IR 05000341/1997009

RP Insp Rept 50-341/97-09 on 970602-06.No Violations Noted. Major Areas Inspected:Plant Support Performance Re Chemistry,Effluents & Environ Monitoring

ML20141E958
Person / Time
Site:	Fermi
Issue date:	06/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141E955	List: IR 05000341/1997009 ML20141E951
References
50-341-97-09, 50-341-97-9, NUDOCS 9707010246
Download: ML20141E958 (18)

Text

-. - -- . .- ... - -. ._ . . . -

. . - _ . . . . . . . - . - - -

-

.

i

.

-

U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

,

. Docket No: 50-341

,

License No: NPF-43 s

'

Report No: 50-341/97009(DRS)

Licensee: Detroit Edison Company (DECO)

]

d l Facility: Enrico Fermi, Unit 2

Location

6400 N. Dixie Hwy.

Newport, MI 48166

i Dates: June 2-6,1997 i

~

Inspectors: R. Glinski, Radiation Specialist G. West, Radiation Specialist i

'

Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

O l 9707010246 970626 PDR ADOCK 05000341 G PDR ,

__

.-

.

.

EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC inspection Report 50-341/97009 This announced inspection included aspects of the licensee's plant support performance regarding chemistry, effl' ents, and environmental monitoring. The report covers a one-week inspection concluded on June 6,1997, conducted by two radiation specialist Overall, the chemistry, effluents, radiation monitor, and environmental monitoring programs were well implemented, however the Post-Accident Sampling System has displayed inconsistent operability.

. e Radiological Environmental Monitoring Program data indicated that the plant j has had no radiological impact on it's environs. (Section R1.1)

,

.

e The gaseous effluents program was implemented in accordance with the

, Offsite Dose Calculation Manual, and dose assessment calculations were accurate and well below regulatory limits. (Section R1.2)

e The continual water quality improvements have resulted in excellent reactor

'

water quality. (Section R1.3)

i e The calibration program for the area and process radiation monitors was l effective and the performance history of these systems has remained

excellent. (Section R2.1)

j e The Post-Accident Sampling System operability continued to be unreliable, as staff have encountered communication, procedural, and material condition

'

,

problems which have precluded the PASS from functioning as designed in a j consistent manner. (Section R2.2)

i 1 e Chemistry in-line and laboratory instruments were properly calibrated and

maintained, and the laboratory was clean and well organized. (Section R2.3)

. e The training snd qualification program for chemistry personnel was i organized, well-managed, and effective; a chemistry technician demonstrated good sampling and analytical techniques during routine reactor water and offgas sample collection and analysis. (Sections R4.1 and R5.1)

e Audits and self-assessments were comprehensive, performance-based, and identified areas for improvement. (Section R7.1)

.- . _ . . -_ _- . --- . - -.

.

,

IV. Plant Support Report Details I

R1 Status of Radiation Protection and Chemistry (RP&C) Controls R 1.1 Implementation of the Radioloaical Environmental Monitorina Proaram (REMP) Inspection Scope (84750)

e The inspectors reviewed the 1996 Annual Radiological Monitoring Reports for Fermi 1 and Fermi 2, the REMP sampling procedure, and representative environmental data for 1997. The inspectors also observed air sampling, water sampling equipment, and interviewed radiation protection (RP) staff regarding REMP perforrnance.

. Observations and Findinas The inspectors observed that the air collection technique ensured sample integrity, and that samples were appropriately labeled and packaged for shipment. Review of a completed air collection sheet revealed that staff correctly calculated total air volume. Collection staff also verified that there were no air leaks within the sampling apparatus which would invalidate the volume data.

