterial (RAM) container in Bay 1 of the OSSF that was labeled as 15 mR/h

on contact and 4 mR/h at 30 centimeters. During discussions regarding radiation

surveys, RP supervision stated that staff was expected to identify and document the

highest dose rates on RAM container labels. The RP staff re-surveyed this container

and revised the label to read 40 mR/h on contact and 8 mR/h at 30 centimeters.

During a walkdown of the radwaste building, the inspector identified that the rope gate at

the entrance to the Hot Machine Shop posted area was not in place. The inspector

notified an RP technician (RPT), who stated that the gate should have been up. The

RPT immediately replaced the rope gate. The posting on this gate stated: " Caution,

Radiation Area, Contaminated Area, Specific RWP Required, Notify RP Prior to Entry".

The presence of other nearby radiological postings, radiation boundary rope, and a

step-off-pad constituted sufficient postings to meet NRC requirements.

The inspector then reviewed the survey map of the Hot Machine Shop and noted that

areas near the Plas-Blaster system and the vacuums were radiation areas, and

contamination levels ranged up to 20,000 disintegrations per minute per 100 square i

centimeters. Further, the inspector noted that this survey occurred approximately one j

hour prior to the identification of the downed gate. In procedure NPOP 67.000.100, j

" Posting and De-Posting of Radiological Hazards." step 6.3.1 required site staff to,

" Place signs and access controls at each entrance and do not obscure their visibility."

The RP staff concluded that a recently hired contract RPT failed to place the access

control with the sign (posted rope gate) after completing the radiological survey. This

j failure constitutes a violation of minor significance and is being treated as a Non-Cited

! Violation, consistent with Section IV of the NRC Enforcement Policy. The RP

management took prompt administrative corrective actions in accordance with the site

procedure.

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Contamination control practices wer3 effective and housekeeping remained excellent,

as catch basins were well secured, contaminated materials were appropriately wrapped,

and contaminated areas were kept to a minimum throughout the plant. Continuous air

monitors and air samplers were located throughout the facility. No radiological

impediments to plant operations were identified. The radioactive sources used routinely

by RP were stored in a cabinet located in the locked calibration facility. Use of these

RAM sources was well controlled by RP staff responsible for radiation detector

calibrations.

The inspector reviewed 1997 and 1998 radiation survey data and noted that these

surveys were comprehensive and were conducted at the appropriate locations and at

the required frequencies. In particular, the inspector noted that the " hot" tool crib

surveys were conducted weekly and these surveys effectively identified contaminated

tools that were either taken to the decontamination room or painted purple to designate

them as hot tools. Since the initiation of hydrogen water chemistry, survey frequencies

for affected areas within the plant were changed to maintain RP department dose

ALARA. The survey maps were located at the main access to the Radiologically

Restricted Area (RRA) and in notebooks located at readily accessible points throughout

the plant.

The inspector observed work associated with the cutting and packaging of RAM stored

in the spent fuel pool. These materia:s (control rod blades, low power radiation

monitors, and velocity limiters) were being prepared for disposal. Tri-Nuke filters used

to maintain water clarity for the spent fuel pool were also planned for shipment offsite.

The RP coverage of contractor activities was evident and radiological controls were

effective in controlling the radiological conditions. In addition, site staff devised a more

efficient means of cutting and packaging this RAM which will result in fewer shipments.

To date there were no personnel contaminations, no airborne radioactivity hazards, and

the collective dose was approximately 125 rem, which was reasonable for the work

accomplished.

c. Conclusions

The radiological survey, posting, and labeling procedures were effectively implemented.

Controls of contamination, airborne radioactivity, radiation dose, radiation sources, and

radworker practices were effective. The radiological surveys were comprehensive and

survey maps were informative. One Non-Cited Violation for the failure to place an

access control gate at the entrance to the contaminated radiation area in the Hot

Machine Shop was identified.

R1.3 The Hot Soot Trackina Proaram

a. Insoection Scooe (IP83750)

The inspector reviewad radiological data and the applicable procedure, conducted hot

spot walkdowns throughout the RRA, and interviewed RP staff regarding the tracking

and disposition of hot spots.

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b. Observations and Findinas

During a walkdown of various hot spots with the cognizant radiological engineer, the

inspector independently verified the dose rates listed on the hot spot postings. A

majority of the hot spots were generally located in overhead or high radiation areas, and

therefore, the hot spots had a minimal radworker dose impact. The radiation dose rates

for several hot spots in higher traffic areas had been significantly reduced by the

installation of permanent shielding. This shielding initiative indicated a continuing strong

, ALARA focus. Although RP has planned to flush out more of the existing hot spots, RP

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engineering has determined thct flushing of several hot spots would not be feasible.

