IR 05000018/2021002
| ML21301A074 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos, Vallecitos Nuclear Center |
| Issue date: | 11/03/2021 |
| From: | Greg Warnick Division of Nuclear Materials Safety IV |
| To: | Feyrer M GE Hitachi Nuclear Energy |
| Anderson S | |
| References | |
| IR 2021002 | |
| Download: ML21301A074 (16) | |
Text
November 3, 2021
SUBJECT:
GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT 050-00018/2021-002, 050-00070/2021-002, AND 050-00183/2021-002
Dear Mr. Feyrer:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on September 27-29, 2021, at your Vallecitos Nuclear Center in Sunol, California. The inspection covered the following shutdown reactors under the subject licenses, Vallecitos Boiling Water Reactor (VBWR), General Electric Test Reactor (GETR), and Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR). The NRC inspectors discussed the results of this inspection with you and members of your staff on September 29, 2021. The inspection results are documented in the enclosure to this letter.
During this inspection, the NRC inspectors examined activities conducted under your licenses as they relate to public health and safety, the environment, and to confirm compliance with the Commissions rules and regulations, as well as with the conditions of your license. Within these areas, the inspection consisted of the examination of selected procedures and representative records, tour of the reactors and supporting equipment, independent radiation surveys, and interviews with personnel. Within the scope of the inspection, no violations were identified and a response to this letter is not required.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. If you have any questions concerning this inspection report, please contact Stephanie Anderson at 817-200-1213, or the undersigned at 817-200-1249.
Sincerely, Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety Docket Nos. 050-00018; 050-00070; 050-00183 License Nos.: DPR-1; TR-1; DR-10 Enclosure:
Inspection Report 050-00018/2021-002; 050-00070/2021-002; 050-00183/2021-002 Roldan-Otero, Lizette signing on behalf of Warnick, Gregory on 11/03/21
ML21301A074 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: SGA Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DNMS/RxIB DNMS/RxIB DNMS/MLDB NMSS/RDB NAME SGAnderson CDSteely RJEvans JDParrott SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 11/01/21 11/01/21 11/01/21 11/01/21 OFFICE C:RxIB NAME LRoldan-Otero SIGNATURE LXR DATE 11/03/21
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 050-00018; 050-00070; and 050-00183
License Nos.: DPR-1; TR-1; and DR-10
Report Nos.: 050-00018/2021-002; 050-00070/2021-002; and 050-00183/2021-002
Licensee: GE Hitachi Nuclear Energy
Facility: Vallecitos Boiling Water Reactor (VBWR)
GE Test Reactor (GETR)
ESADA Vallecitos Experimental Superheat Reactor (EVESR)
Location: 6705 Vallecitos Road Sunol, California
Inspection Dates: September 27-29, 2021
Inspectors: Stephanie G. Anderson Senior Health Physicist Reactor Inspection Branch Division of Nuclear Materials Safety Robert J. Evans, PhD, CHP, PE Senior Health Physicist Materials Licensing and Decommissioning Branch Division of Nuclear Materials Safety
Chris D. Steely Health Physicist Reactor Inspection Branch Division of Nuclear Materials Safety Jack D. Parrott Senior Project Manager Reactor Decommissioning Branch Office of Nuclear Materials Safety and Safeguards
Approved By: Gregory G. Warnick, Branch Chief Reactor Inspection Branch Division of Nuclear Materials Safety
Enclosure EXECUTIVE SUMMARY
GE Hitachi Nuclear Energy NRC Inspection Report 050-00018/2021-002; 050-00070/2021-002; and 050-00183/2021-002
This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of licensed activities being conducted at the three permanently defueled reactors at the Vallecitos Nuclear Center. In summary, the licensee was conducting these activities in accordance with site procedures, license requirements, and applicable NRC regulations. Within the scope of the inspection, no violations were identified.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors and Class III Research and Test Reactors
The licensee conducted annual inspections and audits of the three shutdown reactors in accordance with regulatory, license, and procedure requirements. (Section 1.2)
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
The licensee implemented its safety review program in accordance with its procedures and regulatory requirements. (Section 2.2)
Problem Identification and Resolution at Permanently Shutdown Reactors
The inspectors concluded that the licensee was adequately implementing its corrective action program in accordance with regulatory requirements. (Section 3.2)
Fire Protection Program at Permanently Shutdown Reactors
The licensee had implemented a fire protection program that reasonably prevented fires from occurring and was capable of rapidly extinguishing those fires that occurred.