1 Although the material condition of the air samplers was adequate, several malfunuions occurred in 1996, which caused the REMP staff to designats these air samples as less than representative. The st6 tion has procured and tested new air sampling equipment with digital readout of sampling parameters (such as total air

volume) and the procedure for use was recently approved. However, the inspectors

observed that these samplers had already exceeded the manufacturer's original calibration. Plant staff stated that the new samplers would be calibrated and in the field by July 199 The REMP program involved the collection and analysis of air, water (surface, drinking, and ground), milk, vegetation, fish, and sediment. The sampling, analyses, and reporting were conducted in accordance with the Offsite Dose Calculation Manual (ODCM) and the RP Conduct Manual. All deviations and

, adjustments to the program were noted in the 1996 annual report. Both 1996 and

, 1997 data for both units indicated that there was no radiological impact to the i environment from plant operations, however the inspectors noted some minor

] inconsistencies within the 1996 Fermi 2 annual report. The vendor laboratory

detected cobalt-60 on one indicator air sample in the second quarter of 1996. In accordance with procedure, the REMP staff conducted an investigation. Based on further laboratory analysis, effluent data, meteorological data, and effluent

calculations, the REMP staff concluded that the presence of cobalt-60 on the air filter was not due to airborne effluents from the plant. The inspectors reviewed the

,

investigation and determined that the methodology used was appropriat i

,

_.___.___- _ . _ _ _. _ . _ _ . . . _ _ . . __ _ __._ _ _ _ _ _ _ . .

.

,

,

,

i i

l Surface and drinking water samples were collected by electronically controlled l

,

'

composite samplers which sampled the water at regular intervals each month. No material condition problems werc identified. The inspectors noted that the sampling

.

procedure did not provide any guidance for the collection of water grab sample REMP staff indicated that the preferred method was to sample from the spigot j mounted on the water composite sampling line, but that a dip sampler or portable

!

'

pump could also be used. The inspect (rs discussed with plant personnel that the lack of guidance could potentially result in collection staff using unapproved j sampling techniques. In addition, the sediment sampling procedure only listed the use of a Ponar Dredge as sampling equipment, although staff stated that shovels,

scoops, and vacuums were also utilized for this purpose. RP supervisory staff ]

j stated that the REMP sampling procedure was currently under revision, and that l j these proceduralissues would be reviewed.

i f Conclusions

! Overall, the REMP was wellimplemented and the data indicated that the plant has

, not had a radiologicalimpact on the surrounding environmen R1.2 Imolementation of the Effluents Proaram I

!

, Insoection Scoos (84750)

!

The inspectors reviewed effluent procedures, effluent data, the ODCM, and the l

1 1996 Annual Rsdioactive Effluent Release Report. The inspectors also interviewed

staff regarding the calculation process for determining the dose consequenca to members of the public and conducted a' comparative dose calculatio Observations and Findinas The inspectors observed sample effluent collection and reviewed the methodology for determining the concentrations and radioactivity content of the gaseous effluents. The RP staff utilized System Particulate lodine Noble Gas (SPING)

~

monitors located at the various effluent points (reactor building vent, offgas vent pipe, etc.) to obtain the samples and radiation data for offsite dose assessmen The noble gases present in the effluent and their corresponding concentrations were determined by gamma spectrometry analysis of grab samples. The RP staff recorded the noble gas monitor reading at the time the grab sample was collected, compared this reading to the average noble gas monitor reading for the previous month, and calculated the noble gas content by correcting for the differenc Gaseous particulates and iodines were determined by gamma spectrometry analysis of the weekly air filter and charcoal cartridge composite samples collected by the SPING monitors. For the total gaseous effluent volume determination, the volume flow rate was assumed to be the madmum rate achievable with all fans in operation. Although the licensee has not conducted a surveillance to verify the actual flow rate of the reactor building exhaust vent flow, the use of the maximum achievable flow rate is a conservative approach. Also, the measurement of the

-- - .-.- --. .- -

_ _ . ._ _ _ _ _ ._ _ __. . .

!

turbine building exhaust vent flow after a recent modification demonstrated only a t slight change from the original flow. The RP staff also collected weekly samples for tritium (all results were below the lower limit of detection) and analysis for particulate strontium 89 and 90 were conducted on quarterly composites of the SPING air filters. The gaseous radionuclide concentrations were well below the 10 CFR 20, Appendix B, Table 1, Column 2 limits.

.

The inspectors noted that calculations for dose consequence to members of the

, public were conducted in accordance with the methodology described in the

~

ODCM. RP staff utilized a recently developed spreadsheet program for the dose assessment. The inspectors reviewed an RP validation of this spreadsheet and verified that the new spreadsheet calculations were nearly identical to the previous spreadsheet and hand calculations.

