IR 07200001/1986002
| ML20213G056 | |
| Person / Time | |
|---|---|
| Site: | 07200001, 07001308 |
| Issue date: | 11/03/1986 |
| From: | France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20213G043 | List: |
| References | |
| 72-0001-86-02, 72-1-86-2, NUDOCS 8611170303 | |
| Download: ML20213G056 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 72-001/86002(DRSS)
Docket No.72-001 License No. SNM-2500 Licensee: General Electric Company 175 Curtner Avenue San Jose, CA 95125
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Facility Name: Morris Operation Inspection At: Morris Operation, Morris, IL Inspection Conducted: August 1986 through October 28, 1986 W
r Inspector:
G. M. France, III
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Approved By:
L. R. Gr r, Chief
//@0 Facilities Radiation Date Protection Section Inspection Summary Inspection on August 1986 through October 28, 1986 (Report No. 72-001/86002(DRSS))
Areas Inspected:
Special, unannounced health and safety inspection of fuel shipment and storage operations, with major emphasis on the excessive smearable contamination levels on the cask external surfaces for two separate cask shipments.
The licensee's radiation protection program for annual maintenance and cask turnaround was also reviewed.
Results: One violation was identified (smearable contamination on three empty casks exceeded NRC/ DOT requirements - Section 4).
8611170303 861105 PDR ADOCK 07001308 C
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DETAILS 1.
Persons Contacted L. L. Denio, Supervisor, Quality Assurance and Safeguards
- R. G. Damm, Senior Engineer, Licensing and Radiological Safety T. E. Ingels, Manager, Quality Assurance and Safeguards J. E. McGrath, Supervisor, Plant Safety S. P. Schmid, Specialist, Field Services T. E. Tehan, Senior Engineer, Field Services
- E. E. Voiland, Plant Manager
- Denotes those present at the exit meeting on June 12, 1986.
The inspector also contacted other licensee personnel and other personnel associated with the spent fuel shipments, including: operators, safety technicians, State of Illinois Office of Waste Transportation inspectors, and officials of Burlington Northern Railroad Company, 2.
General The inspection of onsite activities, which began at 8:30 a.m. on October 6, 1986, was conducted to investigate the circumstances surrounding excessive smearable contamination levels on the external surface of three empty shipping casks. The inspector also reviewed the licensee's responses to two Confirmatory Action Letters (CAL) issued to the licensee by Region III, to ensure that contamination levels during transit do not again exceed DOT limits. During the course of the onsite inspection the inspector also reviewed the licensee's radiation protection program during activities associated with preparing the IF-300 casks for use in the Northern States Power Company (Monticello) spent fuel shipment campaign.
3.
Licensee Actions on Previously Identified Items (Closed) Open Item No. 72-001/85001-01, Updating the Emergency Preparedness Procedures. The licensee has updated the emergency preparedness manual to include a roster of personnel who serve as emergency brigade members.
(Closed) Open Item No. 72-001/86001-01, Procurement of State of the Art Surveillance Instruments. The inspector identified a purchase order that estimated time of delivery as October 1986 for delivery of an improved portal monitor system to monitor persons exiting the controlled areas of the plant.
(Closed) Unresc1ved Item No. 72-001/86001-02, Sampling Location Discrepancy of Dairy Farms. The licensee's inquiry disclosed that the vendor who samples dairy farm cows initiates location changes in conjunction with available pastures within the probable affected release area.
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4.
IF-300 Cask Contamination Incident a.
Discussion Radiation surveys of three IF-300 spent fuel casks disclosed that smearable contamination levels exceeded DOT /NRC shipping criteria.
Two rail shipments of empty IF-300 spent fuel casks, containing only residual contamination, were received by Nebraska Public Power District on July 28 and August 19, 1986.
Each rail shipment contained two empty IF-300 casks which were in transit from GE Morris Operations, Morris, Illinois, to Nebraska Public Power District's (NPPD) Cooper Station at Brownsville, Nebraska.
On July 28, 1986, after making a smear efficiency determination on cask No. IF-301, NPPD discovered that four of thirty-two smears indicated that the cask was contaminated (non-fixed) in excess of the NRC/ DOT limit.
Upon receipt of the next rail shipment on August 19, 1986, NPPD determined that two of forty smears on cask No. IF-301 and two of forty smears on cask No. IF-302 again indicated cask contamination levels in excess of the NRC/D0T limit.