The inspector determined that the hot spot evaluation used appropriate methodology.

Also during the walkdown, the inspector noted that two hot spots listed as open in the

licensee's database were no longer posted as such. Further review by the radiological

engineer revealed that these hot spots were de-posted in 1995 based on survey data.

The inspector discussed with RP staff whether these should have been removed from

the open hot spot database. The applicable procedure did not have a tirneliness

requirement for updating the database, and did not indicate the responsible RP staff for -

managing this database, in addition, a review of the hot spot database revealed

inconsistent data entry by the various RP staff. Subsequent to the inspection period,

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further radiation surveys revealed that four other posted hot spots no longer met the

procedural criteria and five other hot spots listed as open had b an de-posted sometime

in the past. The RP department initiated a Condition Assessment Resolution Document

(CARD) to address the weakness in the hot spot program database.

There are currently less than 25 hot spots in the plant which is a further indication of

excellent control of radiological conditions. The low number of hot spots, in conjunction

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with the RP evaluations of the dose impact of each hot spot and the installed shielding,

demonstrated that the hot spot program was part of a strong ALARA focus,

c. Conclusions

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The inspector concluded that the low number and the remote location of hot spots

throughout the facility indicated a continuing strong ALARA emphasis. However, a

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. number of hot spots which were either de-posted over the past three years or which no

longer existed remained in the hot spot database as open. Together with inconsistent

data entry, the inspector determined that oversight of the hot spot database was weak.

R4 Staff Knowledge and Performance in RP&C

R4.1 Violation of RWP Requirements by Mechanical Maintenance Staff

a. Insoection Scooe (IP 92904)

The inspector reviewed the circumstances surrounding a violation of RWP requirements

for work in the North Reactor Water Cleanup (RWCU) and the lube oil cooler rooms.

Interviews with RP and mechanical maintenance (MM) staff were also conductd.

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b. Observat!cns and Findings

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On the afternoon of January 20,1998, MM staff received work assignments, HiRad

keys, dosimetry, and a radiological briefing for their work in the north RWCU room.

Upon arrival at the room, one RPT was inside the RWCU room confirming dose rates

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and another RPT was outside the room performing the stay time tracking required for

l entry into HRA/LHRAs. After completion of the work, the MM staff left the room.

Later that evening, these MM workers returned to the RRA access desk before re-

entering the north RWCU room for anotherjob. At this time the MM staff signed out the

HiRad key, had RP staff re-zero their dosimetry, and stated that they were returning to

the north RWCU room. After dressing out, the workers went to the room and noted that I

there was no RPT present. The posting on the north RWCU door stated," Caution, I

Locked High Radiation Area, Specific RWP Required for Entry, Notify RP Prior to Entry";

and there is a phone located near the north RWCU door. However, two MM staff

entered the room and began the work without notifying RP and without the required stay

time tracking. A few minutes after the workers entered this room, the RP staff was

concerned that they had not received notification and an RPT was sent to the north

RWCU room. The RPT found the workers in the room and then escorted them to the

RRA access desk, where RP staff took prompt corrective actions. The MM worker's

electronic dosimetry read 3 and 10 millirem.

The RWP foc this work in the north RWCU room was the job specific RWP #98-1048.

Instruction 3.0 of RWP 98-1048 stated that, " Stay time tracking is required for entry to

locked high ra iiation areas". The failure to notify RP prior to entering a LHRA resulted

in MM staff entering the room without the required stay time tracking. This failure was

an example of a violation of Technical Specification 6.8.1 (VIO 50-341/98007-02a).

Interviews with these experienced MM workers indicated that although they were aware

of the need for stay time tracking, they were unaware that RP must be present to

accomplish this task. There was also a misunderstanding regarding the difference

betv'een an LHRA and an HRA that was locked. These workers further indicated that

they thought that their HiRad key sign out and other actions at the RRA access desk

were sufficient notification of RP for work in the north RWCU room. The MM

Superintendent and the RP General Superviscr have conducted training sessions to

address these misconceptions.

On March 30,1998, two MM staff were assigned to remove a lube oil valve

(N3000f048A) and then inspect the valve for blockage. The workers received a pre-job

briefing, at which time they were instructed to sign onto RWP #98-1016 and have RP

present to conduct a survey in conjunction with breaching the lube oil system. One of

the workers then went to the tagging center to obtain the Safety Tag Record. Rather

than proceed to the RRA access desk to sign onto the RWP and notify RP, this MM

worker went to the lube oil cooler room and removed the valve. While returning from the

job, the MM worker encountered his partner and realized that he had not signed onto

the RWP #98-1016 and that RP was not present for the system breach. This worker

then proceeded to the RRA access desk and informed RP of his actions.