The inspectors obtained monthly effluent data from plant personnel and performed

, a comparison of the licensee's dose calculation to the NRC's PC Dose program, and the results are presented below; Noble Gas Dose Rate at the Site Boundarv

,

Beta Air Dose Gamma Air Dose

i NRC Value 2.03E-3 mrad 9.99E 4 mrad (

Fermi Value 2.03E-3 mrad 1.00E-3 mrad Particulates/lodines to the Critical Receptor i

~

NRC Value 7.34E-5 mrad Fermi Value 5.79E-5 mrad

"

These comparative results were within the NRC procedural acceptance criteria. In addition, these dose assessments are well below the 10 CFR 50, Appendix I limit As program improvements, effluents staff have procured a Global Positioning System to determine the distance from effluent release points to offsite receptors, and they have pursued an alternate method for collection of tritium samples to achieve a lower detection limit.

As a matter of site practice, the licensee has not released radioactive liquid effluents to any unrestricted area since May 1994, and the inspectors noted that plant personnel reviewed the decant line effluent monitor daily to ensure adherence to this practice.

.

,

._ _ __ .-_ __ . _ _ . . _ _ _ _ _ _ . _ _ _ . _ . . . _ _ _ _

'l

!-

i Conclusions

! The gaseous effluents program was implemented in accordance with the ODCM and site procedures. Dose assessment calculations were accurate and well below regulatory limit R1.3 Chemistry Control of Reactor Water Quality insoection Scone (84750)

.

The inspectors reviewed laboratory analyses and trend charts of reactor water

! quality, which included information on chloride and sulfate concentrations, I

conductivity, and pH. The inspectors also examined the results of recent chemistry

,

surveillances required by Technical Specifications, and observed the operability and condition of the continuous reactor coolant conductivity monitor / recorders.

. Observations and Findinas

.

j

'

The inspectors noted that reactor water quality remained well within Electric Power Research Institute guidelines and station requirements. Technical Specifications j required chemistry surveillances were performed in a timely and acceptable manner.

i The continuous reactor coolant conductivity monitors and recorders were operable l and had only been inoperable once in the last year for maintenance. During this g

brief out of service period (approximately eight hours), the required compensatory i sampling was performed satisfactorily. The inspectors reviewed weekly channel

! checks of these conductivity monitors for the previous three months and no I problems were identifie '

Interviews with personnel and review of reactor water quality data indicated that the licensee remains focused on constant water quality improvement. For example, the staff have pursued severalinputs of chemical contamination in the primary system aggressively and effectivel Conclusions The implementation of reactor coolant analyses and continual water quality improvement has resulted in excellent reactor water qualit R2 Status of RP&C Facilities and Equipment R2.1 Calibration of Area and Process Radiation Monitorina Systems Insoection Scoos (83750)

The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR),

calibration records, and quality control activities for the area radiation monitoring system (ARMS) and the process radiation monitoring system (PRMS). The inspectors also interviewed personnel primarily responsible for calibrations and

, . _ - - - . - - . - - - - . . . - . .. . . - - - . . - . . - - -. . - . . _ _ _ _ _ _ _ _ _ _

'

I a

.

, observed representative radiation monitors and the monitor readouts in the control

room and relay room.

i

, Observations and Findinas The inspectors observed that the types, quantities, and locations of the ARMS and l PRMS detectors, as well as the continuous recording equipment in the control and

, relay rooms, were consistent with the UFSAR description. Records and interviews

'

demonstrated that operability problems were infrequent, and the inspectors did not observe any material condition concerns with either system.

l

Calibrations were conducted in accordance with station procedures. A review of calibration records for representative detectors in each system demonstrated; (1)

j that the calibrations of the ARMS and the PRMS were conducted at the appropriate i 18 month intervals, (2) that the RP staff performed two point calibrations - with the  ;

two points in separais decades, (3) that plant staff enscred that datector response i was within 20% of the primary calibration that was conducted in 1984, and (4)

j that the monitor indication at the local, relay room, and control room were within

!

the 20% acceptance criteria. The inspectors noted that adjustments of detector

'

response were properly conducted when necessary.

