IR 05000073/2009201
| ML091260407 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 05/12/2009 |
| From: | Johnny Eads Research and Test Reactors Branch B |
| To: | Doreen Turner General Electric Co |
| Schoenebeck G, NRR/DPR, 415-6345 | |
| References | |
| IR-09-201 | |
| Download: ML091260407 (21) | |
Text
SUBJECT:
GENERAL ELECTRIC VALLECITOS NUCLEAR CENTER - NRC ROUTINE, ANNOUNCED INSPECTION REPORT NO. 50-73/2009-201
Dear Mr. Turner:
On April 14-16, 2009, the U.S. Nuclear Regulatory Commission (NRC, the Commission)
conducted an inspection at the General Electric Vallecitos Nuclear Center (Inspection Report No. 50-73/2009-201). The inspection included a review of activities authorized for your facility.
The enclosed report presents the results of that inspection.
This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, no safety concern or noncompliance with NRC requirements was identified. However, one inspector follow-up item from a previous inspection was discussed and closed. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC=s document system (Agencywide Document Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room)
http://www.nrc.gov/reading-rm/adams.html. Should you have any questions concerning this inspection, please contact Greg Schoenebeck at 301-415-6345 or by electronic mail at Greg.Schoenebeck@nrc.gov.
Sincerely,
/RA/
Johnny H. Eads, Jr., Chief Research and Test Reactors Branch B Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-73 License No. R-33 Enclosure:
As stated cc: See next page
General Electric Docket No. 50-73 cc:
Mr. Donald Krause, Manager Regulatory Compliance and EHS Vallecitos Nuclear Center General Electric Company 6705 Vallecitos Road Sunol, CA 94586 Mr. Dan Thomas Manager NTR Vallecitos Nuclear Center General Electric Company 6705 Vallecitos Road Sunol, CA 94586 Mr. Harold Neems General Electric Company Nuclear Energy Business Operations 175 Cutner Avenue Mail Code 123 San Jose, CA 95125 Commissioner California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 California Department of Health ATTN: Chief Radiologic Health Branch P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
ML091260407 NRR-106 OFFICE PRTB:RI PRT:LA PRT:BC NAME GSchoenebeck GLappert JEads DATE 5/6/09 5/6/09 5/12/09
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-73 License No: R-33 Report No: 50-73/2009-201 Licensee: General Electric Company Facility: Nuclear Test Reactor (NTR)
Location: Sunol, CA Dates: April 14-16, 2009 Inspectors: Gregory M. Schoenebeck Patrick Isaac Approved by: Johnny Eads, Chief Research and Test Reactors Branch B Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY General Electric Vallecitos Nuclear Center NRC Inspection Report No. 50-73/2009-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the General Electric Company (the licensee) Class II research reactor facility safety programs including organization and staffing; operations logs and records; procedures; requalification training; surveillance and limiting condition of operation (LCO); experiments; health physics; design changes; committees, audits and reviews; emergency planning; maintenance logs and records; and fuel handling logs and records. The licensee=s programs were acceptably directed toward the protection of public health and safety, and were in compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements.
Organization and Staffing
- Organizational structure and responsibilities were consistent with Technical Specification requirements.
- Shift staffing met the minimum requirements for current operations.
Operations Logs and Records
- Operation logs and recordkeeping program conformed to Technical Specification requirements.
Procedures
- Procedure administrative review, revision, adherence to, and implementation satisfied Technical Specification requirements.
Operator Requalification
- Operator requalification was conducted as required by the Requalification Program and Title 10 of the Code of Federal Regulations (10 CFR) Part 55.
Surveillance and LCO
- Limiting conditions for operation and surveillances required by Technical Specifications were being properly implemented.
Experiments
- There were no new experiments since the last inspection. Previous experiment review and approval was done in accordance with TS requirements, licensee procedures, and 10 CFR 50.59 regulations.
-2-Health Physics
- The radiation safety program is commensurate with 10 CFR 20 requirements, Technical Specifications, and Procedures.
Design Changes
- Design changes were made in accordance with 10 CFR 50.59 requirements, TS, and licensee procedures.
Committees, Audits, and Reviews
- The RC provided the oversight required by the Technical Specifications.
Emergency Planning
- The emergency preparedness program was conducted in accordance with the Emergency Plan and implementing procedures.
