IR 05000018/2024001

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GE Hitachi Nuclear Energy - NRC Inspection Report 05000018/2024-001, 050 00070/2024-001, 050-00183/2024-001, and 050-00073/2024-001
ML24143A190
Person / Time
Site: Vallecitos Nuclear Center, Vallecitos
Issue date: 05/29/2024
From:
NRC/RGN-IV/DRSS/DIOR
To: Martinez C
GE Hitachi Nuclear Energy
Johnson M
References
IR 2024001
Download: ML24143A190 (12)


Text

May 24, 2024

SUBJECT:

GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT 050-00018/2024-001, 050-00070/2024-001, 050-00183/2024-001, AND 050-00073/2024-001

Dear Carlos Martinez:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on April 29 - May 2, 2024, 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); Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR); and Nuclear Test Reactor (NTR). The NRC inspectors discussed the results of this inspection with you and members of your staff on May 2, 2024. 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, if you choose to provide one, 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 regarding this inspection, please contact Troy Johnson at 817-200-1596, or the undersigned at 817-200-1249.

Sincerely, Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket Nos. 050-00018, 050-00070, 050-00183, 050-00073 License Nos. DPR-1, TR-1, DR-10, R-33 Enclosure:

Inspection Report 050-00018/2024-001, 050-00070/2024-001, 050-00183/2024-001, 050-00073/2024-01 Signed by Warnick, Gregory on 05/24/24

ML24143A190 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: MTJ Yes No Non-Sensitive Publicly Available NRC-002 OFFICE SHP:DRSS/DIOR SHP:DRSS/DIOR HP:DRSS/DIOR C:DRSS/DIOR NAME TJohnson SAnderson CDennes GWarnick SIGNATURE MTJ SMG CRD GGW DATE 05/22/24 05/24/24 05/24/24 05/24/24

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos. 050-00018; 050-00070; 050-00183; and 050-00073

License Nos. DPR-1; TR-1; DR-10; and R-33

Report Nos. 050-00018/2024-001; 050-00070/2024-001; 050-00183/2024-00; and 050-00073/2024-001 Licensee: GE Hitachi Nuclear Energy

Facility: Vallecitos Boiling Water Reactor (VBWR)

GE Test Reactor (GETR)

ESADA Vallecitos Experimental Superheat Reactor (EVESR)

Nuclear Test Reactor (NTR)

Location: 6705 Vallecitos Road Sunol, California

Inspection Dates: April 29 - May 2, 2024

Inspectors: M. Troy Johnson, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Stephanie G. Anderson, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Christian R. Dennes, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By: Gregory G. Warnick, Branch Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Enclosure EXECUTIVE SUMMARY

GE Hitachi Nuclear Energy NRC Inspection Report 050-00018/2024-001; 050-00070/2024-001; 050-00183/2024-001; and 050-00073/2024-001

This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of licensed activities being conducted at the three permanently defueled reactors and one permanently shutdown test reactor at the Vallecitos Nuclear Center (VNC). 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 Reviews at Permanently Shutdown Reactors and Class III Research and Test Reactors

  • The licensee conducted decommissioning activities and Class III research and test reactors activity in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the site. Staffing level and qualification met minimum requirements. (Section 1.2)

Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

  • The licensee implemented its safety review program in accordance with site 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)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

  • The inspectors did not identify any significant deficiencies in the licensees radioactive waste management or transportation of radioactive materials programs and procedures. (Section 4.2)

Occupational Radiation Exposure at Permanently Shutdown Reactors

  • The inspectors determined the licensee ensured adequate protection of worker health and safety from exposure to radiation or radioactive material in accordance with regulations.

(Section 5.2)

Report Details

Summary of Plant Status

The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) maintains four shutdown reactors: Vallecitos Boiling Water Reactor (VBWR); General Electric Test Reactor (GETR);

Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR); and Nuclear Test Reactor (NTR). GETR and EVESR are in a possession-only, safe storage (SAFSTOR) condition, with no fuel remaining in the reactors or spent fuel pools. At the time of the inspection, VBWR was classified as an Inspection Manual Chapter 2561, Category 3 decommissioning site. In the letter dated January 26, 2024, the licensee informed the NRC that it had permanently ceased operation of the NTR on December 21, 2023 (ML24054A539). On February 28, 2024, the NRC issued amendment 26 which revised the Renewed Facility Operating License No. R-33 and the associated technical specifications to remove the authority to operate the NTR, to authorize possession-only of the reactor and fuel, to remove operational requirements not needed for the possession-only status, and to replace the requirement for NRC-licensed reactor operators with certified fuel handlers (ML24031A622).

Since the last inspection, GEH has been preparing to transfer the site to NorthStar Group, this has included a reduction in staffing and curtailment of any decommissioning related activities.