(Section 4.2)
Occupational Radiation Exposure at Permanently Shutdown Reactors
The licensee monitored occupational exposures, and the results for 2020-2021 were less than regulatory limits. The licensee continued to conduct annual radiological surveys within each of the shutdown reactor structures as required by the three licenses, and the licensee reported the results to the NRC in an annual report. (Section 5.2)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The licensee implemented an effluent and environmental monitoring program as required by the licenses, and the licensee reported the results of the program to the NRC in an annual report. All samples required by procedure had been collected, and all sample results were less than the applicable regulatory release limit. (Section 6.2)
Report Details
Summary of Plant Status
The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) continued to maintain the three shutdown reactors, Vallecitos Boiling Water Reactor (VBWR), General Electric Test Reactor (GETR), and Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR) in a possession-only, safe storage (SAFSTOR)
condition, with no fuel remaining in the reactors or spent fuel pools. The condition of SAFSTOR is a decommissioning alternative in which the licensee is authorized to maintain the facility in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated to levels that permit release for unrestricted use within 60 years of permanent cessation of operations. Licensees who choose the SAFSTOR option must meet all NRC financial and safety regulations, both prior to and during the SAFSTOR period.
On April 24, 2015 (ADAMS Accession Nos. ML15114A437 and ML15114A438), the licensee submitted a request for a partial site release of approximately 610acres of non-impacted property on the northern section of Vallecitos Nuclear Center (VNC) site, for unrestricted use pursuant to Title 10 Code of Federal Regulation (CFR) 50.83(b). The NRC approved the partial site release of 610 acres by letter dated May3, 2016 (ADAMS Accession No. ML16007A348). The property continues to remain under the ownership of GEH.
On December 15, 2015, the licensee submitted a request for license continuance under 10CFR 50.51(b) for reactor licenses DR-10 and TR-1 (ADAMS Accession No. ML15349A045).
That request was approved by letter dated January 2, 2019 (ADAMS Accession No. ML18352A450). The licensee also submitted a request on July 10, 2015 (ADAMS Accession No. ML15195A088) for an alternate decommissioning schedule as described in 10 CFR 50.82(a)(3) and 50.82(b)(4)(i), using the exemption criteria of 10 CFR 50.12.
On May 16, 2017, the NRC staff issued a request to GEH for additional information on the structural integrity of the reactor buildings and how the integrity would be ensured during the extended decommissioning period, in order to assess whether the request would result in undue risk to public health and safety (ADAMS Accession No. ML17138A121). The licensee responded to this request by letter dated July 31, 2017 (ADAMS Accession No. ML17212B019).
Based on this response and a site visit conducted by NRC on September 13, 2017, the NRC determined that certain additional information must be provided by GEH to show how the licensee is ensuring the confinement of residual radioactivity associated with the shutdown reactors at the VNC and evaluating and monitoring the long term physical safety of the reactor structures. The NRC requested more detailed information by letter dated January 18, 2018 (ADAMS Accession No. ML17312B359). On March 28, 2018 (ADAMS Accession No. ML18087A384), GEH provided a response indicating that it would provide an interim status report for the hydrological and structural analyses in approximately 6 months and anticipated completing the actions within approximately 12 months, which would be March 2019. On May 31, 2018 (ADAMS Accession No. ML18151A861), GEH submitted a partial response to the request for additional information. On October 23, 2018 (ADAMS Accession No. ML18296A159), GEH provided an interim status report on the efforts to respond to the two remaining requests for additional information. On March 28, 2019 (ADAMS Accession No. ML19087A221), GEH provided the response for some of the requested additional information, and provided a schedule for submitting the remaining hydrological and structural analysis needed to support the exemption request for an alternate decommissioning schedule.
