IR 07200001/1990001

Insp Rept 72-0001/90-01 on 900212-14,0530,31 & 0601. Violations Noted.Major Areas Inspected:Review of Licensed Activities,Including Mgt & Organization Controls,Radiation Protection Program & Operations Review

ML20059D894
Person / Time
Site:	07200001, 07001308
Issue date:	08/29/1990
From:	France G, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059D884	List: IR 07200001/1990001 ML20059D883 ML20059D886
References
72-0001-90-01, 72-1-90-1, NUDOCS 9009070221
Download: ML20059D894 (10)

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,-n U.S. NUCLEAR REGULATORY COMMISSION?

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Report No.- 72-001/90001(DRSS)

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f Docke't No.72-001

' License No. SNM-2500

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Lice'nsee:

GeneraiElectric5 Company j'

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175 Curtner' Avenue

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San Jose,'CA 95125

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Facility Name:_ Morris'0peration

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Mo'rris Operation, Morris Illinois.

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Inspection At:

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a Inspection Conducted:

February :12-14, May330, 31 and, Junf 7 M0-

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Inspector: kM. France,III i,[;

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roject c2f 9 Director, Fuels-Facilities.and-Date Contaminated ~ Sites

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--Inspection Summary

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A Inspection on February 12-14, and May 30, 31'and June 1, 1990'(Report {

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No. 72-001/90001(ORSS))

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Areas Inspected: = Routine,, unannounced safety inspection to review NRC

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licensed activities, including: = management'and organization controis-r A

(IP 88005); radiation protection-program (IP 83822);; operations re~v.iew

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and-rstriining -(IP 88010); transportation of radioactive materials 1(IP 86740)N, (IP ~88020); maintenance and surveillance testing (IP 88025); 'operatorm trainin x

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, environmental protection (IP-88045); emergency' preparedness':(IP'88050);

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radioactive waste management (IP.88035); criticality, safety (IP 88015);

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_ ; and inspection,of waste: generator requirements of :10 CFR 20 and.10: CFR 61

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-(IP;84850).

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Results:

Two apparent violations were identified. 20ne violat

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failure :tolfollow prmdure led to the: violation of a limiting: ion was"the 4 c

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condition

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'(Secti o~n' 6). (Thk m 1ation was noticited at the NRCts discretion per?

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U 'r 4,{10 CFR'2,-Appcm a section G,, since'the: licensee took ' timely. action

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and returnhd og jlimiting parameter.to'the proper operating model

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) violation.we.r the.f iiew to sign the special work procedure prio,' A;second 3

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p. enteringia u.diatt a area (Section 4).

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DETAILS 1.

persons Contacted (IP 30703)

• L. L. Denio, Manager, Plant Services J. W. Doman, Manager, Operations Program

• T. E. Ingels, Morris Operation Manager

• J. D. Kosman, Mant ger, Plant Operations and Maintenance J. McGrath, Safety and Security Engineer A. Shorkey, Operations Engineer

• Denotes those present at the exit meeting on June 1, 1990.

2.

General This inspection was conducted to examine licensee activities under Special Nuclear Materials License No. SNM-2500, with emphasis on the status of operations and the radiation protection program. Also examined were the actions taken by the licensee to return the spent fuel basin water chemistry to the normal operating range after a limitine condition was exceeded. A citation w s issued for a procedural violauon; failure to sign a special work procedure.

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Management Organization and Controls (IP 88005)

The inspector reviewed the licensee's management organization and controls for operations, including changes in the organizational structure and staffing. A review of safety committee activities were also conducted.

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Organization l

l The Manager of the Operations Program responsible for fuel storage operations, control room functions and operator training has resigned.