Conclusions The calibration program for the ARMS and PRMS detection instrumentation was i effectively implemented. The performance history of the systems indicated that the

overall operability has remained excellen R2.2 inconsistent Ooerability of the Post-Accident Samolina System (PASSl l Insoection Scone (847501 The inspectors interviewed staff, and reviewed chemistry data and the UFSAR regarding PASS operability testing. The inspector also reviewed the PASS procedure and observed the PASS station, control panel, and sampling cask Observations and Findinas The inspectors noted that, as specified in the UFSAR, the PASS station was capable of collecting reactor coolant and containment atmosphere gas samples, and operability testing was conducted semi-annually. All of the samples that have been collected and analyzed were within the Chemistry Specifications acceptance criteria, indicating that the PASS delivered representative samples. However, a review of the semi-annual operability testing showed that the PASS performance was inconsistent. The following list describes recent PASS problems:

e in October 1995, chemistry staff were unable to obtain a containment atmosphere sample due to pressure indication problems, and this pressure indicator was later replaced;

.

e in May 1996, a leaking' septum on the sample vial invalidated the containment atmosphere sample, plant personnel then collected another gas sample for analysis; e In July 1996, during the biennial emergency exercise, the PASS team was unable to obtain a reactor water sample due to a control room operator's failure to recognize and communicate that the PASS had been manually isolated (due to previous valve stroke problems encountered in May 1996)

and required a manual valve manipulation prior to operation; e in August 1996, chemistry staff were unable to collect a reactor coolant sample due to pressure indicator problems which were later corrected; e In May 1997, plant personriel were unable to obtain a reactor coolant sample due to a misalignment of the sample bottle and the resultant loss of the " Bottle In" indication on the control panel. Further examination revealed i that during system line ups conducted after the initial positioning of the sample bottle, the bottle shifted slightly which deactivated the microswitch indicating proper bottle position. Chemistry staff revised the procedure to include a step to verify " Bottle In" indication on the sample panel just prior ;

to sample collection, and staff then successfully collected and analyzed liquid and gas samples;

)

e in June 1997, during a valve operability test, two valves (P34F401B and 402B) did not indicate a change of position; further testing showed that the relays functioned properly, but the valves again did not indicato proper i operatio Section 11.4.4.4.4 of the UFSAR states that operability of the PASS is ,

demonstrated by obtaining the liquid and gas samples during the semi-annual l testing. However, due to various types of problems, the licensee has not I demonstrated consistent operability of the PASS. The inspectors discussed the

'

PASS problems with chemistry, engineering, and maintenance personnel. These individuals stated that vendor representatives had recently reviewed the PASS and were in the process of proposing a modification which would address severalissues which needed improvement. Due to continuing problems and the plans for a significant modification, the PASS Inspection Followup item (IFl 96006-10) will remain ope c. Conclusions The PASS operability continued to be unreliable. The staff have encountered communication, procedural, and material condition problems which have precluded the PASS from functioning as designed in a consistent manne _ __

-- - -- . . . - . .. ._. . - -- - - ._ - . . --

. .

.

R2.3 Material Condition of Laboratory and in-line Chemistry Instruments

.

Inspection Scope (84750)

'

a.

-

The inspectors examined the material condition of both laboratory and in-line chemistry instruments and reviewed representative instrument calibrations and functional checks. Items observed included two gamma spectroscopy systems, various conductivity meters, ion and gas chromatographs, pH meters, an inductively coupled plasma spectrometer, and other miscellaneous instrumentation. The

"

inspectors also walked down chemistry sample panels in the plant, including the

, reactor coolant system (RCS) sample panel and the offgas sample station, Obse_rvations and Findinas in general, the chemistry laboratory, analytical instrumentation, and the in-line equipment were in good material condition. Calibrations and channel checks were performed at the required frequency and in accordance with applicable procedure This data indicated that the instruments remained stable and operational. In addition, the chemistry laboratory was kept clean and organize The inspectors identified one concern regarding sampling from the RCS sample panel. This area, which is a radiation area (dose rates average about 6 mrem /hr),

was quite cramped and lacked a horizontal surface on which a chemistry technician (CT) could place the sampling procedure for reference. This physical setup caused some difficulty for the CT during RCS sampling (see Section R4.1). The inspectors discussed this concern with chemistry supervision, who acknowledged the concern and indicated that the chemistry staff would review this issu l 1 Conclusions J Chemistry laboratory instruments and in-line instruments were maintained in good condition, and were properly calibrated and checke R4 Staff Knowledge and Performance in RP&C i

