IR 05000070/1977001
| ML20052A835 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 04/14/1977 |
| From: | Book H, Curtis J, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20052A734 | List:
|
| References | |
| FOIA-81-483 50-070-77-01, 50-70-77-1, NUDOCS 8204290248 | |
| Download: ML20052A835 (11) | |
Text
{{#Wiki_filter:. U. S. NUCLEAR REGULATORY COMMISSION . . , ' OFFICE OF INSPECTION AND ENFORCEVINT -
REGION V
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IE Inspection Report No.
50-70/77-01 Licensee General Electric Company Docket No. 50-70 TR-1 l Vallecitos Nuclear Center License No.
' Pleasanton, California Priority Facility General Electric Test Reactor (GETR) Category C Location Pleasanton, California Type of Facility Test Reactor (50 MWt) Type of Inspection Routine, Radiological, Unannounced
Dates of Inspection March 25, 28, 30, 31 and April 1, 1977 Dates of Previous Inspection July 19-21 and Auoust 5.1976 (Radiological) /2!77 Principal Inspector ~ c __ . F. A. Wenslawski, Radiation Specialist 4 ate - ' Accompanying Inspectors ta - Y**Y
72
- 6d. R. Curtis, Radiation Specialist (March 25only) Date Other Accocipanying Personnel: None Y'!/f![[ Reviewed by / OD H.
E.' Book, Chief. Fuel Facility and Materials 'Date Safety Branch ' . IE:V Form 219 - - = l ., . s.
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Sumary of Findings Inspection Sumary . Onsite inspection performed March 25, 28, 30, 31 and April 1,1977 with a followup telephone conversation on April 7,1977.
Examined radiation protection program including organization, procedures, training, exposure control and instrumentation. Also examined control of radioactive effluent releases, emergency planning, environ-mental monitoring program and the licensee's action in response to IE Circular No. 76-03.
. Enforcement Action No items of noncompliance were identified. One apparent deviation was identified wherein the licensee was not following acceptable practice for obtaining a representative sample of particulates and radiciodine in the stack exhaust.
(Paragraph 7 of Details) Licensee Action on Previously Identified Enforcement Items Not applicable.
Unusual Occurrences
None reported.
Other Significant Findings A.
Current Findings The licensee was unable to completely substantiate that the calibration and alarm level settings of the gaseous effluent monitor were consistent with technical specification release limits. This matter is an unresolved item.
(Paragraph 7 of Details) B.
Status of Previously Reported Unresolved Items None reported.
' Management Interview At the conclusion of the inspection the results were sumarized and presented to the following licensee personnel: W. A. Smith, Manager of Nuclear Safety and Quality Assurance; P. F. Kachel, Manager of GETR Operations and R. C. Cha11 berg, Reactor Analyst. The following items . were discussed.
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The metnod of sampling the stack exhaust for particulates and radioiodine did not appear consistent with ANSI N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities " with respect to collecting a representative sample. This is a deviation.
(Paragraph 7 of Details) B.
Several problems were revealed during an effort to re-establish calibration factors used in determining alarm level settings on the stack gaseous effluent monitor. The matter was considered unresolved at the conclusion of the inspection and the licensee agreed to further evaluate past data used to substantiate alarm settings.
In a telephone conversation on April 7,1977 the licensee also agreed to complete a previously planned thorough re-calibration of the gaseous monitoring system by April 30, 1977.
(Paragraph 7 of Details) C.
Recent changes to 10 CFR 20.103 concerning exposure of individuals to airborne radioactivity were discussed with the licensee.
The licensee acknowledged the provisions of 10 CFR 20.103(f) concerning p(Paragraph 5.bofDetails)rogram modification to assure compliance with D*etails 1.