Maintenance Logs and Records
- Maintenance was performed and logs and records maintained consistent with Technical Specification and licensee procedure requirements.
Fuel Handling Logs and Records
- The licensee does not have a program for fuel handling at the NTR.
Transportation
- Due to the nature of the VNC operations, there is typically no shipment of reactor licensed radioactive material. In one instance, since the last inspection, the transfer of radioactive material was performed in accordance with procedures.
REPORT DETAILS Summary of Facility Status The General Electric Companys (the licensees) 100 kilowatt research reactor has been operated in support of neutron radiography, reactor operator training, and periodic equipment surveillances. During the performance based aspect of the inspection, the reactor was operated to support this area.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001)
The inspectors reviewed the following to verify compliance with the organization and staffing requirements in Technical Specification (TS) Section 6.1:
- General Electric (GE) Nuclear Test Reactor (NTR) organizational structure and staffing
$ Organization Chart for the GE Vallecitos Nuclear Center, dated January 1, 2007
$ Standard Operating Procedure 6.1 "Staffing Requirements" Revision 941, dated September 8, 2004 b. Observations and Findings Since the last inspection (see NRC Inspection Report No. 50-73/2007-202, ADAMS # ML0718703651) the licensee designated a new manager of Regulatory Compliance and Environmental Health and Safety. Current NRC licensed staff consisted of four Senior Reactor Operators (SROs) and one Reactor Operator (RO). The reactor operations staff=s qualifications satisfied the training and experience requirements stipulated in the TS. The operations log and associated records confirmed that shift staffing met the minimum requirements for duty personnel. Review of records verified that management responsibilities were administered as required by TS and applicable procedures.
c. Conclusions The organization and staffing was consistent with TS requirements.
2. Operations Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to ensure that the operations program was being implemented as required in TS Sections 3, 4, and 6:
- NTR Console Log Books, dated from May 10, 2007 to November 10, 2008
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- Annual Report No. 49 for NTR, dated March 2009
- Annual Report No. 48 for NTR, dated March 2008
- Completed NTR Control Room Data Sheets (SOP 6.8), dated from March 2, 2009 to April 15, 2009
- Vallecitos Technological Safety Council (VTSC) meeting minutes, Third Quarter, dated September 5, 2008
- VTSC meeting minutes, Second Quarter, dated April 24, 2008
- VTSC meeting minutes, First Quarter, dated February 4, 2009
- NTR Preventive Maintenance Index and Completion Record, 2008
- NTR Monthly PM Schedule January 2007 to April 2009
- SOP 6.4 Daily Surveillance Check Sheet dated June 13, 2007 b. Observations and Findings Reactor operations were carried out following written procedures and TS requirements. The inspector observed the performance of the required checklist for operation of the reactor. Additionally, a reactor start-up to power was observed. The inspector noted that the licensed operator on duty was knowledgeable and competent. The inspector verified that reactor operating characteristics, and other TS and procedure required entries, were recorded on the appropriate forms and logs. A review of the forms and logs indicated that TS operational limits had not been exceeded. The inspector determined that reactor operations were carried out in accordance with written procedures and TS requirements.
c. Conclusions Operational activities were consistent with applicable TS and procedural requirements.
3. Procedures a. Inspection Scope (IP 69001-02.03)
The inspectors reviewed the following to ensure that the requirements of TS Section 6.4, Operating Procedures, were being met concerning written procedures:
- Administrative Procedure 9.2 "Standard Operating Procedures" Revision 995, dated September 10, 2008
- Administrative Procedure 9.3 Engineering Release (ER) Revision 992, dated September 10, 2008
- Administrative Procedure 9.4 Change Authorization Revision 561, dated February 7, 2086
- NTR Commercial Procedures Manual, dated September 22, 2008
- ER 08-27, Revision 0 Replace Rubber Stops and Bearings on All Safety Rods, dated December 16, 2008
-3-b. Observations and Findings Oversight and review of procedure implementation was provided by licensee management. Written changes were reviewed and approved by the NTR Manager and the RC manager as required. Records showed that procedures for TS required items were available. The inspector reviewed several of the procedure changes that were initiated since the last inspection and determined that the changes were appropriately analyzed. The inspector confirmed that when a procedural change was required, the change was documented using the Change Authorization (CA) process found in Standard Operating Procedure (SOP) 9.4. The inspector verified that CAs were approved and provided the bases for the determination that the proposed change is allowed by the license and TS. The inspector also noted that when changes were required, special attention was placed on 10 CFR 50.59 considerations.
c. Conclusions Procedure administrative review, revision, adherence to, and implementation satisfied Technical Specification requirements.