The conceptional design engineering and coordination of special studies normally assigned to this. position were reassigned to the Manager, Plant Operations and Maintenance. The managerial and training responsibilities of this position were assigned to the

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Operations Engineer, which is a new pcsition filled by a former Shif t Supervisor. According to Amendmer.t 7 (February 15,1990)of the license (SNM-2500) only four members must be present to conduct the business of the Plant Safety. Committee. The licensee noted that the Operations' Engineer will also replace the~ Marager, Operations Program u a member of the Plant SaNty Coumittee, which consis's of six members. While the above staffi m a'rangement appears to be adequate-for performing the tasks regiired in monitoring the spent fuel basin, the inspector recrmmendel that the licensee notify the NRC headquarters office for a potential license-amendment.

Since the previous inspection (72-Oh/89002), two production operators were recalled from lay-off status and reassigned tc duties that support control room and fuel storage activities.- The l-

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the licensee stated that with the above assignments, the G.E. Morris facility will continue to maintain an operating and security force l

comprised of 26 members.

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Safety Committees The inspector verified that

'r +v meetings were Seld within the 45 a

day interval as required by the iicensee.

Specific topics related i

to basin water integrity and replacement of the :S.9/ cation resin were discussed.

No violations or deviations were identified, l

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Radiation protection 'IP v3822)

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The inspector reviewed the licensee's internal and external exposure control programs including the required records, reports, and-i notifications, a.

Internal Exposure Control Results of gamma spectroscopy analysis of 38 urine samples collected for the January thragh April 1990 operating. period indicated that the highest concentration of radioactivity was reported in three samples with cesium-137 concentrations of 212 to 283122 picrocuries per liter; and two samples exhibiting a cobalt-60. concentration of 294 to 312 126 picrocuries per liter. These concentrations are equivalent to 1 to 2% of MPBB-(maximum permissible body burden) for cobalt-60 and less than 1% MPBB for' cesium-137; no significant

.i problems were noted, q

Based on discussions summarized in Inspection Report No. (72-001/890002) on November 15, 1989, the licensee spiked a urine sample with 294 4 picocuries per liter of cobalt-60 and submitted the sample to a contractor as part of the quarterly bioassay program. The contractor's result agreed to within 5% of the control sample concentration supplied by the licensee.

Whole body count results were reviewed for operations and maintenance personnel for the 1989 operating period. On

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October 12, 1989, the whole body count performed on G.E. Morris workers showed levels of cobalt-60 and cesium-137 that were i

less than 1% of MPBB (11 nanocuries. Cobalt-60; 300 nanocuries cesium-137).

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. b.4 External' Exposure Control

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Fiv'e TLDs were exp"osed tollevels~ of 70 to 280 millirem and submitted,

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to a vendor as controls M The data indicated that the-vendor's q

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- results' were within 10% o'f.the exposed TLD levels.

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W6rkers assigned to'the-basin areaiand the. cask receiving area are-i d

J..h issued TLDs and self-reader, dosimeters (SRDs).

SRD doses are i ij i

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recorded daily, while TLDst are analyzed through a vendor monthly

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exchange program., The highest exposure; assigned to an individual i

for the first quarter 1990 was 210. millirem (February 1990).

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Regulated Work Procedure /Special Work Procedure-(RWP/SWP)

The licensee ~ posts ' regulated; work = procedures (RWP) for routine tasks parformed in radiation. areas.-

In the event that unusualitasks

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are performed,:*he work is covered by a special work procedure;(SWP), '

The. safety manual ' specifies actions to protect the health 1and -safety,

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of employees, a Standard Operating Procedures (SOP) and/or' Morris:

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. 0perations; Instruction (MOI)'are other categories of procedures used

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to' implement these' actions'for. protecting the safety of; employees.

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UndeFM01-909' Revision 5,.Section 4.2, all personnel: authorized to

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perform the work must also sign the'SWP. showing acknowledgement of..

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conditiuns and safety' requirements before' starting _ work.~

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During the weekYof January 7,1990, maintenance workers = performing

assignments under: SWP-90-08-04, 01/08/90,Lwere inspecting the.

. rad-waste evaporator V-580 system flangesLfor, air-water leaks.