Persons Contacted W. King, Manager, Nuclear Safety Technology E. Strain, Compliance Engineer A. Abbott, Shift Supervisor ' - R. Challberg, Reactor Analyst l G. Yuhas, Radiological Protection - W. Mason, Procass Instrument Technician F. Matheny, Process Instrument Technician V. Everett, Training Specialist C. Cain, Manager, Radiological and Environmental Protection P. Webb, Radiological Engineer B. Murray., Radiological Engineer W. Fletchar, Monitor J..Kemper. Industrial Safety & Fire Prevention Specialist H. Mohr, Environmental Protection ' . e i a e. e
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Organization The licensee has had an organizational change since the last inspection.
Basic responsibility for radiation protection remains within the Nuclear Safety & Quality Assurance subsection of the Irradiation Processing Product Operation Section. Two units within NS&QA have radiological protection responsibilities.
Nuclear Safety Technology (NST) remains responsible for radiological engineering and compliance aspects while the Radiological & Environmental Protection (R&EP) ' unit now has responsibility for daily operational health physics, bioassay and environmental protection.
W. King remains the manager of NST while C. Cain has just been appointed manager of the recently formed R&EP unit.
3.
Procedures Section 9.3.3 of the license technical specifications requires that radiation control procedures be prepared and made available.
Chapter VIII, " Radiological Safety" of the GETR Standard Operating Procedures meets the intent of this requirement.
These procedures are prepared by the GETR Operations unit, reviewed by NST and approved by the Manager of Reactor Irradiations.
Discussions with personnel and review of procedures indicated that appropriate review and approvals have been occurring.
, A separate set of procedures entitled " Nuclear Safety Procedures" exists principa.lly to describe operations within the Nuclear Safety and Quality Assurance subsection.
Section 3400 of these procedures apply to GETR and provide the GETR work routines to be performed by the Nuclear Safety monitors assigned to GETR.
The work routines establish the routine surveys to be performed, the frequency of checking instrumentation and changing filters for air samples and other such routine functions.
Check off lists are maintained to assure l all the routine functions are performed.
Vallecitos Safety Standards are site wide procedures which apply to all activities at the Vallecitos Nuclear Center.
Certain topics such as radiological safety training are included in these procedures and apply to GETR.
4.
Training The responsibility for radiological safety training continues as described in IE Inspection Report No. 50-70/76-05.
The addition last June of a training specialist to the NS&QA staff appears to have i added impetus to the licensee's radiation safety training program. VSS Procedure 2.1.2, " Radiological Training / Retraining" is currently being revised to be more definitive, particularly in the area of .t ' . 5,'. . A.
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The revised procedure is expected to be issued by mid-April and will be included in the 8000 series of the Nuclear Safety Procedures.
A training program for radiation monitors is also i being planned.
For this purpose the licensee has adopted a training program developed by Argonne National Lab which is described in ANL l 7291, Rev. 1.
It is' anticipted that the program will consist of - structured selftraining with periodic discussion sessions and exams.
- It is expected that the program will take 1 1/2 years to complete.
The licensee hopes to start the program this April.
It is also anticipated at the current time that the NS&QA training specialist will be assuming the responsibility in 1978 for presenting the RadiologicaB Safety at VNC course which is presently given by Radiological and Special Services.
The NS&QA training specialist is currently coordinating. . the records of attendance at this course.
It is noted that the l ! training manual for the Radiological Safety at VNC course was reissued ' in August 1976.
The licensee's training program appeared consistent with 10 CFR l 19.12. " Instructions to Workers".
] 5.
Exposure Control ' , a.
External The licensee appears to be making a concerted effort to control radiation exposures.
Administrative approvals a.e required to exceed 1.25 Rem /qtr. or 5.0 Rem /yr.
Radiation work permits are requid for all work in radiation areas (except for GETR Operations ' personnel).
Each individual is requiied to maintain a bar graph of radiation exposures received based on dosimeter results and updates are made after badge processing. fianpower needs are determinedpriortoeachoutage(outagesoccureverytwo to three weeks) and individuals are assigned to work the outage.
Prior to the outage individual exposures are extmined and each individual is alloted a given exposure for the oatage.
