IR 05000018/2023001
| ML23122A291 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos |
| Issue date: | 05/05/2023 |
| From: | Greg Warnick NRC/RGN-IV/DRSS/DIOR |
| To: | Pedley C GE Hitachi Nuclear Energy |
| Johnson T | |
| References | |
| IR 2023001 | |
| Download: ML23122A291 (13) | |
Text
May 05, 2023
SUBJECT:
GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT 050-00018/2023-001, 050-00070/2023-001, AND 050-00183/2023-001
Dear Charles Pedley:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on April 10-12, 2023, 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 April 12, 2023. 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 Troy Johnson at 817-200-1596, or the undersigned at 817-200-1249.
Sincerely, Signed by Warnick, Gregory on 05/05/23 Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactors Branch Division of Radiological Safety and Security Docket Nos. 050-00018; 050-00070; 050-00183 License Nos. DPR-1; TR-1; DR-10 Enclosure:
Inspection Report 050-00018/2023-001 050-00070/2023-001; 050-00183/2023-001
ML23122A291 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: MTJ Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DRSS/DIOR DRSS/DIOR C:DIOR NAME MTJohnson SGAnderson GGWarnick SIGNATURE /RA/ /RA/ /RA/
DATE 05/03/23 05/03/23 05/05/23
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.: 050-00018/2023-001; 050-00070/2023-001; and 050-00183/2023-001 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: April 10-12, 2023 Inspectors: M. Troy Johnson Health Physicist Decommissioning, ISFSI, and Operating Reactors Branch Division of Radiological Safety and Security Stephanie G. Anderson Senior Health Physicist Decommissioning, ISFSI, and Operating Reactors Branch Division of Radiological Safety and Security Accompanied By: Eric S. McManus Health Physicist Decommissioning, ISFSI, and Operating Reactors Branch Division of Radiological Safety and Security Approved By: Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactors Branch Division of Radiological Safety and Security Enclosure
EXECUTIVE SUMMARY GE Hitachi Nuclear Energy NRC Inspection Report 050-00018/2023-001; 050-00070/2023-001; and 050-00183/2023-001 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)
Occupational Radiation Exposure at Permanently Shutdown Reactors The licensee conducted its radiation control program in accordance with the license conditions and regulatory requirements. (Section 2.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials The licensees programs for processing, handling, storage, and transportation of radioactive material were effective and conducted in accordance with procedures and regulations.
(Section 3.2)
Report Details Summary of Plant Status The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) transitioned 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) from a possession-only, safe storage (SAFSTOR) condition, with no fuel remaining in the reactors or spent fuel pools to DECON status.
On December 15, 2015, the licensee submitted a request for license continuance under 10 CFR 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 (ML18352A450). The licensee also submitted a request on July 10, 2015 (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 March 19, 2021 (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 Vallecitos Nuclear Center (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 (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 (ML21237A064), GEH requested to withdraw its exemption request for the shutdown reactors from an alternate decommissioning schedule. By letter dated October 12, 2021 (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.
On September 21, 2022 (ML22264A325), GEH submitted their Limited Post-Shutdown Decommissioning Activities Report (LPSDAR) to demonstrate compliance with 10 CFR 50.82(a)(4) and 10 CFR 50.82(a)(7). Although 10 CFR 50.82(a)(4) requirements for content of the PSDAR do not apply to VBWR and EVESR, GEH agreed to prepare the LPSDAR consistent with the description in 10 CFR 50.82(a)(4) and Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report.
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 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 removed the remainder of the water from the reactor vessel on November 15, 2022. Per the 1965 Final Report on Deactivation of VBWR, a manometer was located outside of the containment to allow for monitoring of the water level inside the reactor. The manometer was permanently removed per condition report #40917 and the licensee updated form 01 of procedure 6.2, Patrols and Inspections, revision 3 to remove the task of weekly checking the water level of the VBWR reactor vessel.
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 observed multiple crack formations throughout the containment building. The cracks are being monitored by the licensee to determine growth rate. During the inspection, the inspectors identified a small amount of 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 was pumped to the VBWR transfer tank, then ultimately transferred to the onsite waste evaporator plant (WEP) 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 have 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-foot elevation area alarm panel and at the Central Alarm Station. The licensee uses a portable dehumidifier to remove condensation that builds up in the facility. The licensee has installed lighting which was operating sufficiently to ensure the passageways and stairs were safely lit. While the ventilation stack was still present, it was no longer operational, and the licensee was using an installed 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, piping, and spent fuel pool have been drained of water.