4. Operator Requalification a. Inspection Scope (IP 69001)
The inspectors reviewed selected portions of the following to ensure that the NRC approved Requalification Program was being acceptably implemented:
- Reactor Operator Requalification Written Examination, 2008
- Senior Reactor Operator/Reactor Operator Requalification Operating Examination for 2008
- NTR Memo re: NTR Requalification Administration and Program Schedule for 2008, dated January 10, 2008
- NTR Memo re: NTR Requalification Administration and Program Schedule for 2009, dated March 17, 2009
- NTR Read and Acknowledgement Records
- Requalification Training Records for 2008 - 2009 Requalification Cycle
- NTR Console Logs from May 10, 2007 to November 10, 2008
- Administrative Procedure 9.14 Reactor Operator Requalification Program Revision 855, dated November 15, 1994
- Requalification Program for the General Electric Nuclear Test Reactor, dated June 1987 b. Observations and Findings Current NRC-licensed staff consisted of four SROs and one RO. One of the four SROs is not currently enrolled in the requalification program and the licensee considers his license to be inactive. The inspectors reviewed the files of operators, specifically checking NRC Form 396, Certification of Medical
-4-Examination by Facility Licensee. The inspectors verified that physical examinations of the operators were conducted biennially as required. The inspector also verified that all operators met the required minimum number of hours operating the reactor.
The licensees requalification program included the regulatory requirement for an annual operating test and a biennial written examination. The inspectors verified that both examinations were administered at the specified frequency and that the level of difficulty was comparable to that of NRC-administered examinations.
The inspectors confirmed that the requalification program was being administered in a manner that sufficiently maintains the effectiveness of all licensed operators.
c. Conclusions Operator requalification was conducted as required by the Requalification Program and 10 CFR Part 55.
5. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the surveillance requirements and limiting conditions for operation (LCOs) specified in TS Section 4.0 were met:
$ Standard Operating Procedure 6.4 "Daily Surveillance Check Sheet" Revision 985, dated June 13, 2007
$ Standard Operating Procedure 6.5 "Monthly Surveillance Check Sheet" Revision 644, dated November 16, 2006
- NTR Monthly PM Schedule, dated January 2007 to April 2009
$ Preventive Maintenance Procedure 12.3 "Safety Rod Drives" Revision 511, dated March 6, 1985
$ Completed SOP 6.4 forms, dated from March 2, 2009 to present
$ Completed SOP 6.5 forms, dated from January 2007to present
$ Completed PM forms, dated January 5, 2009 to present b. Observations and Findings The inspector verified that TS required surveillance were completed on schedule and in accordance with licensee procedures. The procedures for the surveillances provided clear and concise direction and control of reactor operational tests and surveillances. The protocols and techniques were effective in verifying the performance of the safety equipment. The records and logs were complete and were being maintained as required.
-5-The inspector observed the licensee complete a daily checklist for TS required items. All of the items on the checklist were carried out appropriately and the personnel conducting the tests did so in a safe and knowledgeable manner.
c. Conclusions The limiting conditions for operation and surveillances required by TS Sections 3.0 and 4.0 were being properly implemented.
6. Experiments a. Inspection Scope (IP 69001)
In order to verify that any modifications to the facility were consistent with TS requirements, procedures, and 10 CFR 50.59 regulations, the inspector reviewed selected aspects of:
- Annual Report No. 49 for NTR, 2008
- Annual Report No.48 for NTR, 2007
- VTSC Meeting Minutes for 2008 b. Observations and Findings The licensee had not implemented a new procedure requiring review and approval by the NTR manager since the last inspection. The inspector reviewed the last experiment reviewed and approved since the last inspection, and determined that the process was performed in accordance with procedures, TS, and 10 CFR 50.59 requirements.
c. Conclusions There were no new experiments since the last inspection. Previous experiment review and approval was done in accordance with TS requirements, licensee procedures, and 10 CFR 50.59 regulations.