R4.1 Samplina and Analysis of Reactor Coolant and Offaas Inspection Scope (84750)

The inspectors observed a CT obtain offgas and RCS liquid samples and perform in-line conductivity measurements. The plant procedures used to perform these tasks were 73.714.01, " Plant Process Sampling, P33-P405A, Radwaste Building Sample Penel" and 78.000.09, "Offgas Sampling and Analysis". The inspectors also observed the CT transport these samples to the chemistry laboratory, perform various analyses of the samples, and record the analytical result .- - . - - . . - - . _ . . . - - . - . _ . _ - - - -.. - - - . . - . . .

4 ,

-

i l Observations and Findinas

!

The inspectors observed the CT using good sampling techniques such as rinsing the

. RCS sample container with the intended sample and purging the sample lines, as

'

required by procedure, to ensure that a representative sample was obtained. The CT also properly obtained a dose rate measurement of the RCS sample and an in-

,

line conductivity measurement. During these tasks, the CT properly handled samples to reduce the potential for any chemical contamination and wore gloves

,

when handling contaminated sample lines and sample valves.

l

The inspectors noted that the individual collecting the samples had trouble keeping the RCS sampling procedure available for reference because of the physicallayout j of the RCS sample panel area. The lack of a horizontal surface on which to rest the procedure, as well as the need for the use of both hands to perform this evolution, j caused the CT to drop the procedure on the floor several times and then place it out

of sight. This increased the time spent in the area, the potential for lack of procedural adherence, and the potential for contamination of the procedure (see i Section R2.1).

!

The inspectors observed the CT perform various measurements and analyses on the

{ collected samples. The individual demonstrated good analytical techniques and j attention to detail. The inspectors did not identify any analysis concerns.

,

j Conclusions

,

A CT demonstrated good sampling and analytical techniques during routine RCS and offgas sample collection and analysi R5 Staff Training and Qualification in RP&C R 5.1 Staff Trainina and Qualification in Chemistry Insoection Scone (84750)

The inspectors reviewed the qualification and training program for chemistry technicians, and interviewed several cts to determine the effectiveness of these program Observations and Findinos The training and qualification program is described in the procedure " Selection, Training and Qualification Program Description" (OP-RC-755, Rev.11), which clearly documents the training and qualification requirements for multiple positions in the chemistry department. Through a review of this document, and interviews with the chemistry department training coordinator and several chemistry engineers, the inspectors noted that new chemistry employees were required to complete 9 highly-structured training and qualification program. This program included site access training (if needed), classroom training, and on-the-job (OJT)

-

_ . _ . . . _ _ __ _. _ _ _ .___ _ _ _. - _ _ . _ .. _ . _ _ _ _ _ _ . _ .. _ _ _ __ _

.

.

i '

F training. The classroom training typically lasted about two' months. The training

- program utilized several forms of peer review and feedback to trainees so that they .

were aware of their performance and potential areas for improvement. The (

inspectors noted that OJT review sheets and management review of employee j performance appeared to address issues openly. Communication between the j training coordinator in the chemistry department and the plant training organization

was frequent and effective.

)

After completion of the formal training process, employee performance was i evaluated periodically through interlaboratory comparisons and feedback was

provided to the employee. The licensee had requalification requirements for various j- skills, and effectively tracked and maintained these requalifications. In addition,

, members of department upper management were aware of current training issues

, and staff performance and participated personally in the training and qualification ;

f progra , Conclusions The training and qualification program for chemistry personnel was well-organized, i well-managed,~ and effective, in particular, frequent performance based skill testing j and feedback to the staff were indicators of a strong commitment to continuous

, improvement.

T R7 Quality Assurance in RP&C Activities

'

R7.1 Quality Assurance in Chemistry Activities Y

a.

'

Inspection Scope (84750)

i j The inspectors assessed the effectiveness of the licensee's identification and

! resolution of chemistry problems. Specifically, the inspectors reviewed the results

?

of self-assessment activities for the previous 12 months and reviewed the

, corrective actions.

