IR 05000314/2010007

Insp Rept 72-0001/85-02 on 850314-1007.No Violations or Deviations Identified.Major Areas Inspected:Fuel Shipping Activities,Fuel Storage Activities & Radiation Protection & Radwaste Programs,Including Organization & ALARA

ML20205F253
Person / Time
Site:	07200001, 05000314, 07001308
Issue date:	10/15/1985
From:	France G, Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205F250	List: IR 05000313/2010007 IR 05000314/2010007
References
72-0001-85-02, 72-1-85-2, NUDOCS 8511050271
Download: ML20205F253 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Report No. 72-001/85-002(DRSS)

Docket No.72-001 License No. SNM-2500 Licensee: General Electric Company 175 Curtner Avenue San Jose, CA 95125 Facility Name: Morris Operation

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Inspection At: Morris Operation, Morris, IL Inspection Conducted: March 14 through October 7, 1985 0,uncu s Principal Inspector: fG. M. France,'III bbf $lf[I y)(3 Fuel Shipment Inspector: W. B. Grant Date YI Approved By: R. G eger, Chief / DIN 6 Facilities Radiation Protection Date Section Inspection Summary Inspection on March 14 through October 7, 1985 (Report No. 72-001/85002(DRSS))

Areas Inspected: Routine, unannounced inspection of fuel shipping activities; fuel storage activities; and radiation protection and radwaste programs, including organization, ALARA, internal surveys, notifications, and reports; '

solid radwaste and transportation activities; environmental protection program, including airborne and liquid effluents, and maintenance surveillance activities. The inspection involved 57 inspector-hours onsite by two NRC inspector Results: No violations or deviations were identifie .

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DETAILS

! Persons Contacted R. M. Cartwright, Senior Technician, Analytical

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• C. Damm, Senior Engineer, Licensing and Radiological Safety

L. L. Denio, Supervisor, Quality Assurance and Safeguards

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J. S. Durham, Safety Technician

! R. V. Hand, S&fety Technician

*T. E. Ingels, Manager, Quality Assurance and Safeguards

! *J. E. McGrath, Supervisor Plant Safety

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S. P. Schmid, Specialist, Field Services T. E. Tehan, Senior Engineer, Field Services

• E. E. Voiland, Plant Manager

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• Denotes those present at the meetin The inspector interviewed other licensee and State of Illinois personnel including: operators, safety technicians, State of Illinois Office of Waste Transportation inspectors, officials of Burlington Northern Railroad Company, and Burns Security personne . General

! The inspection of onsite activities, which began at 10:15 a.m. on September 8, 1985, was conducted to examine routine operations of spent fuel storage activitie Region III inspectors performed monthly onsite surveys on shipments of spent fuel received from the Monticello Nuclear Plant. The inspectors monitored the licensee's spent fuel program from March 14 through October 7, 198 September 13, 1985, was the date of

.I the onsite exit meeting.

. Management Organization and Controls '

The inspector reviewed the licensee's management organization and ,

controls for radiation protection and operations, including changes in '

I the organizational structure, procedure revising and updating, and

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utilization of audit systems.

i Organization Several personnel changes that may affect the radiation protection

program have occurred since the previous inspection. Inspection

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Report No. (72-001/85001(DRSS)).

The Plant Safety Supervisor no longer reports to the Senior Engineer Licensing and Radiological Safety. He has been assigned additional duties in industrial and radiological safety support programs, and reports to the Morris Operation Manager. This organizational change provides the Morris Operation Manager with direct line support to resolve health and safety concern i

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? I As discussed in the previous inspection report (72-001/85001) the  !

Senior Engineer, Licensing and Radiological Safety position has been filled. The only significant difference in esponsibility for the

. incumbent is that the Plant Safety Supervisor and four Safety i Technicians report directly to the Morris Operation Manager.

, The inspector noted that the incumbent in each of the above positions serves as members of the Plant Safety Committee and that items of

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particular safety significance will still be evaluated through safety committee revie No violations or deviations were identified.

Procedure Revising cnd Updating i l The inspector confirmed that the licensee periodically reviews and

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updates radiation protection and fuel storage operating procedure i The inspector noted that procedures that provide instructions and

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prescribe requirements and limits for special work are approved by

, the Plant Safety Committee. The licensee conducts biennial review

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of selected standard operating procedures. In response to inspector concerns the licensee acknowledged that procedures affecting emergency brigade operations are in need of revie The inspector concluded that the licensee's system for reviewing and approving procedures enables the licensee to maintain current

programs for evaluating major operational safety matters.