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' The:SWP coveredithe January 8-12, 1990, operating period. Workers

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entered _and leftsthe location of the evaporator astthe tasks

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required? 'According to the= control room-log, the maintenance

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manager entered the work location,- but failed to sign the 'SWP prior-to his initial, entry.- The4 inspector determined that the maintenance manager's failure to sign the'SWP violated M01-909, j

Revision 5, which requires all! personnel to acknowledge _(by.

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signature) conditions and safety requirements before~ starting work.,,

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ALARA

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/4 The slicensee performed severaltoperations that follow-good ALARA-

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f practices._ 5 The. radiation >1evel'around the evaporator i(heat a'**

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exchanger) was about 700 milliroentgens/ hour (mR/hr);' The licensee:

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succeeded in reducing >the tradiation levels of ~ the' evaporatorisur. face F.

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y from_ nearly 700 mR/hr t'o' 40 mR/hr.

This was accomplished with,a J t

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. ' series of flushes with acetic acid.? A~(PWR' basket) waste insert foi

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.the IF-300 cask is a source _of exposure at 2 mR/hr. < Handling of the: i (

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PWR basket' generally. exposed ~ licensee. personnel'to 60 mR/hr per;.

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Hence,-the decision.was madecto transfer the, basket *to'ther +

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ibasin pool'for underwater storage ~, thereby mitigating tha exposure.

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l0ne violation was identified.

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. 5, 10peration Review (IF 88020)

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Cask Activities

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Currently, two IF-300-casks are being serviced a'nd/or stored at-the GE Morris Operations facility.

The casksiare normally used

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for waste'shipmenes by. Pacific Nuclear,or other licensees.

The-contamination levels = (smear results) on the ' cask surface must neet, 3 '

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the licensee's limit of 500Ldpm/100 cm2 prior to release.

During the.y

course of this inspection, cask numbered IF-301 was being prepared'fori offsite shipment.

Both.inside' cavity and outside surfaces had been

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-decontaminated and the. coo.lant.(ethylene glycol) had.been drained-and monitored for contamination..In' addition,sthe' licensee had serviced the cask in accordance.with annual maintenance requirements. -In order.to complete the~ preparation of'the cask for handling at'another~ site;'GE M0 also decontaminated one backup or redundant yoke and~one standard yoke,jThe inspector' observed that

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after the surface contamination was removed, the yokes were

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repainted and' prepared ~for shipment.

Based upon review of-the

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survey 1 sheets, the inspector determined (that.the licensee met the

release requirement'for surface contamination, i

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Basin Activities.

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The licensee has not received any spent fuelLshipnients since

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. January 26, 1989.s -Irradiated fuel bundles ~are stored.in authorized.

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1 fue,1; storage baskets under a minimum"of 9 feet-of water (abovefthe

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zuppermost top of'the' fuel; bundle).

The major-activity forTthel

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licensee is to maintain the basin and basin water quality to prolong

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the fuel storage. The specific limiting'conditi.o'ns?and surveillance'

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f requirements for basin water quality are discussed in Section 6,

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i-Maintenance Surveillance.

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Notviolations or deviations were ide'ntified.

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MaintenanceSurveillanceMsts(IP88025)

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j The inspector:revi,_w..e ed the results of:the surveillance' tests required by J

the' Technical;Specificatior.s of Appendix' A to License No. SNM-2500.'

The h,

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1, required ~ measurements of basin, water.: quality, basin 71eak rate and V

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operability,. criticality.monitoi's, and stack" effluent ai'r,were made at :

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.the specified frequencies. 20ff-standard ccnditions were:either recorded -

fu a"in the' operator log and/or were referenced in theilicensee'.s unusual'

ev.ent : fil e~.

The most signific' ant finding was the loweringTof the pH in.

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the: basin water. caused'by the inadvertent, routing of acidified water from H

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.thef demineralizer to the basin.

The1 basin water chemistry is usually l?

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maintained'between pH 4.5 and 9.0.

The acidified water lowered the pH P

L to 4.2 and violated.the limiting condition.