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instruction 2 of RWP #98-1016 required that RP must be present for system breach. I

However, the MM worker did not notify RP of the system breach and removed the valve

without RP being present to conduct a survey. This failure to have RP present for a

system breach was another example of a violation of Technical Specification 6.8.1

(VIO 50-341/98007-02b). The RP staff immediately denied RRA access to this MM

worker and counseled the individual on RP requirements.

These findings are consistent with the recent audit of the radiation protection program

which identified inappropriate radworker performance as a concern (See Section R7.1).

c. Conclusion

Two examples of an RWP violation were identified, and both of the examples involved

experienced MM staff. Site supervisory staff conducted training sessions for the MM

department to address any misunderstandings regarding various RP requirements for

work in the RRA. The inspector determined that the licensee's immediate corrective

actions were appropriate.

R7 Quality Assurance in RP&C Activities

R7.1 RP&C Program Reviews and Self-Assessments

a. Insoection Scone (IP 83750)

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The inspector reviewed the 1997 RP&C program review and representative evaluations

of Condition Assessment Resolution Document (CARD) process. The inspector also

interviewed various plant personnel regarding the implementation of the RP program

and the CARD system. l

b. Observations and Findinas ,

The inspector verified that the licensee conducted the 1997 RP program review in

accordance with 10 CFR 20.1101(c). The review was based on information from ,

outside agencies, Nuclear Quality Assurance (NOA) audits, and a compilation of issues

identified by the CARD process. The NQA review of the RP program utilized highly

qualified technical experts from other nuclear facilities. The PP program review

concluded that the program elements effectively maintained radiological controls, but

that radworker performance was a concern. In addition, the RP review identified seven

areas for improvement which focused on improving radworker performance, tra!ning,

and communication. Notably, the 1997 RP review evaluated the corrective actions for

ten issues which had been identified in 1996 NQA audits and found that the corrective  ;

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actions had been effective, and no recurrences of the issues were found.

, The inspector reviewed CARD packages regarding a potential adverse trend in

l radworker performance and the radiological controls of work on the RWCU system. The

radworker performance CARD was initiated by NOA staff who noted, that for the first six

months of 1997, nine radworkers allowed their whole body counts to expire and there

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were several problems associated with the proper use of dosimetry. In January and

February of 1998, seven individuals were denied RRA access for failure to obtain the

annual whole body count or complete radworker requalification training. The RP

department addressed these personnel issues promptly in accordance with site

procedure.

The CARDS for the RWCU pump and seal work noted that the radiation dose expended

for the 1997 work was approximately 50% higher than the original estimates, and this

increased dose resulted from higher dose rates (due to depleted zinc injection) and

various problems during the pump rebuilds. To reduce dose for RWCU pump work, the

licensee fabricated a work table equipped with a ventilation hood and a drain (to ease

decontamination), installed a temporary shield wall in the Hot Machine Shop, and built

an impeller puller to minimize hand contact with the high dose rate impeller. The March

1998 RWCU pump rebuilding activities expended approximately 60% less dose than the

1997 evolutions. The implementation of these dose reduction measures from the CARD

orocess provides further evidence of the continuing strong ALARA focus.

c. Conclusions

The inspector determined that RP program review met regulatory requirements and

effectively identified and followed up issues to improve RP performance. In addition,

NQA audits and the CARD process were also utilized to identify and resolve

performance issues. The RP staff promptly addressed the issues and implemented

effective corrective actions.

R8 Miscellaneous RP&C issues

R8.1 (Closed) Unresolved item 50-341/97003-12: release of contaminated components from

the RRA. Through interviews with RP and MM staff, the inspector determined an RPT

had performed a thorough survey of the offgas valve prior to release from the RRA.

After the valve had been disassembled in the cold machine shop, an MM worker

properly questioned whether another survey was warranted since the valve internals

were now exposed. A subsequent survey identified low levels of contamination on valve

internals, but no contamination was found on MM staff or in the cold machine shop.

Further analyses demonstrated that the low level contamination was caused by a beta

emitter, which could not be identified until after valve disassembly. The inspector

determined that the initial and subsequent surveys, and the actions taken after the

contamination was detected, were appropriate for this task. This item is closed.

