IR 07200001/2018001
| ML18325A200 | |
| Person / Time | |
|---|---|
| Site: | 07200001 |
| Issue date: | 11/21/2018 |
| From: | Michael Kunowski NRC/RGN-III/DNMS/MCID |
| To: | Mcfadden A GE-Hitachi Nuclear Energy Americas |
| Learn M | |
| References | |
| IR 2018001 | |
| Download: ML18325A200 (13) | |
Text
ber 21, 2018
SUBJECT:
NRC INSPECTION REPORT 07200001/2018-001(DNMS) -
GENERAL ELECTRIC-HITACHI MORRIS OPERATION FACILITY
Dear Mr. McFadden:
On October 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the General Electric-Hitachi Morris Operation Facility in Morris, Illinois. The purpose of the inspection was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements. Specifically, the inspectors evaluated your emergency preparedness program, environmental monitoring and radiation protection programs, quality assurance program, surveillance and maintenance program, and training program. At the conclusion of the inspection, the results were discussed with you at an exit meeting on October 30, 2018.
Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, interviews with personnel, and observations of activities in progress.
Based on the results of this inspection, the inspectors did not identify any violations of significance of NRC requirements.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-rm/adams.html. We will gladly discuss any questions you have concerning this inspection. If you have questions, please contact Mr. Matthew Learn of my staff at 630-829-9603.
Sincerely,
/RA/
Michael Kunowski, Chief Materials Control, ISFSI, and Decommissioning Branch Docket No. 07200001 License No. SNM-2500 Enclosure:
Inspection Report 07200001/2018-001(DNMS)
cc w/encl: B. Lockwood, General Manager GE-Hitachi Nuclear Energy, Services Operations S. Reynolds, Head Resident Inspection Illinois Emergency Management Agency State of Illinois
EXECUTIVE SUMMARY
GE-Hitachi Nuclear Energy Americas, LLC
Morris Operation NRC Inspection Report 07200001/2018-001(DNMS)
The inspection consisted of observations of site activities and an evaluation of the licensees programs including radiation protection, surveillance and maintenance, emergency, preparedness, environmental monitoring, training, and quality assurance.
- The licensee established and maintains its emergency plan in accordance with applicable regulations, the License, and Technical Specifications. (Section 1.1)
Radiation Protection and Environmental Monitoring
- The licensee established and maintained its environmental monitoring and radiation protection programs in accordance with applicable 10 CFR Parts 20 and 72 regulations, the License, and Technical Specifications. (Section 1.2)
Quality Assurance
- The licensee was conducting audits, Safety Review Committee meetings, corrective actions, and procedural changes in accordance with the Technical Specifications, regulatory requirements, and applicable site procedural requirements. (Section 1.3)
Surveillance and Maintenance
- The licensee implemented its surveillance and maintenance program in accordance with applicable regulations, the License, and Technical Specifications. (Section 1.4)
Training
- The licensees training program complied with the requirements of the applicable regulations and the License. (Section 1.5)
Materials Control and Accountability
- The licensees material control and accountability program complied with the requirements of the applicable regulations and the license. (Section 1.6)
REPORT DETAILS
1. Away from Reactor Independent Spent Fuel Storage Installation (ISFSI)
(Inspection Procedure (IP) 60858) 1.1 Emergency Preparedness
a. Inspection Scope
The inspectors reviewed the General Electric-Hitachi Morris Operation (GEHMO)
Emergency Plan, observed the biennial emergency exercise, and reviewed the licensees post-exercise assessment.
b. Observations and Findings
The GEHMO Emergency Plan was revised on August 21, 2014, and as such there have been no significant changes to the Emergency Plan since the last routine inspection on September 21, 2016 (ADAMS Accession No. ML16286A291).
Section 8.5 of the GEHMO Emergency Plan requires the licensee to perform a biennial exercise to demonstrate emergency response capabilities and effectiveness of the Emergency Plan. The scenario for the October 30, 2018, exercise involved a simulated contaminated injured worker and a simulated radiological spill. The inspectors reviewed GE Morris Operation Emergency Plan and Drill Report, dated August 4, 2016, which discussed the drill and assessed the licensees performance. The inspectors reviewed quarterly drill records.