The removable contamination apparently built up due to contamination leaching from the cask external surfaces, which had become contaminated when the casks were immersed in spent fuel pools for loading / unloading.
The three contaminated casks were not covered with plastic, took about six days in transit, and were visibly dirty from diesel and/or road grime. Historically, factors of time, thermal cycling, scrubbing action of winds, and wetting and drying cycles all appear to contribute to the conversion of fixed contamination to form removable contamina-tion. The excessive diesel / road grime apparently contributed to the problem by reducing the smear efficiency and possibly affecting the conversion rate. Although not suspected for these casks, it is possible that some of the surface of the casks may have been missed during cleaning before shipment.
b.
Cask Contamination Surveys The inspector interviewed the Radiation Protection and Chemistry Supervisor from NPPD, reviewed shipping papers of the casks and discussed concerns with the Region IV USNRC Senior Resident Inspector at the Cooper station.
Following are the smear survey data which exceeded the NRC/D0T removable contamination limit.
In some cases the smear results values are calculated values which were received verbally from NPPD on October 21, 1986. All values were calculated from the original data using an instrument conversion factor for Cs-137, which is characteristic of contamination at GE Morris. (The highest value using a Co-60 conversion factor is 122,000 dpm/100 cm.)
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Date Cask No.
Smear Results July 29, 1986 IF-301 4 out of 32 smears exceeded the limit
67,559 dpm/100 cm
35,471 dpm/100 cm
29,069 dpm/100 cm
22,971 dpm/100 cm August 19, 1986 IF-301 2 out of 40 smears exceeded the limit.
22,074 dpm/100 cm
27,049 dpm/100 cm IF-302 2 out of 40 smears exceeded the limit.
27,598 dpm/100 cm
32,447 dpm/100 cm Maximum levels of non-fixed radioactive contamination on package external surfaces are specified in 10 CFR 71.89(i).
For exclusive
use shipments, the limit at any time during transport is 2200 dpm/cm.
However, if the surface non-fixed contamination is determined by wiping (smear technique), the radioactivity measured on the wiping material (smear), when averaged over the surface wiped, must not
exceed 220 dpm/cm unless the efficiency of the smear technique is determined to exceed 10%, in which case'the actual efficiency may be 2 surface limit is not taken into account to ensure the 2200 dpm/cm exceeded.
For the smear results noted above, a smear efficiency exceeding 10% could not be demonstrated by the licensee. The licensee therefore violated the requirements of 10 CFR 71,89(i).
(72-001/86002-01)
c.
Licensee's Response to Confirmatory Action Letter GE Morris failed to take adequate measures subsequent to the July 28 shipment that could have mitigated excessive smearable contamination levels for the August 19, 1986 shipment.
Because the licensee failed to take timely action, Region III issued two Confirmatory Action Letters (CAL) to the licensee, one on August 27 and the other on August 29, 1986. GE Morris implemented a more vigorous corrective action program before the final Cooper campaign shipment after the first CAL was issued.
In response to Region III CAL's GE Morris committed to the following actions:
Cask No. IF 304 replaced cask No. IF 302 for the remaining NPPD spent fuel shipment.
The empty casks were/will be covered with 4-mil thick plastic
secured with tape.
The plastic packaging is similar to plastic packaging used successfully during the previous Monticello campaign.
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Cask No. IF-301 was cleaned, allowed to sit three days, surveyed, recleaned, and resurveyed prior to shipment for the remaining NPPD spent fuel shipment.
Each cask was/will be decontaminated to less that 50% of the limits allowed by DOT before shipment.
(Less that 1000
2 dpm/100 cm and average of 500 dpm/100 cm.)
Additional release criteria will be developed based on fixed external surface contamination levels before the Monticello shipments recommence.
Following the steps as listed above, the licensee successfully returned the casks to Cooper on September 2, 1986, for the final
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spent fuel shipment. A subsequent empty shipment in October 1986, during the onsite inspection, successfully arrived at Northern States Power in preparation for the Monticello campaign.
According to licensee personnel, the casks used for the August i
shipment were subjected to additional decontamination washes before
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I the shipment and were not expected to repeat the contamination problems experienced in the July shipment. However, neither the July or August cask shipment was plastic wrapped, even though some preceding casks had been plastic wrapped. Commencing with shipment No. 13, the casks were/will be decontaminated to a new procedure and plastic wrapped.