R8.1 (Discussed) insoection Follow uo item 50-341/97015-01: RWCU material condition

affecting pump disassembly and radworker radiation dose. Particular portions of the

latest RWCU pump rebuild work expended approximately 60% less than the 1997 pump

rebuild work. However, this recent RWCU task did involve a radiation dose of 1.4 r'.sn'

due to rework since the pump impeller would not turn after the initial rebuild. The rewt rk

was necessitated by galling problems with the bush sleeve, and difficulties with

installation of the pump gasket, alignment of the pump / motor, and flushing of'.ne pump

casing.

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The licensee has planned to revise the RWCU pump repair procedure and use mock-up

training to address these problems. In addition, the RWCU pump improvement team

has planned to modify the cooling lines to improve cooling performance and simplify

pump removal / installation, to improve the pump ring capacity, to use electroplated pump

casings and impellers, and evaluate the possibility of replacing the entire casing /

impeller / bearing assembly during pump rebuilds. Because the hcensee continues to

experience material condition and rework radiation dose problems with the RWCU

pumps, this issue remains open.

X1 Exit Meeting Summarv i

The inspector presented these results to licensee management and staff:Juring an exit

meeting on April 9,1998. The licensee representatives did not indicate that any

materials examined during the inspection should be considered proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

D. Craine, Radiological Engineer

i L. Crissman, General Superintendent - Radwaste

P. Fessler, Plant Manager

P. Gipson, Senior Vice President

D. Harmon, RP Supervisor / Operations ALARA

E. Kokosky, Superintendent and Radiation Protection Manager l

G. Macadam, General Supervisor, Radiation Protection Operations

J. Oetken, Radiological Engineer

D. Williams, Assistant Radiation Protection Manager

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G. Harris, Senior Resident inspector, Fermi 2

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INSPECTION PROCEDURES USED

IP 83750," Occupational Radiation Exposure"

IP 92904," Follow up - Plant Support" I

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened

50-341/98007-01 NCV Failure to place an access control gate at the entrance to the Hot

Machine Shop radiation / contamination area

50-341/98007-02 VIO Failure to comply with RWP requirements

Discussed

50-341/97015-01 IFl RWCU materiel condition affecting pump disassembly and

radworker radiation dose

Closed

50-341/98007-01 NCV Failure to place an access control gate at the entrance to the Hot

Machine Shop radiation / contamination area

50-341/97003-12 URI Release of contaminated components from the RRA

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LIST OF ACRONYMS USED

ALARA As-Low-As-is-Reasonably-Achievable

CARD Condition Assessment Resolution Document

HRA High Radiation Area

LHRA Lccked High Radiation Area

MM Mechanical Maintenance

m R/h Millirem per hour

NCV Non-Cited Violation

NQA Nuclear Quality Assurance

OSSF Onsite Storage Facility

RAM Radioactive Material

RP Radiation Protection

RP&C Radiation Protection & Chemistry

RPT Radiation Protection Technician

RRA Rr. biologically Restricted Area

RWCU Reactor Water Cleanup Unit

RWP Radiation Work Permit

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PARTIA1. LIST OF DOCUMENTS REVIEWED

Technical Specificaticas Section 6.8, " Procedures and Programs"

Radiation Protection Conduct Manual, MRP04, Revision 4, " Accessing and Working in the

Radiologically Restricted Area"

Radiation Protection Conduct Manual, MRP06, Revision 1," Accessing and Control of High

Radiation, Locked High Radiation, and Very High Radiation Areas"

Nuclear Production Operating Procedure (NPOP) 67.000.100, Revision 6, " Posting and De-

Posting of Radiological Hazards"

NPOP 67.000.100, Revision 11," Performing Surveys and Monitoring Work"

NPOP 63.000.100, Revision 9, " Radiation Work Permits"

NPOP 63.000.300, Revision 3, " Hot Spot Tracking and Removal"

NPRC-97-0475,"OSRO Action Item; Div I RHR Containment Spray Piping Radiation Build-up",

dated December 12,1997

Fermi 2 RPM System - Hot Spot Detail Reports

Nuclear Quality Assurance Audit 97-0126," Radiation Protection"

CARD 97-11810, " Potential Adverse Trend in Radiation Protection," dated November 24,1997

CARD 97-10291," Review of Radiological Controls for Rebuild of the South RWCU Pump Seal,"

dated October 9,1997

CARD 98-10063," Maintenance Workers Entered Locked High Radiation Area Without Meeting

RWP Requirements or Area Posting", dated January 21,1998

CARD 9811329," Removed Lube Oil Valve Without RP Present", dated March 31,1998

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