If it appears the exposure will be exceeded, further administrative approval is required. A 30% safety factor is applied to all dosimeter readings.
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. - _ . . " -5-l Film badges are used to determine whole body exposure and TLD finger rings are used to monitor extremities. The licensee stated that wrist film badges are available but seldom used.
NTA film is used to monitor neutron exposure. The , ' licensee intends to discontinue the use of NTA film.
This decision is based on (1) the absence of any recorded neutron exposures l and (2) neutron surveys in the facility.
Neutron monitor will l continue for special applications. Film badges for GETR
Operations and maintenance personnel are processed at the same ' frequency as the shutdown cycle, i.e., every two to three weeks.
l Film badges for other personnel are processed monthly. The licensee stated that no exposures in excess of quarterly limits have occurred.
Review of 1976 exposure records for GETR Operations personnel indicated the following maximum quarterly exposures: first quarter, 2020 mrem; second 2080 mrem; third,1540 mrem; fourth, 1925 mrem.
A random review of other exposure records l of individuals who likely received exposure at GETR disclosed l no exposures in excess of allowable limits.
Exposure histories are maintained for all personnel. Visitor exposure records i are maintained in a card file which is applicable to the ' entire Vallecitos site. A random review of the file disclosed { no problems.
The licensee submitted an annual exposure report pursuant to 10 CFR 20.407 in February 1977.
The licensee's records indicate that termination exposure reports to NRC and the applicatic individuals are being made.
' The licensee's access controls to high radiation areas were examined during a tour of the facility.
The licensee considers the containment hatch to be the basic access control point for high radiation areas existing in the containment. The hatch is remotely unlocked from the control room. The control ' room operator has voice communications with and TV coverage of the containment hatch.
Equipment rooms within the containment are also locked to provide additional access control to high radiation areas.
Access controls to the Tank Farm area, Cask , i Storage Pad and Radioactive Waste Temporary Storage Area were ' consistent with the conditions of the exemption provided by Section 9.6 of the technical specifications.
i b.
Respiratory Protection The licensee's use of respiratory protection equipment is governed by Section J " Respiratory Protection" of Chapter VIII, " Radiological Safety" of the GETR Standard Operating Procedures.
' The licensee's respiratory protection program contains the essential elements identified in the approval letter issued by the former AEC on March 31, 1970.
The licensee stated that the principal usage of respirators at GETR is as a precautionary , measure with jobs that could generate airborne radioactivity.
Recent changes to 10 CFR 20.103 concerning the acceptability '
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The licensee acknowledged the need to re-evaluate the currently approved program and make changes where necessary to meet the revised requirements. -The licensee expects to complete this action within the one year time period permitted by the regulations.
. c.
Internal Exposures The licensee performs a whole body count on new employees . and quarterly thereafter. Whole body counts are also performed after any suspected internal deposition. The licensee stated - that no significant i.nternal depositions have occurred. A random review of records disclosed no significant instances l of internal deposition.
The records also indicated that whole ' body counting has been performed after suspected occurrences.
The licensee has recently acquired some new whole body counting equipment consisting of a Nuclear Data 600 multichannel analyzer and a 5x5 inch Na! detector. The detector was not yet installed as of the time of the inspection. The licensee stated that i the new equipment will provide greater sensitivity and more ease of operation. The licensee stated that gross beta urine bioassays are also performed on GETR personnel either annually or semi-annually depending upon job function. Samples are obtained from different personnel on a monthly basis to stagger the workload and have a better continuum of data, d.
Surveys The degree to which the licensee conducts contamination.
, l radiation and airborne radioactivity surveys is well defined in Nuclear Safety Procedures 3400, 3410, 3420, 3425 and 3060.
, l Review of these procedures, records of s0rveys and discussion with personnel indicated that the degree of surveys conducted-is commensurate with the radiological conditions.
' e.
