ML18340A255
| ML18340A255 | |
| Person / Time | |
|---|---|
| Site: | 07200001 |
| Issue date: | 12/06/2018 |
| From: | Mcfadden A GE-Hitachi Nuclear Energy Americas |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M1800217 | |
| Download: ML18340A255 (7) | |
Text
HITACHI Ml80217 December 6, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001 GE Hitachi Nuclear Energy Anthony E. McFadden Plant Manager GEH Morris Operation 7555 E. Collins Ad Morris, IL 60450 USA T (815) 942-5590 X174 F (815) 942-5631 anthony.mcfadden@ge.com
Subject:
GEH Morris Operation Submittal of Biennial Report 10CFR72.48; Changes, Tests, and Experiments
Reference:
SNM-2500 Docket72-1 This letter is submitted, on behalf of GE Hitachi Nuclear Energy Americas, LLC (GEH), per the requirements of 10CFR72.48(d)(2) for the period of Dec 2016 to Dec 2018 for GEH Morris Operation (MO).
Two 72.48 evaluations were conducted from the period of 16 Dec 2016 to 06 Dec 2018. No evaluations warranted an amendment to the current NRC license (SNM-2500).
A brief description and summary of the evaluations are included in the attached enclosures (Encll & 2).
Please do not hesitate to contact me if there are any questions.
Sincerely,
/
//'/
/ ~f~~ny McFfctlen Plant Manager GEH Morris Operation
Director, Division of Spent Fuel Management GEH Morris Operation Submittal of Biennial Report 10CFR72.48; Changes, Tests, and Experiments Ml80217 December 6, 2018 Page 2 of2 Commitments: No commitments have been made in this letter.
Enclosures:
Cc:
- l. 72.48 Evaluation for Hearing Protection Requirements During Criticality Alarm Testing
- 2. 72.48 Evaluation for Changing Purchase Order Coding on Calibration Services PM 18-016 Page 1 of 2 HITACHI Morris 0J'(Jrstlon Morris OJHJratlon Instruction Employee. Only MOI-430 72.48 Applicability Analysis for Changes, Tests, Experiments Review Number. SC-2016*48-02 Description of Activity:
Add a safety note to SOP".....,16..,*:8'9'?',._, Criticality Alarms Operability-Compliance Test, that requires hearing protection if personnel are in the basin area for more than 30 minutes while the horns are activated.
Does this activity:
Yes No X
1----t.......---t Require an amendment to the license, SNM-2500, due to a change In technical speclftcatlons?
Result In more than a minimal increase In the frequency of occurrence of an accident previously evaluated In the CSAR?
Result In more than a minimal Increase In the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety
......;---...; previously evaluated In the CSAR?
Result In more than a minimal Increase in the consequences of an accident previously evaluated In the CSAR?
1----t---f 1---i---:---f 1----t----t 1----t---t l----..11----'
Result In mere than a minimal increase In the ccnsaquences of a malfunction of an SSC Important to safety previously evaluated in the CSAR?
Create a possibility fer an accident of a different type than any previously evaluated In the CSAR?
Create a possibility for a malfunction of an SSC Important to safety wfth a different result than the previously evaluated In the CSAR?
Result In a design balls limit fer fission product barrier as described In the CSAR being exceeded or altered?
Result in a departure from a method of evaluation dascribed In the CSAR used In establishing the deign bBHS or in the safety analyses?
Am response to any of the questions In the list Will require an amendment to the license, SNM-2500 and NRC approval prior to implementation.
If all responses are NO, written records shall be produced which provide the basis for the determination that the change, test. or experiment does net require a license amendment.
Changes and evaluation summaries shall be reported to the NRC every two years.
Prepared by:
F. C. Partney
Title:
OMC Date:
12/15116 Salaty Committee Approval (requlred tr any of the above questlonswe~~n~Weted ~v..
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Operations & Maintenance Coordinator...,-~-=::;;;___,.=-.---,:--r--- Data:
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Administrator, EHS & Procurement:
Date:
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QA Administrator:
Date:
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Manager, Morris Operation:
Date: --LJ.::...c..:...;_j_...:::_.
HITACHI Morris Operation Page 2 of 2 Morris Operation Instruction EmptoyHS Only M0/-430 Note: Additional pages may be attached to provide specific lnfonnatfon required to address any of the above questions 72.48 Applicability Analysis for Changes, Tests, Experiments Review Number: SC-2016-48-02 Description of Activity:
Add a safety note to SOP 16-97, Criticality Alarms Operability - Compliance Test, that requires hearing protection if pers6nnel are in the basin area for more than 30 minutes while the horns are activated.
"NO" Rationale The information added to this procedure Is for personnel safety from an EHS perspective only.
This procedure change does not impact the testing method or evaluation criteria In any way.