No findings of significance were identified.
c. Conclusion The licensee established and maintained its emergency plan in accordance with applicable regulations, the License, and Technical Specifications.
1.2 Radiation Protection and Environmental Monitoring
a. Inspection Scope
The inspectors reviewed the licensees 2016 and 2017 Environmental Operating Reports, submitted as required by 10 CFR Part 72 and Technical Specification 8.2.1, to verify the maximum potential doses to a member of the public were below the 10 CFR 72.104 limits. In combination with the Environmental Operating Report review, the inspectors evaluated the site boundary thermoluminescent dosimeter (TLD) values for 2016 and 2017 to verify the value reported in the Environmental Operating Reports and that the TLD results were consistent with site radiological conditions. The licensees Environmental Monitoring Program was also reviewed to determine the adequacy of the licensees method of determining the maximum public dose. In addition, the inspectors reviewed site occupational dose data for calendar years 2016 and 2017 to verify all doses were under the limits in 10 CFR Part 20.
b. Observations and Findings
The licensees Environmental Monitoring Program defines the methodology for determining the maximum potential public dose at the site fence from direct radiation.
This process uses the most conservative TLD value from each quarter and an occupancy factor for a member of the public at the site fence. The inspectors determined that the TLD values were consistent with site radiological conditions.
The inspectors determined the 2016 and 2017 Environmental Operating Report values for maximum potential dose to a member of the public from direct radiation were consistent with the Environmental Monitoring Program methodology using the most conservative TLD value. This value, when combined with nearly negligible effluent release dose values, was well below the 10 CFR Part 20 regulatory limit.
The inspectors determined that the occupational doses for radiation workers for both 2016 and 2017 were consistent and reasonable when evaluated against the work performed by site personnel, and well under the regulatory occupational dose limits.
No findings of significance were identified.
c. Conclusion The licensee established and maintained its environmental monitoring and radiation protection programs in accordance with applicable 10 CFR Part 20 and 72 regulations, the License, and Technical Specifications.
1.3 Quality Assurance
a. Inspection Scope
The inspectors reviewed the licensees audit, Safety Committee, and corrective action programs, as well as the most recent audit report and minutes from the Safety Committee meetings. The inspectors reviewed corrective action reports from 2017 and 2018 to determine the licensees effectiveness in identifying, resolving, and preventing problems. The inspectors also reviewed a sample of procedural changes from 2017 and 2018 to verify compliance with the applicable regulations and site procedural requirements.
b. Observations and Findings
Technical Specification 6.4.2 requires audits to be conducted in accordance with GE Nuclear Energy Management procedures. Morris Operation Instruction (MOI) 702, MO Internal Audits, is used for guidance on conducting audits. Two audits had been completed since the last NRC inspection.
The Safety Committee and its function are specified in Section 6.4.1 of the Technical Specifications and in MOI-904, Safety Committee. The safety committee is required to meet every 45 days and with a minimum of three members. The function of the Committee is to review plans, procedures, and operations involving the elements of radiological safety prior to implementation. A sample of meeting minutes since the last inspection was reviewed. The minutes indicated that the Committee: met monthly; always contained the required number of members; reviewed site activities involving radiological safety; and reviewed monthly employee dose reports.
A sample of corrective action reports from 2017 and 2018 reviewed by the inspectors identified that the licensee was effective in identifying, resolving, and preventing problems.
The licensee performed three 72.48 applicability analyses for changes, tests, and experiments since the last inspection. The inspectors determined the licensee performed the change and associated applicability analysis in accordance with its 72.48 program and the determination that no 72.48 evaluation was required was consistent with the applicable site procedures and 10 CFR Part 72 regulations.
No findings of significance were identified.
c. Conclusion The licensee was conducting audits, Safety Review Committee meetings, corrective actions, and procedural changes in accordance with the Technical Specifications, regulatory requirements, and applicable site procedural requirements.
1.4 Surveillance and Maintenance
a. Inspection Scope
The inspectors reviewed the licensees surveillance and maintenance program associated with wet fuel storage to verify compliance with the applicable regulations, Technical Specifications, and applicable site procedures. The inspectors walked down the spent fuel basin (SFB), observed preventative maintenance activities, interviewed personnel, and reviewed select documents.
b. Observations and Findings
During the walk down of the site and SFB, the inspectors noted the radiological controlled areas to be generally clean and free of dirt and debris, and adequately marked and posted as required.