2 1 Observations and Findinas

i ,

The self-assessments consisted of routine field observations and comprehensive,

{ programmatic reviews. In addition, the licensee completed individual evaluations of i- each CT, focussing on analytical principles and procedure adherence. Within the chemistry department, the staff documented the findings, assigned corrective

!- actions, and tracked the resolution of those corrective actions. The self j assessments were viewed as a coaching / training tool, and personnel errors were

! corrected or activities were repeated. The inspectors observed that these l assessments were effective in identifying problems.

j The inspectors also reviewed recent results of the quality verification / control

,

program. A review of quarterly results of both intra- and interlaboratory

comparisons indicated that the licensee performs accurate and consistent analyses, i.

/ 11

l

.

4 w, - -

- . - - . - - - . - . . - . - - . _- - .- - . . - . -. . - . . - - - - - . . -.

!

i

.

Comprisons were performed on a regular basis by all staff cts. The inspectors

,

had no concerns with the chemistry quality assurance activities.

.

An audit conducted by Nuclear Quality Assurance identified minor problems -

regarding documentation and equipment repair. In addition, the licensee recently

-

utilized a vendor to conduct a comparison of chemistry activities and procedures to the UFSAR. As a result of this comprehensive review, chemistry staff made over a

,

dozen changes to ensure consistency and compliance between the UFSAR and the chemistry department.

1' Conclusions t

l The self-assessrnents were comprehensive, performance-based, and identified areas

for improvement. The Nuclear Quality Assurance audit identified some minor problems and a comparison of the chemistry program to the UFSAR resulted in a i number of changes to ensure complianc R8 Miscellaneous RP&C lasues R (Discussed) Insoection Followuo item 50-341/96006-10: inability to ootain a PASS sample, in July 1996, during the biennial emergency exercise, the PASS team was unable to obtain a reactor water sample due to a control room operator's failure to recognize and communicate that the PASS had been manually isolated and required a manual valve manipulation prior to operation. The inspector reviewed PASS data since October 1995 and noted that the licensee has experienced other operability problems with the PAGS. In addition, interviews with plant personnel indicated that the PASS vendor was presently developing a proposal to significantly modify the system (See Section R2.2). Therefore, due to the variety of problems and the pending PASS modification, this item remains ope R8.2 (Closed) Violation 50 341/90018-03: failure to perform an adequate radiation survey. The inspectors conducted walkdowns in various areas within the plant and reviewed the appropriate survey maps. The radiation surveys were current and accurate, and recent radiation protection inspections have not identified a problem regarding radiation surveys, therefore this item is close R8.3 (Closed) Violation 50-341/90018-04: excessive radiation levels on the external surface of a package. Recent radwaste surveys and NRC inspections have shown that the RP staff have been successful in identifying unusual radiation levels on transportation vehicles and packages prior to receiving these articles within the protected area. No excessive radiation levels or radiological problems regarding Fermi 2 packages have been identified, therefore this item is close R8.4 (Closed) Insoection Followuo item 50-341/96004-11: personnel contaminations during RWCU maintenance. On April 30,1996, while removing the south RWCU pump casing for seal replacement work, a spiral flexitallic gasket uncoiled causing airborne radioactivity (concentration was 12.5 Derived Air Concentration - DACs).

Four workers received either intemal uptakes or were externally contaminate __ . _ _ . _ _ . _ _ _ _ __ .._ _ __.. _ . _ _ _ _ . _ _ _ _ . . - _ . _ . _ . . _ _ _ _

.

Although respirators were not worn for ALARA considerations, local high efficiency particulate air filter ventilation was utilized during the breach. In addition, during the move of the pump assembly in the hot machine shop a 0.8 DAC sample was obtained and two workers were contaminated. The inspectors determined that RP staff used appropriate methodology for the dose assessment The licensee initiated two Deviation Event Reports (DERs 96-0497 and 96-0498), a self-assessment (NPRC-96-0214), and conducted ALARA reviews in response to this event. The information in the DERs and the self-assessment was incorporated into the job file and continuing training schedule. The RP evaluation determined that severalimprovements should be made to this process, such as repositioning the shielding, chemical decontamination prior to work, continuous airborne monitoring, use of glue to control airborne radioactivity, and the use of respirators for selected activities for pump room activities. Staff also recommended bead blasting the pump internals, use of faceshields, and ensuring adequate flowrates for the plastic containment enclosure for hot machine shop wor The inspectors observed that most of these recommendations were implemented for the north RWCU seal RWP and pre-job ALARA review, which occurred subsequent to the south RWCU seal work. The job progress ALARA review noted that only one personnel contamination occurred during the north RWCU work, and although four air samples showed greater than 0.3 DAC, the use of respirators precluded uptake of airborne radioactivity. The total dose and man-hours for the north RWCU work were 80% of the totals for similar work on the south RWCU seal. The inspectors determined that the RP actions were appropriate and this item is close !