Therefore, there is no Impact on licensed activities or accidents evaluated by the CSAR.
Prepared by:
Page 1 of 3 l
HITACHI Morris Operation Mo"ls Operation Instruction Employes Only MOI-430 72.48 Applicability Analysis for Changes, Tests, Experiments Review Number. SC-2018-48-01 Description of Activity:
Change PO Coding for MO instrument calibration services from 'Q' to 'L *.
Does this activity:
Yes No X
X X
X X
X X
Require an amendment to the nce~nae, SNM-2500, due to a change In technical apeclfications?
Resuit In more than a mlnimallncreau In the frequency of occurrence of an accident previously evaluated In the CSAR?
Result In more a minimal lncreue In the likelihood of occurrence ol a malfunction of a ~ayatem, structure, or component (SSC) Important to **v*Y'U previouaiy evaluated In the CSAR?
Result In more a minimal increase In the consequences of an acctGe!l11 previoualy In CSAR?
Reauit In more than a minimal increase in the consequences of a m.l!!llftu!'lction en SSC important to safety previously evaluated In the CSAR?
Creale a possibility for an accident of a different type than any previously evaluated In the CSAR?
Create a pouibility for a malfunction of an sse Important to safety with a different result than the previoualy evaluated in the CSAR?
Reaultln a design ba*l* limit for fission product barrier as described In CSAR being exceeded or altered?
Reault in a departure from a method of evaluation described In the CSAR used in establishing the design bans or In the safety analyses?
A YES reaponn to any of the questions in the nat will ntquire an amendment to the license, SNM-2500 and NRC approval prior to implementation.
If all responses are NO. written recorda shaH be produced which provide the basis for the datermfnallon that the change, test, or experiment does not require a llcemse amendment.
Changes and evaluation summaries shall be reported to the NRC every two years.
Date: 3/1t./t z Operations & Maintenance Coordinator. --4~~~1lf!!=~--- Date:
'J J12.l' f Administrator, EHS & Procurement:
Date* 3.)tGJ..} I r D
ate:
Manager. Morris Operallon: ----::~:ro;;z:~,.c;-=----- Date: -i-/2-r-J.-4-::~~rL-Note: AcldtUonel pages may be attached to provide epeelflc Information requited to addreusmy of tho above questions Page 1 ol2 F:\\72-4Bs\\SC*2018-4B*01
- cal Pun:h COdlng.docx
I HITACHI Morris Operation Page 2 of 3 Morris Operation Instruction No Response Rationale Employees Only M0/-430 The accuracy and/or operability of these devices do not, by themselves, affect the margin to nuclear or radiation safety. These instruments are not required to meet any of the conditions of the Site operating license, SNM-2500. Therefore, these instruments are classified as FC-3 lAW MOI-431, Design and Facility Classification. Further documentation for this change is recorded in CR-26669. The description for this CR reads:
Previously, all instrumentation calibrations at GEH Morris have been designated as 110".
Discussions with GEH Quality Management determined in order to be consistent with the rest of GEH (i.e. FMO), instrument calibrations should be designated as "L". It has been verified, there are no NRC license, or technical specifications associated with the license, which require "Q" designation for instrumentation at GEH Morris.
Therefore, this change is understood to be straight forward in concept and is acceptable for implementation.
Paae 2 of 2 F:\\72-4Rs\\SC-?01 B-48 Cal Purch Coding dncx
HITACHI Morris Operation Page 3 of 3 Morris Operating Instructions CHANGE INITIATION REQUEST Employees Only MOI-421
- 1.
DESCRIPTION (Describe change and why it is needed)
- 2.
Change PO Coding for radiation monitor and pressure calibrator calibration services from 'Q' to
'L '. This change was initiated and implemented at MO by action from CR-26669 dated Bn/2017 to bring MO calibration activities into alignment with other GEH sites. This change initiation request and screening process is being conducted in hindsight due to CR-27106 to ensure all MO procedural requirements are met.
REVIEW
[X]
OMC
[]
Date 03/12/2018 Classification (FC & QAER) : FC-3 Safety Analysis: N/ A Licensing Impact: N/ A Comments:
Scope Committee DateN/A See 72.48 analysis SC-2018-48-01 for documentation.
- 3.
DISPOSITION
[ ]
Cancelled: Attach rationale for cancellation.
[ ]
Refer to GEH Engineering
[ ]
Refer to Outside Engineering Firm
[X]
Assign to MO person for design: Change was initiated by email to affected personnel (9/7/2017).
~cope Committee Rep: -=~=t--~------,£___:.:_---~;f----Date: '3/tz{,i Comments:
lAW step 4.2 of MOI-421, Scope Committee review is not required. This change is approved retroactively to 9/7/2017, the date of CR-26669.
Date Issued: 10/12/17 Revision: 1 0 Page: 1 of 1