The inspectors toured the containment building, old control room, and GETR tank farm.
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 always maintain the facility in a safe and secure condition. 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 license responsibility as the facility manager for the defueled reactors has 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 Occupational Radiation Exposure at Permanently Shutdown Reactors (83750)
2.1 Inspection Scope To ensure adequate protection of worker health and safety from exposure to radiation or radioactive material at permanently shutdown reactors.
2.2 Observations and Findings Each of the shutdown reactors have license conditions that require annual entries for routine radiation surveys and general examination of conditions throughout the buildings.
The licensee performed its entries and surveillances in accordance with procedures 6.1, Access Control, revision 10, and 6.2, Patrols and Inspections, revision 16. At the time of the inspection, the licensee had completed their annual inspections and surveys of the shutdown reactors and the inspectors reviewed the annual report dated March 24, 2023.
Radiation protection personnel are trained in accordance with procedure CP-20-305-G01, RP Training Program Curriculum Maintenance Guide, revision 0, and procedure 1200, Qualification of Radiation Monitoring Technicians, revision 0. The inspectors reviewed training records for select radiation protection personnel as well as the education and qualifications of the newly appointed radiation safety officer. Training records were complete and up to date and the radiation safety officers education and qualifications were adequate to perform the role.
The inspectors observed radiation protection workers use of survey meters performing area monitoring during tours as well as personnel monitoring during the exit of reactor containments and potentially contaminated facilities. Additionally, the inspectors observed a radiation protection worker perform a daily source check of an instrument.
Survey meters observed in use were Thermo Scientific Radeye B20-ER; Ludlum model 3276 with a 43-92 probe; Eberline RM-15; and Ludlum model 3 with a 44-9-18 probe. All survey meters were marked to indicate they were within calibration.
The inspectors verified that dosimeters used at Vallecitos Nuclear Center (VNC) are processed by a National Voluntary Laboratory Accreditation Program (NVLAP)
accredited processor. Specifically, the inspectors validated that Landauer Inc. which
provides dosimetry processing services to VNC is accredited through NVLAP to International Organization for Standardization / International Electrotechnical Commission 17025:2017 which specifies the general requirements for the competence, impartiality, and consistent operation of laboratories.
Inspectors reviewed onsite storage of dosimeters before their issuance, during use, and before being shipped for processing. Dosimeters not actively issued were stored in a shielded container in a room where no sources of radiation are present. Issued dosimeters, when not actually being worn, were stored in an area for common access which was monitored for background radiation by a control dosimeter that was posted in the immediate vicinity. Additionally, dosimeters were placed in occupied buildings to monitor background radiation throughout the site. All dosimetry actively being worn by personnel was noted to be located appropriately on the body for the radiation exposure expected to be received.
The inspectors evaluated the use of continues air monitors (CAM) as well as air monitoring in progress during tours of the shutdown reactors. The WEP uses a CAM to monitor breathing air in the vicinity of processing operations. The CAM was placed adjacent to the entrance to the processing facility and was noted to be adequate to monitor the air the attendant regularly breathed. Prior to entrance into the shutdown reactors, grab samples were performed and monitored by the licensee. During tours of the shutdown reactors breathing air was monitored using a personnel air sampler also known as a lapel monitor worn by one of the site personnel who moved regularly around the tour group and entered new spaces ahead of other tour group personnel.
During the inspection, the inspectors toured accessible areas within the VBWR, EVESR, and GETR containment buildings to observe radiological postings and access controls.
The inspectors also performed independent radiation surveys to ensure that postings adequately reflected the radiological hazards using a Thermo Scientific RadEye G survey meter (serial number 30932, calibrated to cesium-137 with a calibration due date of November 9, 2023). Through performance of these surveys, the inspectors determined that the postings and controls within the areas were adequate to protect worker health and safety.
During the previous inspection in November 2022, the inspectors identified violation (VIO 0500018/2022002-001) associated with 10 CFR 20.1601(a), which states in part, the licensee shall ensure that each entrance or access point to a high radiation area has one or more of the following features, (3) entryways that are locked, expect during periods when access to the areas is required, with positive control over each individual entry.