In accordance with Technical Specification 4.4 requirements, the licensee performed operability checks and calibration of the basin leak detection system. The basin leak detection system was used to provide indication of a leak in the spent fuel basin liner.
The test consisted of the verification of the pumping capability of the system and turning the alarm unit setpoint down to the current leak detection level causing the alarm to activate. The inspectors evaluated the documentation provided for 2017 and 2018.
The current leak rate was approximately 150 gallons per day.
To meet Technical Specification 4.1 requirements, the licensee used Standard Operating Procedures (SOP) 16-84, Exhaust Sample Analysis - Compliance Test, Revision 17, to collect effluent air samples between the main stack and the sand filter on a weekly basis to measure activity in the air leaving the sand filter for environmental monitoring purposes. The inspectors evaluated the documentation provided for 2017 and 2018; all activity values were below those specified in the applicable site procedure and Technical Specifications.
To meet Technical Specification 4.2 requirements, the licensee used Standard Operating Procedure (SOP)16-100, Effluent Water Analysis - Compliance Test, Revision 22, to collect water samples of the sanitary lagoons on a monthly basis to measure activity in the water for environmental monitoring purposes. The inspectors evaluated the documentation provided for 2017 and 2018; all activity values were below those specified in the applicable site procedure and Technical Specifications.
To meet Technical Specifications 4.3 requirements, the licensee used SOP 16-110, Sealed Source Inventory and Leak Check - Compliance test, Revision 16, to leak test sealed sources on a quarterly basis. The inspectors evaluated the documentation provided for 2017 and 2018; all leak tests results were below those specified in the Technical Specifications.
To meet Technical Specifications 4.5 and 4.6 requirements, the licensee used SOP 16-10, Basin Water Analysis - Compliance Test, Revision 17, to collect SFB water samples on a monthly basis to measure the conductivity and activity in the water to ensure adequate aging management. These values were monitored in order to maintain a benign environment for fuel and equipment stored in the SFB. The inspectors evaluated the documentation provided for 2017 and 2018; all conductivity and activity values were below those specified in the Technical Specifications.
The licensee used SOP 16-97, Criticality Alarms Operability - Compliance Test, Revision 15, and SOP 16-98, Area Radiation Monitor Calibration - Compliance Test, Revision 21, to partially fulfill Technical Specifications 4.4 requirements. Technical Specification 4.4 states that systems and equipment shall be tested for operability and calibrated at least once during the intervals specified in Table 4-2.
Table 4-2 states that criticality monitors shall be operability tested on an annual basis and calibrated on a quarterly basis. The inspectors determined that the licensee performed criticality monitor surveillance in accordance with Technical Specification 4.4 and Table 4-2.
Table 4-2 states that area radiation monitors shall be operability tested on a quarterly basis and calibrated on a quarterly basis. The inspectors determined that the licensee performed area radiation monitor surveillance in accordance with Technical Specification 4.4 and Table 4-2.
No findings of significance were identified.
c. Conclusion The licensee implemented its surveillance and maintenance program in accordance with applicable regulations, the License, and Technical Specifications.
1.5 Training
a. Inspection Scope
The inspectors reviewed the licensees training program.
b. Observations and Findings
The inspectors reviewed the training program as well as the qualification records of Operations personnel. MOI-155, MO Training, and MOI-606, MO Training Program, were reviewed as well as a sample of qualification records for plant staff. The inspectors verified that all operators met the required training requirements.
No findings of significance were identified.
c. Conclusion The licensees training program complied with the requirements of the applicable regulations and the License.
1.6 Materials Control and Accountability for ISFSIs
a. Inspection Scope
The inspectors reviewed the licensees materials control and accountability (MC&A)program. The inspectors reviewed licensee documentation to resolve unresolved item (URI) 07200001/2013401-01, Proper Method for Conducting an MC&A Physical Inventory.
b. Observations and Findings
In accordance with 10 CFR 72.72, the licensee is required to conduct an annual physical inventory of its special nuclear material. The licensee utilizes Morris Operation instruction MOI-314, Basin Inventory Procedure, Revision 4, to account for reactor spent fuel stored in the storage basin.