1 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors (71801) and Class III Research and Test Reactors (69002)

1.1 Inspection Scope

The inspectors observed site activities, reviewed materials, and interviewed site personnel:

  • To evaluate the status of decommissioning and verify whether the licensee was conducting decommissioning activities in accordance with regulatory and license requirements.
  • To maintain awareness of work activities to assess licensee control and conduct of decommissioning.
  • To determine if activities at Class III research and test reactors were conducted safely and in accordance with regulatory requirements and licensee commitments, since the last inspection.

1.2 Observations and Findings

a. Status of Decommissioning

At the time of the inspection the licensee had curtailed decommissioning activities in preparation for license transfer to NorthStar Group. While normal day to day routine maintenance was being performed, no decommissioning activities were in progress.

b. Decommissioning Operations

The inspectors performed plant tours of VBWR, EVESR, GETR, and NTR including radiologically controlled areas and containments to assess field conditions and decommissioning activities. Also, the inspectors evaluated the material condition of

structures, systems, components, housekeeping, system configurations, worker level of knowledge, as well as procedure use and adherence.

The inspectors evaluated whether the licensee's organization and staffing were appropriately adjusted for changes in the status of decommissioning. The inspectors determined the licensee staffing met the minimum requirement to ensure reasonable assurance of safety and security in accordance with regulatory requirements and the license.

c. Decommissioning and Class III Research and Test Reactors Staffing and Training

The inspectors reviewed select radiation protection and transportation staff records to determine if they were trained in accordance with license and regulatory requirements and found that personnel qualifications and training were both current and adequate.

d. Decommissioning Planning, Scheduling, and Cost Assessment

The inspectors reviewed the licensees decommissioning strategy and schedule to determine whether the licensee had made any changes to decommissioning schedule or major milestones in accordance with Title 10 Code of Federal Regulations (CFR)

50.82(a)(7) and noted that no significant changes had been made.

e. Problem Identification and Resolution

The inspectors reviewed a sample of problems documented in the corrective action program and verified that the licensee had identified and implemented appropriate corrective actions.

1.3 Conclusions

The licensee conducted decommissioning activities and Class III research and test reactors activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the site. Staffing level and qualification met minimum requirements. No significant findings were identified.

2 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (37801)

2.1 Inspection Scope

The inspectors independently gathered sufficient information to determine whether licensee performance meets the following objectives:

  • To verify the licensees safety review process was in accordance with the requirements of 10 CFR 50.59, Changes, tests, and experiments.
  • To provide assurance that required license amendments have been obtained.

2.2 Observations and Findings

a. Decommissioning Safety Review Program

The inspectors reviewed procedure VSS 2.0, Change Authorization, revision 27, and determined that the procedure was adequate to identify changes to technical specifications resulting from proposed changes, tests, experiments, and modifications as applicable.

The inspectors reviewed training document VNC 50.59 Change Process Training and determined that the licensees safety review process committee is appropriately staffed and trained in accordance with regulatory requirements.

b. Design Changes, Tests, Experiments, and Modifications

The inspectors have reviewed four Change Authorizations (CA) screenings. The four CA screenings had been completed since the last inspection. The four CAs were CA-2023-03-VBWR Vessel Removal-Final, CA-2024-03-Restoring the Dome Roof, CA-325-Time Domain Reflectometry - RPM Irradiation Test, and CA-326-Optical Fiber Based Gamma Thermometer Probe Irradiation Test. The inspectors assessed the details of each CA and found the judgments appropriate relative to 10 CFR 50.59.

2.3 Conclusions

The licensee implemented its safety review program in accordance with site procedures and regulatory requirements. No findings of significance were identified.

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 four shutdown reactors:

  • To evaluate the effectiveness of licensee controls in identifying, resolving, and correcting issues in accordance with the NRC approved Quality Assurance (QA)

Program and 10 CFR Part 50, Appendix B, Criterion XVI.

  • To determine whether the audits and assessments were conducted in accordance with the requirements of the NRC-approved QA program and 10 CFR Part 50, Appendix B.
  • To confirm that the licensee has established, implemented, and performed management reviews of the safety conscious work environment.

3.2 Observations and Findings

a. Corrective action programs

At the time of the inspection, the licensee was implementing its corrective action program under procedures CP-16-108, Corrective Action Program, revision 16, and associated implementing procedures that apply to all GEH nuclear sites.

The inspectors reviewed the licensees implementation of these procedures and a recent list of corrective action condition reports (CRs) generated since the last inspection. The following CRs associated with activities at the shutdown reactors were reviewed to verify adherence to the corrective action procedures - CRs 45848, 45849, 45850, 45851, 45861, 45862, and 45866. The inspectors evaluated each CR and determined corrective actions taken were in accordance with regulatory requirements.

b. Safety Conscious Work Environment

The inspectors reviewed licensee procedure CP-22-300, Ombuds Program, revision 4.1, for addressing concerns raised by employees and contractors. The inspectors determined that the licensee was appropriately documenting and addressing issues identified by these reports in the corrective action program.

