IR 05000073/2014201

IR 05000073-14-201 on June 2-4, 2014 at the General Electric Vallecitos Nuclear Center - NRC Routine Announced Inspection Report No. 50-73/2014-201

ML14171A622
Person / Time
Site:	Vallecitos Nuclear Center
Issue date:	07/07/2014
From:	Isaac P Research and Test Reactors Licensing Branch
To:	Caine T General Electric Co
Font O, DPR/PROB, 415-2490
References
IR-14-201
Download: ML14171A622 (17)

Text

uly 7, 2014

SUBJECT:

GENERAL ELECTRIC - NRC ROUTINE, ANNOUNCED INSPECTION REPORT NO. 50-73/2014-201

Dear Mr. Caine:

On June 2-4, 2014, the U.S. Nuclear Regulatory Commission (NRC, the Commission)

conducted a routine, announced inspection at the General Electric Vallecitos Nuclear Center (VNC) and held a subsequent phone call on June 12, 2014 and a re-exit meeting on June 13, 2014 (Inspection Report No. 50-73/2014-201). 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. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, 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 NRCs 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 Ossy Font at 301-415-2490 or by electronic mail at Ossy.Font@nrc.gov.

Sincerely,

/RA/

Patrick Isaac, Acting Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-73 License No. R-33 Enclosure:

NRC Inspection Report No. 50-73/2014-201 cc: See next page

General Electric Docket No. 50-73 cc:

Juan Ayala Radiation Safety Officer 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 P.O. Box 118300 University of Florida Gainesville, FL 32611-8300

ML14171A622 NRC-002 OFFICE NRR/DPR/PROB/RI NRR/DPR/PROB/BC NAME OFont PIsaac DATE 6/24/2014 7/7/2014

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-73 License No: R-33 Report No: 50-73/2014-201 Licensee: General Electric Company Facility: Nuclear Test Reactor (NTR)

Location: Sunol, CA Dates: June 2-4, 2014 Inspectors: Ossy Font Craig Bassett Approved by: Patrick Isaac, Acting Chief Research and Test Reactor Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY General Electric Vallecitos Nuclear Center NRC Inspection Report No. 50-73/2014-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the General Electric Company (GE, the licensee) Class II research reactor facility safety programs including: procedures; experiments; health physics; design changes; committees, audits and reviews; and transportation. The licensees 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.

Procedures

• Procedure administrative review, revision, adherence to, and implementation satisfied Technical Specification (TS) requirements.

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 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59 regulations.

Health Physics

• Periodic surveys were completed and documented as required by procedure.

• Postings and signs met regulatory requirements.

• Personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits.

• Radiation survey and monitoring equipment was being maintained and calibrated as required.

• The radiation protection training program was acceptable and training was being completed as required.

• The radiation protection and the as low as reasonably achievable programs satisfied regulatory requirements.

• Appropriate Radiation Work Permits were in place to provide guidance and precautionary requirements for on-going and emergent work at the facility.

-2-Environmental Protection

• Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

• The environmental protection program satisfied NRC requirements.

Design Changes

• Design changes were made in accordance with 10 CFR 50.59 requirements, TS, and licensee procedures.

Committees, Audits, and Reviews

• The Reactor Committee provided the oversight required by the TS.

Transportation

• The licensee made no shipments of radioactive material under the auspices of the R-33 license.

REPORT DETAILS Summary of Facility Status The General Electric Companys (GE, the licensees) 100 kilowatt research reactor has been operated in support of neutron radiography, reactor operator training, and periodic equipment surveillances. During the inspection the reactor was operated to support radiography operations.

1. Procedures a. Inspection Scope (IP 69001)

The inspectors reviewed the following to ensure that the requirements of Technical Specifications (TS) Section 6.4, Procedures, were being met concerning written procedures:

• Standard Operating Procedure (SOP) (various), reviewed December 20-21, 2012

• Engineering Releases, ER# 12-09 and ER# 12-10 b. Observations and Findings Records showed that procedures for TS required items were available. Since the last inspection it was determined that there were no substantive changes to the procedures. The licensee maintained approved procedures to satisfy the requirements of the TS.