7. Health Physics c. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Part 20 requirements:
- Annual Report No. 49 for NTR, 2008
- Annual Report No.48 for NTR, 2007
- ALARA Committee Agenda, 2/12/2009
- Change Authorization Standard No. 2.0 Rev.10, 10/08
- Change Authorization Log, various 2009
- Effluent Monitoring and Environmental Surveillance Programs
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- Engineering for ALARA Standard No. 5.8.1 Rev. 5, 11/94
- GE VNC Nuclear Safety Survey Record, various 2009
- Building 105 (NTR) Surveys January 1 to March 31, 2009
- Review of NTR Radiation Work Permit, September 18, 2008
- Review of NTR Radiation Work Permit, December 5, 2008
- Review of NTR Radiation Work Permit, July 18, 2008
- NTR DIGIDOSE Tracking Record, 1st Quarter 2009
- NTR DIGIDOSE Tracking Record, 2nd Quarter 2009
- Landauer Radiation Dosimetry Report , 1/20/09
- NTR Preventative Maintenance Stack Gas Monitor, 5/5/2008
- NTR Preventative Maintenance Constant Air Monitor, 5/5/2008
- Standard Operating Procedure: 12.38 Stack Flowrate Measurement
- VTSC Meeting Minutes-2nd Quarter 2008, 4/24/2008 b. Observations and Findings The GE VNC facility implements the principles of As Low As Reasonably Achievable (ALARA) through its ALARA Committee. Formed in 2008, the ALARA committees mission is to set goals for person-rem, thereby reducing overall dose, increasing exposure awareness, and developing new processes to reduce overall dose. The ALARA committee has approached the various groups onsite, including Reactor Operations, about implementing dose reduction for their activities. The Reactor Operations group has identified that a significant portion of daily dose involves the checks of the seismic and conductivity meters within a high radiation area. The group intends to address this issue by installing remote monitoring indication within the control room to avoid undue exposure. Currently, the Reactor Operations group is working with the ALARA committee to determine if this is a viable option to be performed during the next extended reactor shutdown period when preventative maintenance is normally performed.
The inspector observed a smear survey conducted upon completion of radiography processing. The survey was conducted in accordance with SOPs by the shutdown reactor operator. Radiation Work Permits (RWPs) were performed as required by licensee procedures. The RWPs provide the guidance for expected radiation conditions in work areas, special instructions for working in the area, and protective clothing and equipment requirement for work.
The inspectors reviewed effluent discharge records and determined that radiological gaseous effluent releases to the environment were in accordance with 10 CFR 20. The facility did not discharge radiological effluent waste to the sewer system in 2008.
c. Conclusions The inspectors determined that the licensee health physics program and operations were in compliance with 10 CFR 20 regulations, licensee procedures, and TS.
-7-8. Design Changes a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that if design changes were made, they were reviewed and approved in accordance with 10 CFR 50.59, the TS, and the licensees administrative procedures:
- Change Authorization No. CA-283, Safety Rod Replacement Part (Rubber Stop), March 10, 2008
- Rubber Gasket Material Property Sheet A12A7
- Nitrile Rubber Molded Parts A12C20
- Administrative Procedure 9.3 Engineering Releases Rev. 992, September 10, 2008
- Administrative Procedure 9.4 Change Authorization Rev. 561, February 7, 2006 b. Observations and Findings The inspectors reviewed applicable records and interviewed licensee personnel with regards to the design change process at the NTR. Upon review of a random selection of Change Authorizations, it was determined that the independent reviews were performed in accordance with licensee technical specifications.
The inspector verified that Change Authorization included a 10 CFR 50.59 safety analysis performed by the Regulatory Compliance (RC) manager or the VTSC based on the complexity of the project with emphasis on safety of the reactor facility and reactor staff.
The inspectors reviewed the Change Authorization process for the replacement for Safety Rod rubber stop. The material specification used in the original design of the rubber stop had been discontinued. The purpose of this rubber stop is to prevent metal-to-metal contact at the end of normal scram motion between the surface of the dashpot and the coupling region of the control rod. The licensee performed a detailed review for replacement parts, identifying the properties of the replacement material to determine radiological, health, and environmental hazards.
c. Conclusions Design changes were made in accordance with 10 CFR 50.59 requirements, TS, and licensee procedures.