The new procedure requires that contsmination
smears on outgoing shipments average less than 500 dpm/100 cm, with
a maximum of 1000 dpm/100 cm. To further identify potential non-fixed contamination, the licensee agreed to establish a limit on beta contact reading, maximum of 15 mR/hr, on casks prepared for shipment. At the receiving station additional beta surface measurements will be made in an attempt to correlate high smears and surface embedded (fixed)
c atamination. This procedure will be implemented during the N Nicello (Northern States Power Company) campaign.
Cask shipments were periodically monitored for beta levels during the period January through September 1986.
Unfortunately, the July 28 and August 19, 1986 shipments which showed contamination levels in excess of the NRC/ DOT limit were not measured for beta levels. Data for all other shipments monitored for beta during the NPPD campaign were significantly less than 15 mR/hr.
Although the licensee expects that decontamination efforts for future empty cask shipments will be sufficient to meet NRC/D0T contamination restrictions, they will continue to utilize plastic wrapping as a precautionary measure. This action is acceptable to Region III.
However, the licensee also indicated that they will continue to investigate engineering solutions to reduce the potential for contamination of the cask surface and to improve decontamination efficiency. The engineering solutions investigated will include cask modifications to reduce cask surface area, use of a temporary
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containment device to minimize cask surface exposure to spent fuel pool water, coating of casks to enhance decontamination efficiency, and improved decontamination techniques.
The results of these investigations will be reviewed during future inspections.
One violation was identified.
5.
Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organizational structure, procedure revising and updating, and utilization of audit systems.
a.
Organization Radiation protection staff stability continues to be excellent. On a routine basis, technicians provide coverage during the day and afternoon / evening shifts, and upon request all shifts are covered by radiation protection personnel. The inspector observed that several staff members and the Plant Manager participated in actual maintenance and decontamination operations. Hence, individual doses were minimized.
b.
Reviews and Audits An in-house audit conducted by a Corporate staff member recommended that the licensee emphasize the use of the visitors log for persons entering the basin area. The licensee noted that staff members acting as escorts for visitors are required to wear dosimeters and are responsible for instructing visitors to sign the log sheet.
In other audit concerns, the staff reviewed the Burns Security procedures in support of contract negotiations.
c.
Safety Committee The inspector examined rainutes of the monthly safety meetings held by the Plant Safety Committee and reviewed the committee file on incidents pertaining to safety.
The committee discussed safety improvements for IF-300 cask rail cars.
Apparently, one worker inadvertently walked off the edge of the rail car platform. The licensee noted that rail car platforms are not the same length. The licensee's engineering staff plans to install a safety railing to prevent falls. The worker was not seriously injured.
No violations or deviations were identified.
6.
Radiation Protection lhe inspector reviewed the licensee's internal and external exposure control programs including the required records, reports, and notifications.
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a.
Internal Exposure Control Whole body count results for licensee personnel were similar to those reported in Inspection Report No. 72-001/86001(DRSS).
Results for each individual showed no significant detectable activity. An occasional recount was required for individuals showing external contamination.
b.
External Exposure During the heavy maintenance schedule, the licensee issued a Special Work Permit to cover potential exposures greater than 25 mR/hr to any one individual. As of September 1986, about seven workers had received over one rem exposure for the year. Most of the exposure was received while preparing cask No. IF-304 for return to Carolina Power and Light.
c.
Airborne Releases The inspector determined that in spite of the heavy maintenance schedule airborne radioactive concentrations taken in the fuel basin area were less than 10 CFR 20 limits.
The inspector concluded that personnel exposure levels were kept to a minimum during the licensee's heavy maintenance schedule.
No violations or deviations were identified.
7.
Operations Review The inspector toured the facility and reviewed the status of operations.
Thirteen shipments of spent fuel have arrived at the GE Morris facility from Nebraska Public Power District's Cooper Station since August of 1984.
Region III inspected 10 of the shipments arriving at GE Morris. The campaign was temporarily halted after September 18, 1986, and the licensee is currently performing annual maintenance on the IF-300 casks in preparation for the receipt of Northern States Power Company (Monticello)
spent fuel.
With receipt and storage of NPPD spent fuel the GE Morris fuel storage facility is now at 71 percent capacity. The licensee performed cask decontamination and contamination surveys according to standard operating procedures throughout the NPPD campaign.
On the final NPPD shipment only one of two casks was returned loaded with spent fuel bundles.
Stripped threads on three cask head closure bolts prevented use of the second cask.