On November 15, 2019 (ADAMS Accession No. ML19319B845), GEH provided its final response on the request for additional information. By letter dated March 16, 2020 (ADAMS Accession No. ML20071G411), the NRC staff requested additional information for EVESR and GETR to make an independent assessment regarding the acceptability of the proposed exemptions. The licensee responded to that request for additional information by letter dated July 15, 2020 (ADAMS Accession No. ML20197A011). Also, on July 15, 2020 (ADAMS Accession No. ML20174A114), NRC staff requested additional information for the VBWR to make an independent assessment regarding the acceptability of the proposed exemptions.
On March 19, 2021 (ADAMS Accession No. ML19304B459), the NRC staff submitted a SECY paper to the Commissioners, SECY-21-0033, Request for an exemption from the decommissioning schedule requirements for shutdown reactors at GE Hitachi Vallecitos Nuclear Center. In the SECY paper, there were two options for the Commissions consideration. Option 1 was to approve a 10 CFR 50.12 exemption from the applicable decommissioning schedule requirements of 10 CFR 50.82(a)(3) and 10 CFR50.82(b)(4)(i) for the EVESR and GETR and delegate to the staff only the authority to grant or deny such an exemption for the VBWR based on GEHs demonstration of the VBWRs continued structural integrity. Option 2 was to deny the exemption request for all three shutdown reactors at the VNC. The NRC staff recommend approving Option 1, a 10 CFR 50.12 exemption from the applicable decommissioning schedule requirements of 10 CFR 50.82(a)(3) and 10 CFR 50.82(b)(4)(i) for the EVESR and GETR and to delegate to the staff the authority to grant or deny such an exemption for the VBWR based on the licensees demonstration of the VBWRs continued structural integrity.
On August 6, 2021 (ADAMS Accession No. ML21218A110), the Commission disapproved the staffs recommendation to grant GEH an exemption of 10 CFR 50.12, to extend the decommissioning schedule for EVESR, GETR, and VBWR and instead approved a denial of the request under Option 2. On August 25, 2021 (ADAMS Accession No. ML21237A064), GEH requested to withdraw its exemption request for the shutdown reactors from an alternate decommissioning schedule. By letter dated October 12, 2021 (ADAMS Accession No.
ML21258A042), the NRC staff sent a letter to GEH accepting the withdraw of the exemption request and reviewed the requirements from 10 CFR 50.82 that apply to the decommissioning of the shutdown reactors at the VNC.
1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801) and Class III Research and Test Reactors (69002)
1.1 Inspection Scope
The inspectors reviewed the licensees control and oversight of the three shutdown reactors.
1.2 Observations and Findings
a. Status and tours of the shutdown reactors
1. Vallecitos Boiling Water Reactor
Vallecitos Boiling Water Reactor is a possession-only reactor under License No. DPR-1, Amendment 21. It was a 50-megawatt (MW) power reactor that achieved full power operations in 1957, after receiving its Construction Permit No. CPPR-3 on May 14, 1956.
It was shut down on December 9, 1963, for an extended period of time and subsequently was deactivated. All fuel has been removed from the facility.
The possession-only facility license DPR-1, License Condition 4 states in part, that there should be an audible control device maintained on the doors to the containment building. In addition, License Condition 5 authorizes GEH to dispose of component parts or devices from the VBWR facility in accordance with the provisions of 10 CFR Part 20.
The licensee removed extensive components from the facility between October 2007 and November 2008. All reactor systems have been removed except for the reactor vessel. The licensee monitors the water level weekly in the reactor vessel and the inspectors confirmed that it had remained essentially constant at approximately 96 inches of water, since the last NRC inspection conducted in March 2021.