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Safety Committees

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The inspector examined the minutes of the monthly meetings held by

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the Plant Safety Committee. The Committee approved the review /

! revision of several standard operating procedures, to include

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50P-16-11, Revision 4, Basin Leak Detection Alarm Compliance Tes ..

The Committee also reviewed plans to combat seepage into the basin

from perched water formed by heavy rains. Approval by the Morris t

Operation Manager allowed corrective action by introducing a surge pump to discharge the water. The Manager, Morris Operation noted that no seepage has occurred since the sump pump was last inspecte The Committee continues the practice of selecting monthly topics for i discussion that relate to rad protection and industrial safety

] concern Other Safety Committee actions may be found in Section

3(d) Internal Reviews and Audit Internal Reviews and Audits The inspector noted that the licensee utilizes routine inspections /

> audits and tests to assess operating capability of spent fuel cask The inspector reviewed minutes of safety committee meetings and verified that the licensees level of in3pection performed in the annual maintenance of shipping casks is sufficient to detect problems nonconforming to technical specification During annual

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inspection of an IF-300 cask the licensee discovered that due to excessive wear of the casks head seal surface the cask failed the technical specification for allowable head seal leakage at 200 psi water pressure. The cask had been in service for 12 years and the 3 condition was corrected by remachining the seal surface In accordance with 10 CFR 71.95, the licensee is required to report i to the Director, NRC NMS l

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(a) Any instance in which there is significant reduction in the i effectiveness of any authorized packaging during use; and t (b) Details of any defects with safety significance in'the packaging after first use, with the means employed to repair the defects and prevent their recurrence.

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The licensee concluded that there was no significant reduction in the effectiveness of packaging during use, and since the cask had been l in service for 12 years, failure of the head seal to pass the hydro l pressure test was probably due to " fair wear" and not a defect in cack design. For the reasons stated, the licensee concluded that j the internal inspection disclosed an item nonconforming to technical specifications, but not identified as an item reportable to NRC NMS The licensee performed an inspection on a second IE-300 cask and discovered that neutron shield fluid (glycol) was weeping through a 1/8 inch thick seal plate. The failure was apparently caused by thermally induced expansion and contraction over the years the cask has been in servic The Plant Safety Committee concluded that the condition did not constitute a rignificant reduction in the effectiveness of the packaging, and that the inspection did not reveal a condition caused by design fault. The licensee brought in a specialist, who recommended rewelding the sea The licensee corrected the

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leak by rewelding the seal. There was no apparent structural significance in the licensee's inspection findings nor was there any compromise to lessen the safety or increase exposure to the '

publi The inspector and licensee acknowledged that during future inspections, it may be desirable for the licensee to communicate those instances to the NRC that surface during programmed reviews or inspections, showing an anomalous quality that may lead to safety considerations.

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The inspector concluded that internal reviews and inspection or audit findings receive additional reviews by the Plant Safety Committee, with final review and determination by the Morris Operation Manage No violations or deviations were identifie s

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! Radiation Protection

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The inspector reviewed the licensee's internal and external exposure control programs, including the required records, reports and notifications,  ;

and the licensee's program for maintaining occupational exposure ALARA.

• Internal Exposure Control The inspector reviewed the results of routine urinalysis performed on 43 Morris Operation personnel since the last inspection (Inspection Report No. 72001/85001). No significant detectable activity was

.! found. The highest reported urinalysis for gamma emitters showed about 0.12 percent of a body burden equivalent detected as cesium-13 ;

The annual whole body count for mixed fission, corrosion, and activa-i tion products had been delayea by the vendor until late September 1985. Whole body count results will be reviewed during a future l inspectio External Exposure Vendor supplied film badge reports from March 1985 to date were

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reviewed. Due to maintenance performed on a leased IE-300 cask about 16 persons at Morris Operations received an accumulative exposure of about 1.2 r/ hour. The maximum exposure received by an individual

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was about 350 mrem. Total man-rem for 1984 was reported as 1 ;

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I Source Leak Tests

The licensee performed leak tests on radioactive sealed sources in i j accordance with requirem~ents fisted in technical specification 4. ;

The maximum level of removable contamination from each tested source was less than 0.005 pCi using dry-wipe testing technique Posting, Labeling and Control i The inspector confirmed that the licensee had posted the September 1984 revised edition of Form NRC-3, which is required by 10 CFR 19.11(c), in a sufficient number of places te permit individuals engaged in licensed activities to observe them on the way to or

from any particular licensed activity.