IE Circular No. 76-03 The licens'ee's action in response to IE Circular 76-03, " Radiation Exposures in Reactor Cayities", dated September 13, 1976 was examined.
The licensee conducted an audit in response to the circular on 9/22/76. Results of the audit and actions taken have been documented. Review of the documentation and discussion with the licensee indicated that the licensee took appropriate action in response to the Circular.
l 6.
Instrumentation l The licensee has a variety of portable radiation survey meters.
' Instruments are located throughout the facility and are available for use by personnel in the area. Portable survey instruments are calibrated at 10 weak intervals fellowing instrue:icns i::..nuf;cc;r_r technical manuals and using a Co-60 calibration source.
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. -7- - calibrations are maintained and calibration stickers are attached to each instrument. Many instruments were observed during the course of the inspection and all were within the calibration due date.
The licensee has 28 Victoreen area radiation monitors located throughout the facility. These are calibrated at four month intervals in accordance with a preventive maintenance (PM) procedure using a Victoreen Model 848-8 field calibration unit.
The Victoreens are included in a computerized PM program. Weekly functional checks are also performed on the area monitors. The alarm level settings of all area monitors were examined during the inspection and found to be consistent with procedural requirements. The licensee's CAM's and one continuous halogen monitor are calibrated semi-annually.
No calibration procedures exist for these instruments although they are included in the PM program. A monthly check of the CAM's is done following the manufacturer's recommendations.
. 7.
Radwaste Effluents The licensee's methods of sampling and monitoring gaseous effluent releases to determine compliance with the release limits of Section 3.3 of technical specifications were examined. The licensee continuously monitors noble gas releases and samples for particulates and radiciodine with filter changes occuring weekly and twice weekly, respectively.
Continuous monitoring of particulates also is performed and results are used as a possible action indicator.
Examination of the licensee's methods of sampling and monitoring disclosed several potential problem areas.
The first concerned the degree to which the stack particulate and iodine sampling system can be considered to be collecting a representa'tive sample.
It was noted that the stack sampling probe is located close to where the containment exhaust enters the stack.
Although the licensee had planned to relocate the probe, action on the matter had ceased as of the time of the inspection.' It was also noted that the particulate / iodine sampling leg was connected to the sampling line by a teg connection and the sampling line subsequently had eight short radius.
90 elbow turns and a short length of rubber hose upstream of the . particulate and iodine collection devices. The location of the sampling probe and the design of the sampling line are not consistent with recommendations of ANSI N13.1-1969, " Guide to Sampiing Airborne Radioactive Materials in Nuclear Facilities."
The second problem concerned the calibration of the noble gas monitor.
This monitor consists of a 2" x 13/4" NaI detector monitoring a continuous flow chamber of approximately 1.3 liters in volume.
This system was calibrated sometine prior to April, 1969 by circulating known concentrations of gas through the chamber.
The basic calibration results were recorded in a document dated April 23, 1969. A review of this document resulted in several questions bearing on the adequacy of the calibration. These questions concerned: (1)there s . . . V.
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. . .. -8- , appeared to be some doubt as to the volume of the counting chamber, (2) since the instrument is energy dependent, the assumed mix of the effluent is important in interpreting instrument response.
The licensee did not know the assumed mix used for. calibration purposes but it appeared to differ from that given in the license application, APED-5000-A, (3) the calibration data appeared to significantly overestimate the instrument response to Xe-133. Since, according to APED-5000-A Xe-133 accounts for approximately 1/3 of the mixture, an underestimate , ! of the effluent release rate could occur, (4) although the instrument has been calibrated at six month intervals, it could not be established that acceptance criteria for pulse height and efficiency corresponded to the original baseline calibration performed as described in the April 23, 1969 document.
Despite these questions, evaluations performed during the inspection indicated that the alarm settings are probably conservative.
Because all questions could not be resolved during the inspection, this matter is currently considered to be an unresolved i item. The licensee intends to reevaluate past calibration data and the matter will be reviewed again by IE:V in the near future.