The inspectors toured the facility with licensee representatives. The inspectors confirmed there was an audible control device functioning on the manual doors to the containment building that provided an alarm at the 300-area alarm panel and at the Central Alarm Station. The inspectors observed that the roll-up door was secured, which was installed in place of the equipment hatch. The inspectors entered the basement level to observe the condition and integrity of the retired facility. The inspectors identified humidity and temperature sensors inn the retired facility. The inspectors observed multiple crack formation throughout the containment building. The cracks are being monitored by the licensee to determine growth rate. During the inspection, the inspectors did not identify any standing water on the floor of the basement. The sump pump was in operation at the time of the inspection, and any water that is collected in the basement of VBWR is pumped to the VBWR transfer tank, then ultimately transferred to the onsite waste evaporator plant for processing.
2. ESADA Vallecitos Experimental Superheat Reactor
The ESADA Vallecitos Experimental Superheat Reactor (EVESR) is a possession-only reactor under License No. DR-10, Amendment No. 7. The EVESR was a light water moderated, steam cooled, superheat, experimental research reactor that used slightly enriched uranium dioxide as fuel. It operated at a maximum of 17 MW thermal and was initially licensed in 1963. It achieved full power operation in 1964, and was shut down on February 1, 1967, and subsequently deactivated. All fuel and other special nuclear material had been removed and shipped offsite. In addition, a significant amount of equipment used to operate the reactor, such as nuclear instrumentation, piping, pumps, and valves has been removed.
The inspectors toured the facility with licensee representatives. The inspectors confirmed there was an audible control device functioning on the airlock door to the containment building that provided an alarm at the 300 feet elevation area alarm panel and at the Central Alarm Station. The licensee had a portable dehumidifier to remove significant quantities of condensation that tended to buildup in the facility. The licensee had lighting installed and it was operating sufficiently to ensure the passageways and stairs were safely lit. The stack was no longer operational, and the licensee was using a portable ventilation system.
3. General Electric Test Reactor
General Electric Test Reactor is a possession-only reactor under License No. TR-1, Amendment No. 17. The reactor was a 50 MW thermal experimental test, development, and isotope production reactor that utilized highly enriched plate fuel and was initially licensed to operate in 1959. The reactor was shut down in 1977 and subsequently deactivated. All fuel and isotope production targets containing special nuclear material have been removed from the facility and shipped offsite. The reactor, systems and piping, and spent fuel pool have been drained of water. The containment polar crane was functional, and only required re-certification for it to be considered operable.
The inspectors toured the containment building, old control room, tank farm, and GETR auxiliary buildings immediately adjacent to the containment structure. As GETR has been shut down since 1977, there are no licensed operators nor a requalification program, which is appropriate for the plant conditions. Staffing was appropriate to meet the required weekly surveillance patrols, which were being conducted in accordance with site procedures.
4. Other
The licenses for the three shutdown reactors require, in part, that activities involving access to the facility area and use of any area shall be conducted under the direction of a designated facility manager with functional responsibility and commensurate authority to maintain the facility in a safe and secure condition at all times. The inspectors reviewed the licensees organization and discussed the organizational structure with members of the licensees organization. Based on discussions and observations, the inspectors determined that the individual fulfilling the licensed responsibility as the facility manager for the defueled reactors, adequately met the license condition requirements.
1.3 Conclusions
The licensee conducted annual inspections and audits of the three shutdown reactors in accordance with regulatory, license, and procedure requirements.
2 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (37801)
2.1 Inspection Scope
The inspectors reviewed the licensees control and oversight of the safety review program to ensure design changes, tests, experiments and modifications were effectively conducted, managed, and controlled during plant decommissioning.
2.2 Observations and Findings
Within the past 4 years, the licensee has only made one modification to the existing plant systems of VBWR, EVESR, and GETR. This is due to the length of time since shutdown for VBWR, EVESR, and GETR. All three reactors have been in SAFSTOR status for several decades.