1 , Airborne Releases and Quantification The inspector selectively reviewed licensee records of area air sample analysi Alpha and beta / gamma measurements of airborne

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radioactive concentrations performed in the fuel basin area were less than the MPC allowed in 10 CFR 20. While perferming maintenance l on an IF-300 cask two operators in full face respirators were exposed '

to concentrations of airborne radioactivity that exceeded the i l licensee's action level of IE-08 pCi/ml. The airborne concentration i was determined by high volume grab samples, but ARM instruments did j not detect airborne concentrations above the action level.

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The health physics review of the incident disclosed that the radioactive airburne emission did exceed the licensee's action level of 1E-08 pCi/ml, but that the elevated activity was localized which prevented the ARM instruments from detecting the increas The two operators were appropriately wearing full face masks that offered a protective factor that limited the effect of the exposure to less than one MP f. ALARA Activities _

The inspector examined licensee records that documented the use of engineering controls in reducing occupational exposures. The licensee installed several new air driven torque-socket wrenches. These were iaentified to the inspector during a tour of the basin decontamination pa By employing air powered torque wrenches, operator time required to remove a spent fuel cask head is reduced from about two hours to less than one hour. Personnel exposure levels were also reduced by using lead shielding when performing cask maintenance. Other actions performed by the licensee to reduce exposure levels include the following:

• Clean-up and disposal of crud samples submitted for laboratory analyse * Video critique of practiced dry runs of cask waste liner remova The inspector observed the licensee video taping spent fuel arrivals. Video critique is useful in improving operator performance, and as an added benefit saves operator or man-hour time and subsequently reduces exposure level * The licensee has limited the number of intrusions into the LAW vault by installing a LAW liquid level indicator for digital read out from the control room panel displa g. Survey, Contamination Control /0ff-site Releases The inspector observed licensee performance in req': iring visitors to perform exit monitoring procedures from the cask unloading facilit Licensee Operators and Safety Technicians are cognizant of the requirement to control the trafficking of radioactive contamination from area to area. The inspector ooserved a Safety Technician instructing four members of the Canadian Broadcast Corporation (CBC-TV) in the proper way of exiting the cask unloading facilit The licensee conducts frequent piant tours. Plant personnel are trained to instruct and or caution visitors and vendors about contamination control. In addition, the licensee's vendor supplied security guards conducted careful contamination surveys on all persons exiting the plan The l'icensee also decontaninated several items for release offsite, including:

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• Spanner wrench decontaminated by the electropolishing technique, which reduced hot spots from over 6000 dpm/100 cm2 to less than 2200 dpm/100 cm2 ,

• Poster rugs were decontaminated to release limits of less than 2200 dpm/100 cm2 ,

Activities performed in the basin decon area caused survey readings as high as 118,000 dpm/100 cm 2 , but subsequent cleanup efforts brought the contamination level to fixed hot spots of about 1900 dpm/100,cm2 ,

During the course of this inspection, the licensee prepared a redundant yoke for shipment. The yoke used in IF-300 cask handling programs was decontaminated to acceptable levels of less than 2200 dpm/100cm2 . The yoke was packaged as three separate components and placed into wooden crates. Contamination survey data showed fixed smear counts or, yoke components of less than 2200 dmp/100cm2 ,

while the packaged wooden creates showed smear counts up to 220 dem/100 cm2 ,

The inspector concluded that the licensee is complying with regulatory requirements related to radiation protectio No violations or deviations were identifie . Operatior,s Review The inspector reviewed with the licensee the status of operations at the Morris Operatio Fuel Storage Activities The inspector reviewed the licensee's fuel storage activities including current and proposed fuel receipts and shipment From November 20, 1984, through October 7, 1985, Region III USNRC inspectors performed monthly onsite inspections of Morris Operation activities during receipt of spent fuel shipments from Northern State Power's Monticello Nuclear Generating Station. The frequency of spent fuel shipments is bi-weekly; by October, 684 fuel bundles of Monticello fuel will be stored at Morris Operation's spent fuel facilit The October shipment will represent the last shipment from Monticello for 1985. In November, the Nebraska Cooper Station will renew their series of spent fuel shipments for storage at Morris Operatio s .