R8.5 (Closed) Insoection Followuo item 50-341/96005-06: contaminated respirators I found outside the RRA. During a quarterly survey inside storage building 44A, RP staff found contaminated respirator canisters, with emearable activity for all respirators less than 500 dpm. The canisters were taken to the radwaste building, Building 44A was thoroughly surveyed, and a Deviation Event Report (DER 96-0711) was initiated. The followup survey identified two air hoses, an air regulator box, other respirator canisters, and respirator facepieces with fixed and loose contamination (3000-5000 dpm). All of the contaminated materials were transferred to the RRA. Other buildings outside the RRA were surveyed and no results above background were identifie Licensee review of this issue determined that many of the canisters had been returnod from a vendor with contamination levels above the contract limit. The air hoses and respirator facepieces had been stored in Building 44A approximately four years and two years, respectively. The contaminated respirator parts had been received from decontamination contractors and had only been spot checked by RP staff prior to storage in Building 44 A licensee evaluation (NPRC-96-0344) determined that respirators should be surveyed individually and unbagged in the tool monitor prior to release from the RRA. Plant staff was authorized to store respiratory protection equipment in a

._

.

.

radioactive material storage area within the RRA to reduce the need for release surveys. Also, potentially contaminated hoses will not be removed from the RR During an August 27,1996 meeting, radiological health personnel were reminded to maintain a questioning attitude regarding material received from vendors and to

, oversee Building 44A storage practice The inspectors observed free release surveys, determined that the licensee's actions were appropriately implemented, and noted that there has not been a recurrence of contaminated respirator equipment or air hoses located outside the RRA. This item is close R8.6 LClosed) Inspection Followup Item 50-341/96010-16: inadequate RP practice resulting in a personnel contamination. On July 3,1996, two Instrument and Control technicians removed a flow switch from the offgas system. The

'

technicians did not consider the potential for contamination and attempted to exit the RRA with the flow switch. One worker alarmed a personal contamination monitor and further surveys determined that the flow switch was contaminate RP staff did not initiate a DE The RP staff determined that the breaching of the offgas hydrogen monitor without i notification of RP was a violation of the radiation work permit (RWP), and the technicians were denied access to the RRA. The RP dose assessment for the contaminated worker estimated a skin dose of less than 0.5 mrem. Both technicians processed through the RRA access reinstatement program satisfactorily and the instrument and control staff received training on this occurrence. The ,

inspectors determined that the RP department's actions were appropriate and this '

item is close X1 Exit Meetina Summary The inspector presented the inspection results to licensee representatives during an exit meeting on June 6,1997. The licensee acknowledged the findings and did not indicate that any materials examined during the inspection should be considered proprietar !

I I

14  !

__ _

-

l l

-

,

PARTIAL LIST OF PERSONS CONTACTED Licensee

S. Bartman, Chemistry Supervisor P. Duffy, Radiological Engineer P. Fessler, Plant Manager  !

E. Kokosky, Radiation Protection Manager l

T. Lashley, Radiological Engineer '

G. Macadam, General Supervisor, Radiation Protection Operations J. Metter, System Engineer R. Nearhoof, Chemical Engineer R. Pospisch, Analytical Engineer l D. Thomas, Maintenance Enginear T. VanderMey, Radiological Engineer D. Wilger, Senior Chemical Engineer D. Williams, Radiological Engineering Supervisor HBC G. Harris, Senior Resident inspector, Fermi 2 C. O'Keefe, Resident inspector, Fermi 2

!