The licensee had recognized, prior to the inspection, potential shortcomings of the noble gas monitor and had initiated action.
! A job order dated 2/23/77 was issued to completely recalibrate the monitor using known concentrations of gas and to perform stack measurements to determine the effluent mix.
During a telephone conversation on 4/7/77 the licensee agreed to have the system calibration completed by 4/30/77.
Examinatioh of gaseous effluent release data for 1976 disclosed no instances of releases in excess of technical specification limits. During periods in February,1976 the licensee experie,nced I-131 releases higher than normal.
The maximum release occurring was approximately 35% of.the maximum permissible short term release rate. The annual average release rate for I-131 was below the permissible annual average release rate.
The licensee has had no liquid radwaste releases occurring under the GETR license. Liquid wastes are transferred by tank to the site evaporator.
Subsequent releases are under State license. The licensee is planning to install a pipeline from GETR to the evaporator to avoid the necessity of trucking the waste.
, . 8.
Emergency Planning The licensee continues to maintain the site emergency plan and
GETR emergency plan described in Section 3 of the SAR as viable , documents.
The site Industrial Safety and Fire Prevention Specialist - remains as the site emergency planning coordinator. The NS&QA training specialist has been assigned to assist in the development . O 9, e - . - -- w gr - m-e -- - e--,~~.m w-w.p, e--.-,-ww---,-~-w,------ ,,,,w,---, e-,- --- ------ . --
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of some more detailed inplementing procedures.
Draft copies of implementing procedures describing responses to a criticality and radiation releases have been prepared and are under review. Medical treatment arrangements have been made with Valley Memorial Hospital in Livermore and Washington Hospital in Fremont. The licensee stated that arrangements consist of verbal agreements. Verbal agreements have also been made with the Calif. Division of Forrestry to provide - initial offsite firefighting assistance. CDF fire fighting personnel are periodically given a tour of the Vallecitos site facilities with the last such tour occurring about two months ago.
GETR emergency equipment is identified in the GETR emergency plan.
The specified equipment was available.
It was noted during a check of the licensee's automatic card dialing system that the licensee had the wrong telephone number for the ERDA radiological assistance team. The licensee stated that the correct number would be obtained. The licensee performs weekly tests of the "All Call" announcement system and monthly testing of the "HICON" phone circuit system. Test results are documented.
The licensee conducts annual criticality and fire drills at the GETR < facility, the last drills occurring 9/15/76 and 5/21/76 respectively.
Documentation of critiques and followup actions exist. The licensee's
degree of emergency preparedness appeared consistent with the intent , of the SAR.
j 9.
Environmental Monitoring Progrim -
The licensee's radiological environmental monitoring program remains as described in IE Inspection Report 50-70/75-05 with the i exception that the environmental specialist is now assigned to NS&QA., e Radiological and Environmental Protection unit. The results of the , 1976 environmental monitoring program are doedmented in an annual
report. entitled " Environmental Surveillance for Radioactivity - Vallecitos Nuclear Center 1976", NED0-12659.
Review of the annual report and discussions with the licensee indicated that the environmental monitoring program disclosed no anomalous results.
. In discussing the stack emission data provided in the annual report, it was disclosed that the GETR noble gas releases were based on a , noble gas monitor conversion factor which appeared to give non-conservative . I ' results.
The licensee agreed to evaluate this factor along with his
reassessment of the noble gas monitor calibration discussed in ' paragraph 7.
It should be noted that the factor is only used to determine quantities of noble gas released and is not used in , evaluating release rates which are governed by technical specifications.
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Facility Tour A tour of the GETR containment and adjacent facilities was conducted.
Posting pursuant to 10 CFR 19.11 was observed to be prominently posted on a bulletin board near the change room.
Posting of radiation areas, high radiation areas and radioactive material caution signs appeared adequate.
Independent radiation surveys were made at all locations toured, substantiating the licensee's posting. No - adverse conditions were observed during the tour.
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