3.3 Conclusions

The inspectors concluded that the licensee was adequately implementing its corrective action program in accordance with regulatory requirements. No findings of significance were identified.

4 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)

4.1 Inspection Scope

The inspectors observed site activities, reviewed documents, and interviewed site personnel:

  • To verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.

4.2 Observations and Findings

a. Radioactive Material Storage and Control

The inspectors toured the radioactive waste storage facilities to observe the condition and marking of radioactive materials and to verify that radioactive materials were controlled, labelled, posted, and secured against unauthorized removal. Additionally, the inspectors verified that the areas met the requirements of their licensing basis.

The inspectors reviewed the documentation for a sealed source leak check from the licensees inventory. The survey results of the 24 sources were all under the minimum detectable activity for alpha and beta emitters. The inspectors noted the documentation to be adequate.

b. Radioactive Waste Processing

The inspectors observed a waste processing system and walked down accessible portions of the system to verify that the current system configuration and operation were in accordance with license commitments.

c. Transportation of Radioactive Materials

The inspectors interviewed licensee personnel who prepare shipping papers and found they had adequate knowledge to ensure documentation was prepared as required by NRC and U.S. Department of Transportation (DOT) regulations. The inspectors reviewed select licensee shipping papers and noted the preparation as adequate.

The inspectors also reviewed procedure 7.3, Radioactive Waste, revision 21, for procedures and standards in regard to generating, characterizing, handling, inventorying, storing, packaging, and shipping of low-level radioactive waste. The inspectors also reviewed procedure 150P020, Class A Low Level Radwaste Packaging and shipping, revision 3, for requirements for packaging, labeling, marking, surveying, and shipping of Class A radioactive waste for transportation and disposal. The inspectors determined that the licensee had an adequate program for processing, handling, storage, and transportation of radioactive material that meets regulatory requirements.

4.3 Conclusions

The inspectors did not identify any significant deficiencies in the licensees radioactive waste management or transportation of radioactive materials programs and procedures.

5 Occupational Radiation Exposure at Permanently Shutdown Reactors (83750)

5.1 Inspection Scope

To independently gather sufficient information to determine whether licensee performance meets the following objectives:

  • To ensure adequate protection of worker health and safety from exposure to radiation or radioactive material at permanently shutdown reactors.
  • To evaluate whether the licensee adequately identified problems and implemented appropriate and timely corrective actions related to occupational radiation safety.

5.2 Observations and Findings

a. Organization, Changes, and Training

Since the last inspection, the licensees organization and personnel have undergone a reduction and reorganization with the pending transfer of the site to NorthStar Group.

Notably, there was a change in the Radiation Safety Officer (RSO) as the former RSO had vacated their position. At the time of the inspection, the licensee was using an interim contracted RSO from Chesapeake Nuclear Services to fill this role. No significant changes were noted in facilities, radiation instrumentation, equipment, programs, or procedures that may affect occupational radiation protection.

b. Radiological Work Planning and Observation

At the time of the inspection, no radiological work was in progress.

The inspectors reviewed the licensees corrective action program and verified the licensee was adequately addressing and identifying the magnitude and extent of radiological hazards as well as adequately implementing appropriate radiological controls.

The inspectors verified that the licensees planning was commensurate with the risk of the work, identifying appropriate dose reduction techniques, defining reasonable dose goals, and identifying verification points where applicable.

The inspectors performed tours of the radiologically controlled areas to verify appropriate radiological postings and evaluate material conditions.

No special exposures were planned for or had occurred at the time of the inspection.

5.3 Conclusions

The inspectors determined the licensee ensured adequate protection of worker health and safety from exposure to radiation or radioactive material in accordance with regulations. No findings of significance were identified.

6 Exit Meeting Summary

On May 2, 2024, the NRC inspectors presented the final inspection results to Carlos Martinez, Site Manager, and other members of the licensees staff. All proprietary information reviewed was returned to the licensee.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee C. Martinez, VNC Site Manager J. Smyly, Regulatory Compliance Manager K. Zanotto, Facilities Manager H. Stuart, Radiation Protection Technician D. Demore, Radiation Safety Officer INSPECTION PROCEDURES IP 71801 Decommissioning Performance and Status Reviews 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 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors

ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed None

Discussed None

LIST OF ACRONYMS

ADAMS Agency Documents Access and Management Systems CFR Code of Federal Regulations CR Condition Report DOT U.S. Department of Transportation 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 NTR Nuclear Test Reactor QA Quality Assurance RSO Radiation Safety Officer VBWR Vallecitos Boiling Water Reactor VNC Vallecitos Nuclear Center

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