Although no.tiaireportable

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event, the lic'ensee notified Region III via telephone in December 1989 l

and' issued Operation ~ Alert 89-1.;(listed below) which describesithelevent

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and follow-up action taken byithe: licensee.

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Operation Alert 89-1 Narrative a

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On the morning of December 1,1989,'a mainier,ance tech installed a strainer on P831-1 demineralized water transfer pump shaf t seal coolant / flush line.

The tech closed Valves V6 and V7 in order to isolate the pump. ;When finishing the job, the tech opened Valves V6 and V7, and seeing V5,_which is located next-to V7,' closed, decided he must have~also closed this-valve.

He opened V5 at this time.

He worked from approximately 9 to 10 a.m. on this job.

Between 9 and 10:30 a.m., operations was adding water to the basin.

On the morning of D'ecember 4, secon'd shift, a routine sample of basin water was taken and checked for pH.~

No significant change in pH was noticed.

On December 7, a routine sample of basin water was taken and; checked for pH.

At this~ time the low pH was seen.

A second sample was taken on December 17 and it also showed a low p't.

On December 8 the December 4 sample of basin water was recheckea and thisi time it also showed a low pH..The Morris License SNM-2500 requires the basin pH to be between 4.5 to 9.0.

The December 7 pH was less than 4.5 so the. Plant Safety Committee (PSC) was notified.

Conclusion g

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On December 1,1989, between 10 and 10:30, because valve V5 was open,' low

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pH water was added to the basin.- On December 4, 1989, because valve V6 was still open, low pH water was a'ain'added to the basin.

Approximately g

1500 gallons total of the low pH water was added to the basin.

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Filter rebuilt 12/5/89'

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Plant Safety Committee meeting 12/7/89

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Addition of anion resin _-12/8/89 (5#)L

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Additi.,on of anion resin 12/11/89 (12-1/2#)1

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Filter rebuilt 12/14/89' (A special resin bed was used this

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' time - 60'lbs of Anion, 25 lbs of Cation, and 4.4 lbs:of-

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Zeolon-100)

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On December 28 the filter was again rebuilt with 05e special

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resin mix' ratio.

_ Recc.amendations

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r Lock Valves V4 and V5 closed.

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. Request the operation tech'who is the assigned roundsman for the. shift

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, to' perform any valve alignment required for maintenance work. "

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,In accordance with Appendix 2, Technical Specifications, License

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No. SNM-2500, Paragraph 6.5.2 Limiting Conditions the licensee complied with the following requirements:

Assure timely return of operations to specification

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compliance.

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Advise the NRC during i.he next i.gection of events C

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resulting in limiting condition being exceeded.

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The inspector reviewed 50P No. 8-6 Spa *ing of Demineralized Water Booster-Pum, dated June 23,:1987, and the revised version dated January 15,

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The revised procedure instructs the. operator or maintenance

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technician to lock Valves V4 and V5 to prevent-the pumping of low pH water to the boiler system or.to the fuel storage basin.~ The<following

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precautionary note was added to the procedure:

Remove "00 NOT OPERATE"

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tags as valves are. returned to'their' normal position.

Figure-1 of the procedure was also modified to show the valve." locked /ciosed" position.

The inspector observed thatLthe' locking mechanism for Valves V4 and V5 a!'e in place.

The inspector; also confirmed by records review and observation that the; basin water! chemistry tested within the technical-parameters and that the basin water leve, was located at the appropriate fill-level (nine feet above the uppermost top-of the fuel bundles).

Both the 1987 and 1990 version of the procedure.(SOP 8-6) indicated the following:

This procedure.will cover the proper valving sequence to

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be performed..To prevent upsets in the demineralized water-system ar.d boiler operation, the valving must be done correctly.

Section-3.

Valving Required,.Line 3b. of the procedure instructs the operator / technician to close Valve V5. - Contrary.to' this instruction

.(1987' version)-the maintet.ance technician opened Valve _V5 and-accidentally discharged acidified water into basin water causing the l

pri concentration to exceed the limiting condition.