The inspector reviewed documentation of an incident involving the radioactive concentration in the cask coolant as determined by analysis of the first cask flush of an air cooled cas Initial radioactive concentration of the cask coolant showed 1.19 pCi/m On the second and third flushes the analysis showed a concentration of 0.7 and 0.6 pCi/ml, respectively. The consistent values shown

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in the second and third flush analyses indicated that the radioa-ctive concentration of the coclant was below the action level, additional samples were taken and a composite was made of the first three samples. The final or composite analysis showed a concentration below the 1.0 pCi/ml technical specification requirement, hence, the concentratidn of radioactive material indicates that no failed fuel existed in the cask, and no breach of spent fuel occurred during transi The inspector concluded that the documented account of t

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licensee performance and discussions with licenses personnel sh]wed that the transfer of the spent fuel to the basin pool vccurred according to procedure and licensee requiremen '

i Housekeeping The inspector observed that railroad tracks leadi g to the cask receiving area were clear and that the licensee nad adequately prepared the area to receive each shipment. Railroad officials

! disclosed that during the course of transporting spent fuel from Monticello to Morris Operation there were no delays caused by licensee performance. Delays that did occur were off site, caused by track and or draw bridge maintenance and represented incidents germane to railway transport. In response to other inspector concerns, a railroad official also noted that there were no problems from intervenors that caused delays in transit or a breach in securit The inspector concluded that the potential for accumulating fissile materials in unauthorized locations or exposing the public to unnecessary levels of radiation.was minimized, because of the ,

implementation of planned approved procedure . Criticality Safety Commensurate with the requirements of 10 CFR 72, the licensee's spent fuei l handling and storage systems were designed during plant construction and or prior to plant operation to meet parameters derived from criticality safety bench mark calculation During the course of the inspection period March 14 through October 7, 1985, there were no facility modification and changes, or spent fuel inquiries that required the licensee to perform nuclear criticality safety analyse No violations or deviation were identifie . Waste Generator Requirements, 10 CFR 20 and 61 The inspector reviewed waste generation activities to oetermine whether the licensee has established and is maintaining adequate management ,

controlled procedures which reasonably assure compliance with the requirements of 10 CFR 20 and 10 CFR 61 applicable to low level radwaste form, waste characterization and classification, stabilization, and

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shipment manifests and tracking. The inspector also reviewed licensee actions related to a shipment of solidified radwaste shipped in June 1985, to the burial facility located at Barnwell, South Carolin The Plant Operations Unit backed with approval by the Plant Safety Committee has the responsibility for establishing and maintaining adequate management-controlled procedure; in accordance with 10 CFR 20 and 10 CFR 6 The licensee's waste handling (SOP-I-52, Revision 10) and shipping procedures (50P-I-53) appear to address the regulatory concerns for carrying out various radwaste packaging and shipping activities. By procedure the licensee performs quality control inspections for container integrity and surveys the shipment for radiation levels. There appeared to be a clear delineation of authority and responsibility of those individuals assigned to radwaste processing for low level land buria Licensee records appeared adequate to document a manifest tracking system to include waste form and classification, as required under 10 CFR 20 and 10 CFR 61. The inspector verified that the licensee maintained a current copy of the disposal site Rad Waste Transport Permi The inspector noted that the Field Services Specialist is the cognizant person required to effect an investigation in any instance where receipt of shipment has not been verified within the specified perio No violations or deviations were identifie . Transportation The inspector reviewed the transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt; packaging, and delivery of licensed radioactive material The inspector reviewed licensee shipping records and confirmed that health physics surveys were documented. The inspector noted that a system is in place 16 ~ intain a record of each shipment of licensed material in accordance with 10 CFR 71. In addition, shipping records disclosed that the licensee performed radwaste program requirements that covered:

• Monitoring for radiation and contamination of radwaste packages and transport carrier,

• Package marking and labeling, and vehicle placarding,

• Instructions that provide disposal site acceptance criteria,

• And shipping paper documentation in accordance with licensee procedure The inspectors reviewed the licensee's program for receipt and/or shipment of radioactive materials. The review included inspection of six incoming rail shipments of spent reactor fuel shipped from Monticello Nuclear Generating Station, during the months of April through the 7th of