Repairs on the cask will take place at GE Morris.
External cask smears performed on empty casks showed contamination levels of less than 2,200
dpm/100 cm before each shipment.
However, measurements performed at NPPD exceeded the NRC/ DOT limit on two occasions involving three casks.
The contamination incident is discussed in Section 4 of this report.
No violations or deviations were identified.
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'8.
Training The inspector reviewed the licensee's provisions for training and periodic retaining of employees, as related to employee work assignments with radioactive and fissionable materials.
A schedule for recertification for Operation Technicians was posted for the following subjects:
IF-300 Cask Handling (Video)
Demineralized Water System
Ventilation System Pertaining to UPS System
LAW Evaporator /LSA Waste Management (Video)
Morris Operation Water System
Nuclear Concepts and Criticality Control
Plant System Winterization Crane Operator Training The Recertification training program is scheduled for the second and third week of November.
Each applicant must pass a written exam to qualify for certification.
Results of the training and exam scores will be reviewed during a future inspection. Open Item No. 72-001/86002-01(DRSS).
No violations or deviations were identified.
9.
Nuclear Safety During the course of the inspection period, June 13 through October 10, 1986, there were no facility modifications or changes, or spent fuel inquiries that required the licensee to perform nuclear criticality safety analyses.
The inspector determined that a monitoring system using gamma or neutron sensitive radiation detectors with audible alarm signals were being maintained in the plant areas where SNM material was stored.
Several standby detectors were available, if needed.
No violations or deviations were identified.
10. Transportation The inspectors reviewed the licensee's nrogram for receipt and/or shipment of radioactive materials. The review included inspection of three (3) incoming rail shipments of spent reactor fuel shipped from NPPD during the months of July through September.
In addition, the inspector observed the licensee's preparation of two empty IF-300 rail cask for return to Monticello Nuclear Generating Station (MNGS).
Smearable contamination levels were less than 1000 dpm/100 cm for the outgoing shipment. Upon
receipt of the October shipment, MNGS determined that non-fixed contamination levels proved less than the NRC/D0T limit.
Except for the violation noted in Section 4 (IF-300 Cask Contamination)
no problems were identified concerning transportation.
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11. ExitMee'M The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the safety inspection on October 10, 1986.
In response to certain matters discussed by the inspector, the licensee:
a.
Agreed to correlate and or evaluate radiation survey data on outgoing empty casks with data compiled by the receiving station.
(Monticello PowerDistrict)
b.
Agreed to establish a beta exposure limit of 15 mR/hr for outgoing empty casks, and a followup of beta evaluations at the receiving station.
The inspectors also discussed the likely infomational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. During the course of the inspection and the exit meeting, the licensee did not identify any such documents or inspector statements and references to specific processes as proprietary.
12.
Enforcement Conference An enforcement conference was held on October P8, 1986, in the Region III office to discuss the circumstances surrounding excessive non-fixed external contamination on three empty IF-300 spent fuel casks, Region III's concerns related to the events, and the identified violation. The meeting was attended by Mr. Jack A. Hind, (Region III) Director, Division of Radiation Safety and Safeguards, Mr. E. F. Voiland, Plant Manager, General Electric Morris Operation, and members of their respective staffs.
The licensee was informed that the incident was being considered for escalated enforcement action because the non-fixed radioactive contamination exceeded NRC/ DOT limits and because the licensee failed to initiate immediate corrective actions after the July shipment. The licensee disagreed that immediate corrective actions were not taken in that subsequent to the July shipment, workers were verbally instructed to increase their efforts in cask cleaning measures. However, the licensee acknowledged that it was an error in their judgement to not cover the casks (involved in both the July and August shipments) with plastic. The licensee noted that plastic covering of the casks prevents a build up of road grime on the external cask surface and thereby apparently decreases the conversion rate from fixed radioactive contamination to non-fixed contamination.
In attendance at the meeting were:
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U. S. Nuclear Regulatory Commission J. A. Hind, Director, Division of Radiation Safety and Safeguards L. R. Greger, Chief, Facilities Radiation Protection Safety B. W. Stapleton, Enforcement Coordinator G. M. France, III, Fuel Facilities Inspector General Electric Morris Operation E. E. Voiland, Plant Manager, GE Morris Operation T. E. Ingels, Manager, Quality Assurance and Safeguards R. G. Damm, Senior Engineer, Licensing and Radiological Safety S. P. Schmid, Specialist, Field Services
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