All through 2020 and up to the date of this inspection in September 2021 there were no 10 CFR 50.59 evaluations or modifications by the licensee in which to review. However, the inspectors reviewed FMP 6.3, Use and Modifications of Facilities, Revision 2, VSS 2.0, Change Authorization, Revision 23, and the training program. It was noted by the inspectors that all licensee personnel who are qualified to perform 50.59 evaluations have been appropriately trained as required by licensee procedure. The licensee procedure to implement 50.59 evaluations appears to be effective and meets regulatory requirements.
2.3 Conclusions
The licensee implemented its safety review program in accordance with its procedures and regulatory requirements.
3 Problem Identification and Resolution Action at Permanently Shutdown Reactors (40801)
3.1 Inspection Scope
The inspectors reviewed the licensees corrective action program related to the oversight of the three shutdown reactors.
3.2 Observations and Findings
At the time of the inspection the licensee was implementing its corrective action program under procedure CP-16-108, Corrective Action Program, Revision 13.1. The procedure applies to the GE-Hitachi nuclear sites and facilities at VNC. According to the procedure, any employee may initiate a condition report (CR). The priority levels for issues identified in the corrective action program ranged from A to D, with A being a significant condition adverse to quality, safety or security, B was a condition adverse to quality, safety or security, C was similar to broke/fix or conditions that had minimal effect on the safe or reliable operation of a facility, and D was considered an improvement item.
In addition to procedure CP-16-108, the inspectors also reviewed procedure WI-16-108-01-F03, Priority Screening Criteria Matrix, Revision 2, audit NQA-2021-04, GEH-Parts, conducted in May 2021 that included the corrective action program, and a list of CRs related to the shutdown reactors generated between January 2020 and the time of the inspection, including several specific CRs related to the shutdown reactors (CRs 34902, 33529, 34409, 33593, 33721, 33893, 33895, 33969, 34068, 34135, 34136, 34233, 34557, 34794, 35059, 35212, 36332, 37493 and 37543 meeting condition B criteria) for adherence to licensee corrective action procedures.
The inspectors also reviewed procedure CP-16-100, Trend Analysis, Revision 2.1, the process and results of GEHs Vallecitos specific trend analysis of CRs categories based on key words, the recent efforts by GEH to better specify trend categories specific to the activities done on site and related to the shutdown reactors for better identification of issues, and how these trending issues are reviewed by management. The inspectors also looked at the licensees effectiveness at reasonably preventing problems and promptly detecting and correcting issues of concern.
3.3 Conclusions
The inspectors concluded that the licensee was adequately implementing its corrective action program in accordance with regulatory requirements.
4 Fire Protection Program at Permanently Shutdown Reactors (64704)
4.1 Inspection Scope
The inspectors evaluated the licensees fire protection program to support licensed activities and regulatory requirements.
4.2 Observations and Findings
The licensee is required under 10 CFR 50.48(f) to maintain a fire protection program to:
(1) reasonably prevent fires from occurring; (2) rapidly detect, control, and extinguish those fires that do occur and that could result in a radiological hazard; and (3) ensure that the risk of fire-induced radiological hazards to the public, environment, and plant personnel are minimized. The three shutdown reactors are required to have a fire protection program; however, they are not required to maintain fire detection or suppression equipment at their facilities because the majority of flammable materials have been removed. The inspectors reviewed the fire protection program from an emergency preparedness perspective to verify that the program can reasonably prevent fires from occurring and rapidly extinguish those fires. The inspectors also reviewed the fire drill report for 2020, fire extinguisher monthly surveillances, quarterly fire training, fire hoses conditions, and the preventive maintenance monthly inspections.
4.3 Conclusions
The licensee had implemented a fire protection program that reasonably prevented fires from occurring and was capable of rapidly extinguishing those fires that occurred.
5 Occupational Radiation Exposure at Permanently Shutdown Reactors (83750)
5.1 Inspection Scope
The inspectors reviewed occupational exposures and the results of the licensees radiological surveys within the three shutdown reactors for compliance with license and regulatory requirements.