This abnormality persisted in 16 of 36 samples analyzed between the November 20land i

December 18, 1989, operating period.

The basin water quality was t

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I restored ^af ter several treatments with the rebuilt resin.

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l It appeared that the licensee. acted promptly:in.not'ifying the Regibn, in

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documenting the event as required by the' license (SNM-2500), installing

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engineering controls, modifying the procedure, and requiring that an r

operetor roundsinnn' e present to assist maintenance in the proper valving

u sequence;to isolate systemLcomponents.

These actions should prevent a J

y recurrence of. the unrJanned event; However,.the licensee noted that the'

water. chemistry can'c.iange due.to degradation of the resin.

Nevertheless, l>

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.the inspection findings supports the-licensee's initiative forl identifying

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and correcting the problem.'" hence,,an exercise of-discretion, ast

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. described in 10 CFN'Part 2, Appendix C,' section G of 10 CFR Part 2'is in,

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order. and no violation-will be issued.

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. One violation was identified.

Discretion was declared and no violation

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was 'ssued.

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Criticality w 88015).

Tlie~ inspector o: nerved the licensees performance in testing the ef fective.

range-of the criticality alarm through out-the plant. site._ No evacuations'were required.

The' test team' consisting of five members responded to the control room from theirL respective locations in an j

expeditious manner.

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There has been no' fuel movement since the licensee' completed the storage

.of fuel received in-January 26, 1989.- In the event.that fuel storage

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contracts are terminated, the licensee would retrieve the fuel from the-

~ basin under current criticality guidelines which allows.the. movement of only one bundle at a time.

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No violations or deviations were Identified.

8.

Emergency Preparedness-'(IP 88o50)-

Discussion with' licensee personnel indicated that' plant evacuation drills-are held in, order to test the ability of personnel to evacuate to the assigned assembly point (completed November 3, 1989).

Emergency' equipment including fire fighting equipment and safety lights are periodically inspected for? operability.

During 'one such check 11t was-determined that an emergency light'.was inoperable because of a moisture problem.

This item was promptly replaced.

The licensee indicated that-no damage occurred on April 24,1990. when the commercial power feed was

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lost.

Apparently, the power failure was.of short duration and did not'

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affect the start up of the emergency generator.

Consequently,.there sas-

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noAnterruption.of. service to safety alarms'and/or-air monitors, y 9'

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,No diolations or deviations were identified.

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if w N i9j jRadioactive1WasteIianagement(IP;88035)~andInspections.ofWaste

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p,' Generator Requirements of 10 CFR'20 and 10 CFR 61-(IP 848501

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'The inspector reviewed the licensee's program for' waste generatiokin '

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r accordance with requirements of-10 CFR-20 and 10 CFR 61 applicable toj

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~1oW level radwaste form, classification, stabilization, and-shipmenty,,

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l manifest.

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sin accordance with 10 CFR 20.311, the licensee maintains a manifest for y n

all waste shipments.

On December 1, 1989, the licensee shipped.

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450 cu. ft. of. solid radioactive waste to a vendor for volume. reduction?

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by compaction. : Waste compaction _usually results in a volume 1/3 the

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. input volume., Radioactive waste thatiis normally prepared-for volume l

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' reduction usu'lly consists of contaminated plastic, paper, wood'and.

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metal.

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The classification of'redionuclides is usually based on;th'e licensee's'

i analysis of samples of_ resins.

Shipping manifest'for the last'

quarter 1989_wastefshipments indicated that radioactive' waste is y

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classified in accordance with 10 CFR 61.55.

The concentration of

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radionuclides contained in. radioactive u ste at-GE M0.is comprised of-mostly nickel-59, -63; cobalt-60; and cesium-137; along with smaller

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concentrations of cesium-135 Fiodine-129;'ahd plutonium-241.- From the records of three shipping manifests _, the total nuclide1 concentration

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ranged from 527 to 1740 millicuries. ;0ther than a typing error (symbol; for manganese 94 tristakenly inserted for niobium 94).the papers appeared.