-8-9. Committees, Audits, and Reviews a. Inspection Scope (IP 69001)
The inspectors reviewed the following to ensure that the audits and reviews stipulated in TS Section 6.2 were being completed by the cognizant Safety Review Groups:
- 2008 Annual Report No. 49 for NTR, dated March 2009
- 2007 Annual Report No. 48 for NTR, dated March 2008
- Charter of Vallecitos Technological Safety Council (VTSC), dated December 2008
- VSS 1.1.1,VTSC Membership Listing
- VTSC meeting minutes, Third Quarter, dated September 5, 2008
- VTSC meeting minutes, Second Quarter, dated April 24, 2008
- VTSC meeting minutes, First Quarter, dated February 4, 2009
- Incident Investigation Number 08-01, dated April 10-25, 2008 b. Observations and Findings The inspectors verified that the VTSC composition, meeting quorums, and meeting frequency were all in accordance with TS Section 6.2. The inspector verified that the VTSC is following all aspect of its charter. The VTSC had quarterly meetings and a quorum was always present as required. The inspectors also verified that independent reviews required by TS 6.2 were completed by appointed individuals. The inspectors noted that the licensee responded to audit findings and ensured that corrective actions were properly completed.
c. Conclusions The VTSC provided the oversight required by the Technical Specifications.
10. Emergency Planning a. Inspection Scope (IP 69001)
To verify that the licensee was implementing and complying with the Emergency Plan (E-Plan) requirements, the inspector reviewed selected aspects of:
- Vallecitos Nuclear Center Reactor Facilities Radiological Emergency Plan, October 1981 (Revised November 2007)
- Vallecitos Nuclear Center Respiratory Protection Qualification, October 14, 2008
- Respiratory Protection Fit Test, Annual Test, 2008
- Respiratory Protection Written Exam, 2008
- Respiratory Clearance Evaluation , 2008
- Mobile Equipment Platform Inventory of Supplies
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- General Emergency Response and Building Emergency Team Training Records, March 25, 2009
- MOU between ValleyCare Medical Center, Pleasanton and GE VNC, January 30 2009 b. Observations and Findings The inspectors followed up on an Unresolved Item (URI) 50-73/2007-201-01, Failure to renew the Memorandum of Understanding (MOU) with the Alameda County Sheriffs Office and the ValleyCare Medical Center. Upon further review it was determined that the MOU was renewed for another two year. Based on this information, the URI is closed.
The E-Plan currently in use is the correct revision being used by the licensee.
There are hardcopy versions in various locations of Building 105 and at the Emergency Support Center. In addition to the hardcopies available at certain locations, the E-Plan is readily available throughout the facility via the licensees intranet.
Training for facility operators, staff, and members of the VNC having emergency response duties complete an initial training program and annual review, in accordance with procedures.
The documentation of the drill was reviewed. Emergency preparedness and response training was completed on an annual basis. Through drill scenario and record reviews, emergency responders were determined that key emergency response personnel can respond to an emergency condition as required.
Emergency drills had been conducted annually as required by the E-Plan.
Critiques were written following the drills to document the strengths and weaknesses identified during the exercise. Action items were developed to correct the deficiencies.
c. Conclusions The emergency preparedness program was conducted in accordance with the approved E-Plan and implementing procedures.
11. Maintenance Logs and Records a. Inspection Scope (IP 69001)
To verify that the licensee was complying with the applicable regulations, the inspector reviewed selected aspects of:
- NTR Preventive Maintenance Index and Completion Records, Year 2008
- PMP 12.3, Safety Rod Drives, Revision 511, dated March 6, 1985
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- NTR Corrective Maintenance Safety Rod #1, dated March 11, 2008
- NTR Corrective Maintenance Safety Rod #4, dated March 10, 2008
- NTR Preventive Maintenance Safety Rod #4, dated January 9, 2008
- ER 08-02, safety Rod #4 General Maintenance/Repairs, dated January 3, 2008
- ER 08-09, Troubleshoot Safety Rod #4 Alignment Problem, March 11, 2008
- ER 09-03, Safety Rod Dashpot Housing Bolt Position Log, dated February 26, 2009
- CA 285, Safety Rod Drive #1 Alignment, dated March 11, 2008
- CA 286, Safety Rod Rubber Stop Insertion Results and Response, dated July 7, 2008
- CA 283, Safety Rod Replacement Part (Rubber Stop), dated March 10, 2008
- SOP 4.2, Safety Rod Repairs, Revision 668, dated September 20, 1988
- SOP 3.2, Safety Rods, Section 6.5 and 6.6 b. Observations and Findings The inspectors reviewed the maintenance records related to scheduled and unscheduled preventive and corrective maintenance activities that had occurred during the inspection period. Routine and preventive maintenance was controlled and documented in the appropriate logs. The inspector verified that all maintenance was conducted in accordance with the requirements of TS Section 4.0. After all maintenance items were completed, system operational checks were performed to ensure the affected systems were operable before returning them to service The inspectors reviewed the records for the replacement of rubber stop on one safety rod. The replacement was performed because the original part had deteriorated and was no longer able to perform its intended function. An Engineering Release (ER 08-02) was written and work performed to replace the deteriorated rubber part. Following the maintenance, the licensee discovered that the wrong part was installed which caused the safety rod to bind in the fully inserted condition. The licensee conducted an investigation and installed a properly configured part. The licensees investigation identified the root causes, evaluated their maintenance procedures, and made recommendations to prevent an occurrence of a similar incident. The safety rod was tested and passed all operational tests satisfactorily.