5.2 Observations and Findings
a. Occupational Exposures
The occupational dose limits for adults are provided in 10 CFR 20.1201. The inspectors reviewed the licensees occupational exposure records and discussed these records with the radiation safety officer. The licensee divided the site staff into groups based on major work activities. The groups included facilities management, hot cell work, nuclear test reactor, and regulatory compliance/radiation protection. Worker exposures were primarily from external sources but may include internal exposures based on air sample results.
During calendar year 2020, the onsite individual who received the highest total effective dose equivalent exposure worked at the nuclear test reactor. This individual received 0.876 rem with a regulatory limit of 5 rem. The highest dose to a hot cell worker was 0.434 rem, while the highest dose to a facilities worker was 0.201 rem. Finally, the highest dose to a regulatory compliance/radiation protection worker was 0.220 rem.
The inspectors also reviewed the available occupational exposure records for calendar year 2021. At the time of the inspection, the highest dose was assigned to a nuclear test reactor worker at 0.380 rem for one quarter. Other workers received lower levels of exposure. The licensee continued to monitor worker exposures using optically stimulated dosimeters, electronic dosimeters, and air sampling as necessary based on the work assignment.
b. Annual Radiological Surveys Within Shutdown Reactors
The licenses for the three shutdown reactors include conditions which state that a general radiation survey shall be conducted at least annually, and the results of the survey shall be submitted to the NRC on an annual basis. The radiological surveys of the interiors of the three shutdown reactors were conducted in August 2020. The results of the surveys were submitted to the NRC by letter dated March 29, 2021 (ADAMS Accession No. ML21088A309). The radiological surveys included ambient and surface radiation levels, removable contamination levels, and ambient air samples.
The inspectors reviewed the sample results for 2020. Although each building had variable levels of contamination, according to the licensee, the overall radioactivity levels were found to remain low. The licensee had not established action levels for the survey results, in part, because the areas were located within radiologically restricted areas, and the areas were not routinely accessed by site personnel.
The inspectors also reviewed the annual survey results for 2021. These surveys were conducted in July and September 2021. The 2021 results were comparable to the 2020 sample results. The licensee is expected to submit the results for the 2021 surveys to the NRC during the first quarter of 2022. In summary, the licensee conducted the 2020-2021 annual radiological surveys in accordance with license requirements, and the licensee reported the results of the 2020 surveys to the NRC.
5.3 Conclusions
The licensee monitored occupational exposures, and the results for 2020-2021 were less than regulatory limits. The licensee continued to conduct annual radiological surveys within each of the shutdown reactor structures as required by the three licenses, and the licensee reported the results to the NRC in an annual report.
6 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
6.1 Inspection Scope
The inspectors reviewed the licensees effluent and environmental monitoring program for the facility. The inspectors did not review the licensees radioactive waste treatment operations since these operations were not in service during the inspection.
6.2 Observations and Findings
Licenses DR-10 and DPR-1 for the EVESR and VBWR, respectively, require the licensee to maintain records showing the radioactivity released or discharged into the air or water beyond the effective control of the licensee as measured at the point of such release or discharge. At the time of the inspection, the licensee had established and implemented an effluent and environmental monitoring program in accordance with the instructions provided in the Environmental Monitoring Manual, Revision 6, and Procedure 7.2, Radioactive Effluent Control, Revision 13. The licensee reported the results to the NRC in annual reports. The inspectors reviewed the 2020-2021 results and discussed the results with the radiation safety officer. In summary, the licensee collected and analyzed all required samples, and no sample result exceeded the respective regulatory limit.
The licensee implemented a site-wide program to monitor gaseous and liquid effluents.
The program included collection and analysis of air, water, sediment, and vegetation samples, and measurement of ambient gamma radiation levels. The results for 2020 were reported to the NRC by letter dated March 1, 2021 (ADAMS Accession No.
Airborne effluents were continuously monitored at four operating building discharge stacks. Liquid effluents included industrial wastewater and clean water. The water was sampled prior to discharge. Industrial wastewater was recycled as landscape water, while clean water was released to local drainage ditches. Groundwater was monitored at eight locations in 2020. Vegetation samples were collected in two downgradient locations, and stream sediments were collected at one location. The licensee monitored the airborne radioactivity levels at four sampling stations around the site. Finally, the ambient gamma radiation levels were measured at 20 locations around the site.