URI 07200001/2013401-01, Proper Method for Conducting an MC&A Physical Inventory, was previously opened to determine whether procedure MOI-314, Revision 4, contained an adequate methodology for a physical inventory of spent nuclear fuel to fulfill the requirements of 10 CFR 72.72.
The inspectors, in consultation with the Office of Nuclear Materials Safety and Safeguards, determined that procedure MOI-314, Revision 4, contained an adequate methodology for a physical inventory of spent nuclear fuel in accordance with 10 CFR 72.72. Since the URI was opened, the licensee has revised the procedure, however, the methodology remains unchanged and, therefore, adequate throughout its revisions. The inspectors observed the licensee utilize procedure MOI-314, Revision 7, to perform its 2018 physical inventory.
URI 07200001/2013401-01, Proper Method for Conducting an MC&A Physical Inventory, is closed.
No findings of significance were identified.
c. Conclusion The licensees MC&A program complied with the requirements of the applicable regulations and the license.
2.0 Exit Meeting The inspectors presented the inspection results to licensee management at the conclusion of the inspection on October 30, 2018.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PEOPLE CONTACTED
- A. McFadden, Plant Manager, GE-H Morris Operations
- B. Partney, Coordinator, Operations and Maintenance
INSPECTION PROCEDURE USED
60858 Away-From-Reactor ISFSI Inspection Guidance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened Type Summary
None
Closed Type Summary
200001/2013401-01 URI Proper Method for Conducting
an MC&A Physical Inventory
Discussed Type Summary
None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
CFR Code of Federal Regulations
DNMS Division of Nuclear Materials Safety
GEHMO General Electric-Hitachi Morris Operation
ISFSI Independent Spent Fuel Storage Installation
NRC United States Nuclear Regulatory Commission
MC&A Materials Control and Accountability
MCID Materials Control, ISFSI, and Decommissioning Branch
MOI Morris Operation Instruction
TLD Thermoluminescent Dosimeter
URI Unresolved Item
LIST OF DOCUMENTS REVIEWED
CFR 72.48 Evaluations 2016 -2018
Annual 2016 OSL Dose Summary
Annual 2017 OSL Dose Summary
Corrective Action Requests 2016-2017
Emergency Plan and Drill Reports; dated 2017-2018
Environmental Operating Report 2016; Letter to NRC RIII Regional Administrator
Environmental Operating Report 2017; Letter to NRC RIII Regional Administrator
GEH Morris Operation Submittal of Reports of Individual Monitoring for 2016;
dated March 29, 2017
GEH Morris Operation Submittal of Reports of Individual Monitoring for 2017;
dated April 12, 2018
Morris Operation Emergency Plan; dated August 21, 2014
Quality Assurance Plan for Morris Operations, Revision 3
Radiation Dosimetry Reports; 1st through 4th Quarter 2016 and 1st through 4th Quarter 2017
Safety Review Committee Meetings Summaries 2016-2018
SOP 16-10; Basin Water Analysis Compliance Test Data Sheets; January 2016 through
August 2018; Revision 17
SOP 16-100; Effluent Water Analysis Compliance Test Surface Water Data Sheets; Revision 22
SOP 16-11; Basin Leak Detection Alarm -Operability Test; Revision 14
SOP 16-110; Sealed Source Inventory and Leak Check; Revision 16
SOP 16-12; Basin Leak Detection Calibration - Compliance Test; Revision 13
SOP 16-84; Exhaust Sample Analysis - Compliance Test; Revision 17
SOP 16-97; Criticality Alarms Operability - Compliance Test; Revision 15
SOP 16-98; Area Radiation Monitor Calibration - Compliance Test; Revision 22
SOP 16-102; Effluent Water Analysis Compliance Test; Revision 9
SOP 16-17; Fuel Storage System Inspection Data Sheet; Revision 2
MOI-312; Environmental Monitoring Program; Revision 4
MOI-314; Special Nuclear Material (SNM) Accountability; Revision 4
MOI-314; Special Nuclear Material (SNM) Accountability; Revision 7
NQA-2017-10; GEHMO Audit
NQA-2016-10; GEHMO Audit
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