A reactor startup was performed to support several radiography shoots. The startup was performed satisfactorily in accordance with reviewed and approved procedures.

c. Conclusion Procedure administrative review, revision, adherence to, and implementation satisfied TS requirements.

2. Experiments a. Inspection Scope (IP 69001)

In order to verify that any modifications to the facility were consistent with TS requirements, procedures, and Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59 regulations, the inspector reviewed selected aspects of:

• Annual Reports for License R-33, Docket 50-73, for the periods of January 1, 2012 through December 31, 2013

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• Nuclear Test Reactor (NTR) SOP (NTR SOP) #10.1 Experiment Type Approvals (ETAs) for explosive material radiography, various dates

• NRT Console Log, various dates b. Observations and Findings The inspectors reviewed the process for the approval and conduct of experiments at the facility; during this inspection there was a specific focus on experiments involving the radiography of explosive material in the south and north cells. The licensee recently implemented a work tracking spreadsheet with the ability to raise flags to notify of any restrictions and limitations thresholds that might be exceeded by the prepared work. The experiments and storage on site were being addressed and in adherence. The inspector determined that the experimental review process and approval for handling and storage of TNT-equivalent explosive material is in accordance with TS and approved procedures.

c. Conclusion Experiment review and approval was done in accordance with TS requirements, licensee procedures, and 10 CFR 50.59 regulations.

3. Health Physics a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with 10 CFR Part 20 and TS 4.2 and 6.3 requirements:

GE VNC dosimetry records for 2012 through the present Various forms documenting routine and special survey results for 2012 through the present Latest annual Radiation Program Review conducted by an auditor and dated March 2014 Meeting minutes of the GE Vallecitos Nuclear Center (VNC) ALARA Committee for the past two years Calibration and periodic check records for radiation monitoring instruments GE VNC Vallecitos Safety Standards (VSS), Standard No. 1.4, ALARA Committee Charter, issued February 2012 GE VNC VSS, Standard No. 5.2, Radiation Exposure Limits, Rev. 10, issued September 2011 GE VNC VSS, Standard No. 8.1, Radiological Training for VNC Employees, issued December 2008 GE VNC Nuclear Safety Procedures (NSP) No. 2100, Dosimeter Accountability, Records, and Reports, Rev. 9, issued January 2008 GE VNC NSP No. 3355, Radiological Surveys - Unrestricted Use, Rev. 10, issued October 2011

-3-GE VNC NSP No. 3550, Building 105/NTR Work Routines, Rev. 10, issued May 2008 GE VNC NSP No. 4310, Air Sample Collection Responsibility, Rev. 9, issued November 2012 GE VNC NSP No. 5100, Inventory, Inspection, and Calibration of Instruments Used for Radiation Protection of Personnel, Rev. 9, issued December 2005 GE VNC Annual Report for the GE-Hitachi NTR, No. 53, dated March 29, 2013 GE VNC Annual Report for the GE-Hitachi NTR, No. 54, dated March 31, 2014 The inspectors toured the licensees facility and observed the use of dosimetry and radiation monitoring equipment. The inspectors also interviewed staff members as well.

b. Observations and Findings (1) Surveys The inspectors reviewed daily, weekly, monthly, semiannual and annual radiation and contamination surveys of licensee-controlled areas completed by GE VNC Environmental Health and Safety (EH&S)

Department personnel. The various periodic contamination and radiation surveys had been completed within the prescribed time frame required by procedure. Survey results were evaluated to ensure that established action levels had not been exceeded.

In addition to reviewing the various surveys and evaluating the results, one of the inspectors also conducted a radiation survey of the Reactor Cell using an NRC-supplied instrument. The radiation levels noted by the inspector were comparable to those documented by the licensee on survey maps and no anomalies were noted.