c. Conclusions Maintenance logs, records, and performance satisfied TS and procedure requirements.
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12. Fuel Handling Logs and Records a. Inspection Scope (IP 69001)
The inspectors reviewed the following to verify compliance with requirements of TS and procedural requirements:
- Fuel movement records b. Observations and Findings Currently, there are no fuel handling procedures at the facility. The licensee does not conduct fuel movements and fuel inspection is not required by TS. In the event fuel handling is required, the licensee indicated it would create procedures to conduct such operations.
c. Conclusions The licensee does not have a program for fuel handling at the NTR.
13. Transportation a. Inspection Scope (IP 86740)
The inspectors interviewed licensee personnel and reviewed the following records to verify whether the licensee has established and is maintaining an effective management-controlled program, to ensure radiological and nuclear safety for shipping licensed radioactive material:
- Annual Report for License R-52, Docket 50-113, dated August 21, 2008 b. Observations and Findings By nature of its operations, the VNC does not typically conduct waste transfer to or from the R-33 license. Most material transfer occurs within the scope of the VNC materials license. Occasionally, radiography operations may involve the shipment of SNM to the North Building where, by procedure, it can be temporarily transferred from one VNC Criticality Limit Area to the RTR VNC Criticality Limit Area (CLA) without being transferred to the R-33 license. The said transfers may occur as long as they do not exceed: 1.) the total material on the temporary movement status shall not exceed a material in transit limit; 2.) the receiving CLAs limits; and 3.) the material is returned no later than the next consecutive working day to the original CLA. In one instance, the inspectors found that there was SNM transferred to the RTR VNC CLA due to the need for storage longer than the timeframe identified previously. The inspector verified that the licensee performed the material transfer in accordance with procedures and that the associated documentation was properly filled out and approved.
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c. Conclusions Due to the nature of the VNC operations, there is typically no shipment of reactor licensed radioactive material. In one instance, since the last inspection, the transfer of radioactive material was performed in accordance with procedures.
14. Exit Interview The inspector presented the inspection results to licensee management at the conclusion of the inspection on April 16, 2009. The inspector described the areas inspected and discussed in detail the inspection observations. No dissenting comments were received from the licensee. The licensee acknowledged the observations presented and did not identify as proprietary, any of the material provided to or reviewed by the inspector during the inspection.
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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Turner, VNC Manager D. Thomas, NTR Manager D. Krause, EHS and Regulatory Compliance Manager J. Ayala, Radiation Monitoring Specialist Other Personnel K. McKinney, Contract Guard Force Supervisor (Wackenhut)
INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Transportation ITEMS OPENED, CLOSED, AND DISCUSSED OPENED None CLOSED 50-73/2007-202-01 URI Failure to renew the Memorandum of Understanding with the Alameda County Sheriffs Office and the ValleyCare Medical Center Discussed None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Document Access and Management System ALARA As Low As Reasonably Achievable ECP Estimated Critical Position GE General Electric Company IP Inspection Procedure LCO Limiting Condition of Operation MOU Memorandum of Understanding NRC Nuclear Regulatory Commission NTR Nuclear Test Reactor Rev. Revision RO Reactor Operator RC Regulatory Compliance
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RWP Radiation Work Permit SRO Senior Reactor Operator TS Technical Specifications URI Unresolved Item VNC Vallecitos Nuclear Center VTSC Vallecitos Technological Safety Council