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No violations or deviations were identified.

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>a 10.

Tr'ansportation' of' Radioactive Matei0ials (IP 86740)l

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^ The' inspector reviewed the" licensee's transportation activities to a"

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... determine whether the licensee is' maintaining an adequate program to

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e assure radiological safety in -the1 receipt,. packaging, and delivery of

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licensed radioactive' materials.

No' discrepancies other(than a..

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, t'yping error were found in'the licensee's shipping records:(last _

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quarter 1989).

The inspector determined that the' shipping records

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(transportation activities) were traceable to. sign-offs-(checklists) -

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performed by. persons assigned to thr quality assurance department.-

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y The inspector noted that theulicensee1should review 10 CFR 71.137

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Auditsn and expand their program to assure _that~ audits'of-

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transportation activities are;pe_rformed'by appropriately traine'd

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personnel not'havingzdirect responsibilities in the' areas being.

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oudited.

The Manager, Plant-Services'who supervises the qua'lity assurance program indicated: thatithh matter would.be reviewed.

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No violations'or deviations were identified.- However, one concern, the

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dicensee's adequacy to perform transportation audi,ts,jwas noted.'

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11. : Operator Training / Retraining (IP 88010)

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The-inspector reviewed the' licensee's training progra for. requali fying s

operators. Two operators (on reduced work force status) were returned--

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to their previous, employment-status during the 1989 operating period.

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In order to requalify at plant operators and/or service l technicians,.,

the workers completed the health and safetyLtraining 'or' safety _"A".

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certification, control room monitoring and.on: shif t tnining _ for, roundsman duties., The operators _are provided a'udio visual. instructions for self-study and must also demonstrate a proficiency level by work "

performance and by written examination.

The inspector observed / interviewed-one of the operators' performing control room; monitoring tasks and' concluded that the; operator demonstrated the understanding required to perform and

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document results of routine surveillance testst No violations or deviations were identified, y

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12.

Environmental Protection (IP 88045)

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The inspector observed that the ' licensee completed an EPA requirement,to 1.-

excavate an underground diesel fuel' tank,' - The tank is now stored in an

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approved above ground facility that is' diked for spill control and covered.

l for protection against.the weather.

1 In past operat'.as the acid and base waste streams discharged 'com the

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anion and cation resin units were not proper.ly mixed or neutralized until

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defined this operation as,n;the evaporation pond.

after a settling period i The EPA.apparently

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a treatment, pond and for compliance the streams-must be neutralized'or fall within:the limiting condition of the pH range

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prior to' discharge.

On' that basis, the licr see prepared an aboveground l

. tank for collecting and mixing the streams 1 the limiting pH range for-subsequent discharge.

The radionuclide concentration of the' mixture is

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also monitored and subsequently met'the release limits'of.10 CFR 20.

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No violations or deviations were identified.

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13.

Exit Meeting

.T'e# scope and findings ~of the inspection were discussed with licensee

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. representatives (Section 1) at the close of-the onsite inspection on

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! June'1,1990..The following matters were discussed:

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m I a, tit"wasLnoted that thA licensee is' reviewing 10 CFR 71.137

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(Transportation Activiti Audits) to assure compliance.

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. (Sec. tion.12)

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b. : iThe; inspector: acknowledged that the licenseeiidentified and

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corrected the' problem that> caused the'pH of,the basin water f'

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> :to exceed the " limiting condition."- (Section_6)

w A violat' ion is' pending. for failureIto sigh a..!' work permit" prior to.

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• L entering a designated radiation area. -(Section-4)

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The licensee will submitLrecent staff changes to'DIMNS.for potential

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license amendment (review).

Duringthecourseofthe_inspectionandthe'exitmeeting,the' licensee did not identify any documents or references'to specific processes as'

proprietary.

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