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October 198 For each incoming shipment, the inspectors reviewed shipment records, observed cask receipt preparations, performed independent radiation contamination surveys, and verified implementation of the licensee's transportation activities procedures. The inspectors dis-cevered that the level of non-fixed radioactive contamination on the external surface of one incoming cask exceeded the NRC contamination limit of 22,000 dpm/100 cm2 , for one smear. The licensee observed the same problem during receipt of an incoming cask. In both cases the contamination level was less than 30,000,dpm/100 cm2. By applying smear efficiency techniques to each cask it was adequately demonstrated that the 22,000 dpm/100 cm 2 contamination limit was not exceeded. No problems were note Since the last inspection (Inspection Report No. 72-001/85001) three Morris Operation Personnel identified as the Operating Engineer, Field Services Specialist and the Senior Engineer Licensing and Rad Safety, attended a workshop on specific transportation programs. The four- day session or Radioactive Material Transportation Workshops was conducted for DOE by Science Applications International Corporation, and included discussions describing the characteristics of radwaste material, implementation of IAEA standards, and hazardous west The inspectors concluded that licensed performance during the receipt of incoming spent fuel shipments admquately demonstrates that minor contamination levels can be corrected. No problems were note The licensee's shipping records also disclosed that about 1,100 cubic feet of low level waste was shipped to the Barnwell disposal site. This represented the licensee's first shipment of LLW since 10 LFR 61 became effectiv No violation or deviations were identifie . Maintenance and Surveillance Testing The inspector examined the licensee's maintenance operations to determine if records are maintained on plant systems pertinent to safet The required measurements for the determination of basin water quality disclosed that the concentration of radioactivity was less than the action level of 0.02 pCi/ml beta. Other chemical parameter concentrations were well within technical specification limits, and the required measure-ments were performed within the specified frequenc Records also disclcsed that criticality detectors were checked for operability and area radiation monitors (ARM) were cglibrated within the frequency required by Table 4-2, technical specification 4.4.1. The licensee noted that other than the replacement of a criticality horn no other problems were identified. In response to inspector concerns, the licensee confirmed that spare criticality systems were onsite and available to place in servic No violations or deviations were identifie I

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o 1 Trainin_g

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The inspector reviewed the licensee's provisions for training visitors and

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contractors who may enter or have work assignments in controlled area ,

The inspector noted considerable visitor / contractor activity at Morris Operations, including:

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• Filming of spent fuel activity by representatives of the Canadian l Broadcast Corporation news television team,

• Contract painting of the facility water towe In response to inspector concerns the licensee noted that initial training in safety and radiation protection was provided and temporary certification was assigned to visitors and contractors. This training covers facility

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alarm system, emergency procedures, security and 10 CFR 19.12 requirer:;ents.

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The inspector verified through observation, record review and interviews with the Plant Safety Supervisor that the licensee is conducting radiation i safety training for visitors, contractors and employees commensurate with Morris Operations policy and.10 CFR 19 requirement No violations or deviations were identifie . Emergency Preparedness The inspector verified that emergency equipment including fire extinguishers,  !

respiratory protection devices and radiation survey instruments is checked i on a periodic basi Emergency equipment is compared to checklist items on a monthly basi The inspector noted that expendable items, such as batteries are replaced

, on a predetermined frequency, and radiation detection survey instruments are calibrated at the frequency prescribed by Appendix A, Technical

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Specifications. Currently, the emergency coordinator is the Operation Shift Supervisor. The OSS has the authority and responsibility in an emergency for the welfare and safety of Morris Operation personnel and equipmen i In response to inspector concerns, the licensee acknowledged that the ,

, emergency procedure should be reviewed in order to determine if any changes are necessar The in .pector recommended an early review of the emergency procedure.

! This was further discussed during the exit meeting.

I 1 Exit Meeting The iqspector met with licensee representatives (denoted in Section 1)

at the conclusion of the onsite inspection on September 13, 198S. The inspector summariled the scope and findings of the inspection and stated

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that there were no violations or deviations identified within the scope of this inspectio The licensee acknowledged the inspector's concern about reviewing emergency preparecaess procedures in order to determine if changes that affect personnel assignment and equipment are necessar During the course of this inspection and the exit meeting, the licensee did not identify any documents or inspector statements and reference to specific processes as proprietary.

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