The inspectors reviewed the licensees results for 2020-2021 and discussed the program with licensee representatives. The inspectors confirmed that all samples required by site procedures had been collected. The inspectors compared the sample results for 2020-2021 to the respective regulatory limits. No sample result exceeded a regulatory limit.
The inspectors reviewed recent changes to the effluent and environmental monitoring program. The licensee recently installed three new monitoring wells. The wells were named the EVESR-SE, MW-10, and VBWR dewatering wells. The licensee began sampling the EVESR-SE well in 2021, but the MW-10 well was dry and could not be sampled. The licensee is considering its options for this well which may include relocation or redrilling of the well. The third well, the VBWR dewatering well, was not ready to be sampled at the time of the inspection.
Based on the results of the stack effluent monitoring program, the licensee calculated the public dose at the site boundary. The licensee used the COMPLY computer code to calculate these doses, in part, to demonstrate compliance with the constraint rule requirements specified in 10 CFR 20.1101(d). Using the 2020 data, the doses to the site developed areas was calculated to be 3.5 millirem per year or less, and the doses to the property line were calculated to be 0.5 millirem per year or less. These calculated results were below the 10 millirem per year total effective dose equivalent limit provided in regulations.
The licensee self-identified a potential problem with its environmental dosimeter program. The licensee conducted a study of the results of samples collected between 2010-2020 and observed that the control dosimeter results were generally higher than the results of the environmental dosimeters. In response, the licensee added additional control dosimeters to its sampling program in different locations to potentially lower the average background value. At the time of the onsite inspection, the licensee continued to collect data for future analysis. Once the results of the study have been tabulated, the licensee plans to take corrective actions that may include relocation of the control dosimeters for the environmental monitoring program.
In addition, the licensee conducted a study to determine if the current locations of the environmental dosimeters (inside of metal boxes) impacted the measured results. The licensee placed a second dosimeter outside of the onsite boxes for comparison to the sample results of the dosimeters inside of the boxes. The results indicate that the two sets of dosimeters provided similar measurements, meaning that the metal boxes could continue to be used to house the environmental dosimeters.
The inspectors observed the licensees staff implementing portions of its environmental monitoring program. The inspectors observed the changeout of an air sampling filter at one of four environmental sampling stations and toured the count room where the air filter samples were analyzed. The inspectors noted that the technician conducting the filter changeout followed site procedures and maintained control of the exchanged filters.
The technician who managed the count room was knowledgeable of the tasks being performed. The inspectors discussed recent sample results with the count room technician and confirmed that the action levels used by the count room software were consistent with the action levels specified in site procedures.
6.3 Conclusions
The licensee implemented an effluent and environmental monitoring program as required by the license, and the licensee reported the results of the program to the NRC in an annual report. All samples required by procedure had been collected, and all sample results were less than the applicable regulatory release limit.
7 Exit Meeting Summary
On September 29, 2021, the NRC inspectors presented the final inspection results to the Mr. Matt Feyrer, Site Manager, and other members of the licensees staff. The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary information. No proprietary information was identified.
SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee M. Feyrer, Site Manager J. Smyly, Environmental, Health and Safety Manager D. Heckman, Regulatory Affairs and Licensing Lead K. Zanotto, Lead Manufacturing Projects J. Ayala, Radiation Protection Supervisor
INSPECTION PROCEDURES IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 69002 Class III Research and Test Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors IP 64704 Fire Protection Program at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed None
Discussed None
LIST OF ACRONYMS
ADAMS Agency Documents Access and Management Systems CFR Code of Federal Regulations CR Condition Report EVESR Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor GEH GE Hitachi Nuclear Energy Americas, LLC GETR General Electric Test Reactor NRC U.S. Nuclear Regulatory Commission VBWR Vallecitos Boiling Water Reactor VNC Vallecitos Nuclear Center
Attachment