Specifically, during an NRC tour of the WEP building, the licensee failed to assign and brief an attendant per procedures WI-27-105-01, Posting and Controls of Radiological Areas, revision 3, and WI-27-105-15, High Radiation Area Access Control, revision 2.
The licensee responded to the notice of violation by letter dated January 10, 2023 (ML23010A271). The facility was brought back into immediate compliance when all personnel exited the High Radiation Area (HRA) and the WEP building was locked to prevent entry. The licensee took corrective actions to prevent and safeguard against future occurrences. The licensee installed an audible device for entry into the WEP. The licensee provided refresher training to the staff on procedure WI-27-105-01 requirements to maintain positive controls of HRAs. The licensee revised procedure 60P060, Waste Evaporator Plant (WEP) Operation, revision 5, which now includes expectations on how
to establish positive control over each individual entry to the HRA per procedure WI-27-105-01, section 4.6.3. The inspectors determined that the licensees corrective actions were adequate, and this violation is now closed.
2.3 Conclusions The licensee conducted its radiation control program in accordance with the license conditions and regulatory requirements.
3 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)
3.1 Inspection Scope To verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.
3.2 Observations and Findings The inspectors performed a tour of the radioactive waste storage areas at the WEP and building 304 to verify radioactive materials were controlled, labelled, posted, and secured against unauthorized removal as well as evaluate the material condition of the containers, including whether there were signs of swelling, leakage, or deformation. Both buildings had radioactive waste stored in secured 55-gallon drums and radioactive equipment not currently in use. Building 304 kept drums with higher radiation readings in a pit in the middle of the building to reduce accessible radiation levels.
Both buildings were secured against unauthorized access with sturdy lockable doors and limited key access. The WEP has a full time attendant on duty when the building was open for operations with a loud audible buzzer that alerts the attendant when someone crosses the building entry threshold with the liquid processing area locked and controlled as a high radiation area. Building 304 was controlled as a high radiation area and had a high radiation area guard when the building was open for access but was otherwise kept locked with restricted access.
The inspectors examined the storage, transfer, inventory, and leak test records of select sealed radioactive sources. Two areas storing sealed radioactive sources were examined, both were locked with restricted access controls with appropriate signs displayed prominently. Inventories and leak test records showed no discrepancies.
The inspectors reviewed the education, experience, qualifications, and training of the one shipping broker to determined they meet the training requirements found in 10 CFR 71.5 and DOT requirements contained in 49 CFR Part 172, Subpart H.
The inspectors reviewed three radioactive material shipping packages, which occurred on December 5, 6, and 12, 2022. These packages were the lead and asbestos bricks that provided shielding for the VBWR vessel. The packages were sent to Waste Control Specialist in Andrews, TX as Class A waste. The inspectors reviewed the shipping paperwork and verified that they had been appropriately characterized, classified, and prepared in accordance with licensee procedure 130P005, Shipping and Receiving
Radioactive Materials, revision 9, and procedure 150P020, Class A Low Level Radwaste (LLRW) Packaging and Shipping, revision 3.
3.3 Conclusions The licensees programs for processing, handling, storage, and transportation of radioactive material were effective and conducted in accordance with procedures and regulations.
4 Exit Meeting Summary On April 12, 2023, the NRC inspectors presented the final inspection results to Charles Pedley, 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 C. Pedley, Site Manager J. Smyly, Environmental, Health and Safety Manager D. Heckman, Regulatory Affairs and Licensing Lead K. Zanotto, Facilities Manager J. Ayala, Project Management H. Bunting, Radiation Safety Officer INSPECTION PROCEDURES IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 69002 Class III Research and Test Reactors IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Discussed None Closed 0500018/
2022002-01 VIO Failure to positively control an unlocked posted high radiation area to demonstrate compliance with 10 CFR 20.1601(a).
Attachment
LIST OF ACRONYMS ADAMS Agency Documents Access and Management Systems CAM Continuous Air Monitor 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 HRA High Radiation Area NRC U.S. Nuclear Regulatory Commission VBWR Vallecitos Boiling Water Reactor VNC Vallecitos Nuclear Center NVLAP National Voluntary Laboratory Accreditation Program WEP waste evaporator plant 2