.i INSPECTION PROCEDURES USED IP 84750, " Radioactive Waste Treatment, and Effluent and Environmental Monitoring" 1

4 ITEMS OPENED, CLOSED, AND DISCUSSED Closed

-

50-341/90018-03 VIO Failure to perform an adequate radiation survey

.l

'

50-341/90018-04 VIO Excessive radiation levels on the extemal surface of a packago l l

-

50-341/96004-11 IFl Personnel contamination during RWCU maintenance

]

50 341/96005-06 IFl Contaminated respirators found outside the RRA 50 341/96010-16 IFl Inadequate RP practice resulting in a personnel contamination

.

Discussed 50-341/96006-10 IFl Inability to obtain a PASS sample l

l

'

l

.

LIST OF ACRONYMS USED ARMS Area Radiation Monitoring System CT Chemistry Technician DAC Derived Air Concentration DER Deviation Event Report ODCM Offsite Dose Calculation Manual OJT' On-the-Job Training PASS Post-Accident Sampling System PRMS Process Radiation Monitoring System i RCS Reactor Coolant System RRA Radiologically Restricted Area RWCU Reactor Water Cleanup Unit I UFSAR Updated Final Safety Analysis Report l

l l

l i

_ - - - -. - .- ._ .. -.

.

l

.

LIST OF DOCUMENTS REVIEWED  !

UFSAR Section 11.4 - Process and Effluent Radiation Monitoring System

UFSAR Section 11.4.4.4 - Postaccident Sampling System l l

UFSAR Section 12.1.4 - Area Radiation Monitoring UFSAR Section 12.2.4 - Airborne Radioactivity Monitoring NOA Audit Report 97-0108, " Chemistry, Radiological Effluents, Radioactive Material Transfer and Disposal".

NPRC-97-0028, "1996 Annual Radioactive Effluent Release Report".

NRC-97-0050, "1996 Annual Radiological Environmental Operating Report".

NRC-96-0110, " Fermi Plant, Unit 1, Annual Report for Year Ending June 30,1996".

NPRC-96-0450, "1997 Radiological Health Goals".

Nuclear Production Operating Procedure (NPOP) 62.000.202, Rev.11, "REMP Sampling and Shipping".

NPOP 64.080.601, Rev. 9, " Source Checks for Liquid and Gaseous Radiation Monitors".

NPOP 64.611.504, Rev.10, " Area Radiation Monitoring System Channels 1-5,7-14, and 18-48".

Radiation Protection Conduct Manual MRP02, Rev. 4, " Administrative Controls".

NPOP 62.00.100, Rev. 4, " Radioactive Effluents and Dose Tracking".

NPOP 62.00.110, Rev. 5, " Evaluation of Dose Rates Due to Radioactive Particulates, lodines, and Tritium in Gaseous Effluents".

NPOP 62.000.111, Rev. 5, " Gaseous Effluent Dose Due to lodines, Particulates, and Tritium".

NPOP 62.000.112, Rev. 5, " Noble Gas Site Boundary Dose Rate and Setpoint Evaluation".

NPRC-96-0069, " Validation and Verification of the Microsoft Access Effluent Surveillance Application".

NPOP 73.714.01, " Plant Process Sampling, P33-P405A, Radwaste Building Sample Panel".

NPOP 74.000.18, " Chemistry Shif tly,72 Hour, and Situation Surveillances".

l

'

l NPOP 74.000.19, " Chemistry Routine Surveillances". I NPOP 75.000.01, "Leeman Labs Plasma Spec l lCP Spectrometer".

l NPOP 76.000.34, " Reactor Coolant Analysis". j

!

NPOP 78.000.09, "OffGas Sampling and Analysis". 1

1 Fermi 2 Chemistry Program Review Committee Reports - various

!

Laboratory Quality Verification / Quality Control Fourth Quarter 1996 Repor Laboratory Quality Verification / Quality Control First Quarter 1997 Repor NPOP 78.000.12, Rev. 6, " Post-Accident Sampling and Transport". l NPRC-96-0344, " Release of Respirators and Filter Cartridges".

NPRC-96-0350, " Respirator Free Release".

l NPRC-96-0214, "RWCU Pump Rebuild Self-Assessment April 1996 System Outage".

!

i l

l i

i

$

i

!

V e

W d

. . - -