(2) Postings and Notices During tours of the facility, the inspectors observed that the barrier rope, caution signs, and postings in the lower roof area over the NTR had become weather-worn and had fallen into disrepair. Also, the entrance to one controlled area did not have a cautionary sign. When the licensee was notified of these problems, they were immediately corrected.

It was noted that the restrictions established for other controlled areas were acceptable for hazards such as radiation, high radiation, and contamination and were posted as required by 10 CFR 20, Subpart J, Precautionary Procedures.

-4-Copies of current notices to workers were posted in various areas in the facility. The copies of NRC Form 3, Notice to Employees, noted at the facility were the latest issue and were posted as required by 10 CFR 19.11.

(3) Dosimetry The inspector determined that the licensee used optically-stimulated luminescent dosimeters (OSLs) for whole body monitoring of beta and gamma radiation exposure with an additional component to measure neutron radiation. The licensee also used thermoluminescent dosimeter (TLD) finger rings for extremity monitoring. The dosimetry was supplied and processed by Landauer, a vendor that was accredited through the National Voluntary Laboratory Accreditation Program.

An examination of the OSL and TLD dosimeter results, indicating exposure to radiation at the facility for the past 2 years, showed that the occupational doses, as well as doses to the public, were within 10 CFR Part 20 limits.

(4) Radiation Monitoring Equipment Calibration frequency met procedural and/or TS requirements and records were maintained as required. The inspectors verified that the instruments that were stationed for use in the Reactor Cell and in adjacent areas had been calibrated and were within the allowed calibration interval.

(5) Radiation Protection Program The licensees Radiation Protection Program was established through various standards and procedures in use at the facility. The standards and procedures were maintained and available on-line. The program included requirements that all personnel who performed work in association with radioactive material receive training in radiation protection, policies, procedures, requirements, and facilities.

(6) ALARA Program The ALARA Program was also outlined and established through various guidance documents, standards, and procedures. The ALARA program provided guidance for keeping doses ALARA and was consistent with the guidance in 10 CFR Part 20.

(7) Radiation Protection Training As noted above, people who handled radioactive material, including licensee personnel, were required to receive training in radiation

-5-protection. This was accomplished by staff members attending a class, reading material on-line, and successfully passing a written examination.

Completion of this training by reactor staff personnel was verified by EH&S Department personnel as well as by the Reactor Manager and/or the Reactor Supervisor.

(8) Radiation Work Permits (RWPs)

The inspector reviewed RWPs that had been written in 2013 and current RWPs that were in use during the inspection. There were two RWPs that remained in effect for the entire year due to the repetitive nature of the work they covered. One RWP covered normal operations and the other covered NTR outage work. Each had subsets of the RWP which were used to accomplish various tasks. It was noted that the controls specified in the RWPs were acceptable and applicable for the work being done.

Also, the RWPs had been reviewed and approved as required.

As noted in NRC Inspection Report 50-073/2012-201, the RWPs were semi-automated and used by the licensee to control and track individual dose and to make dose reduction enhancements at the NTR. The program appeared to be effective in helping to maintain doses ALARA.

a. Conclusion The inspectors determined that the Radiation Protection and ALARA Programs satisfied regulatory requirements because: 1) surveys were being completed and documented acceptably, 2) postings met regulatory requirements, 3) personnel dosimetry was being worn as required and doses were well within the NRCs regulatory limits, 4) radiation monitoring equipment was being maintained and calibrated as required, and 5) acceptable radiation protection training was being provided.

4. Effluent and Environmental Monitoring a. Inspection Scope (IP 69001)

The inspectors reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and TS Sections 3.2, 3.4, 4.2, and 4.4:

Ambient Air and Gaseous Effluent monitoring records for the period from 2012 through the present Environmental surveillance program records for the period from 2012 to the present including analytical results of samples of industrial wastewater, groundwater, stream bottom sediments, and vegetation GE VNC VSS, Standard No. 7.0, Environmental Protection - Operation of VNC Facilities/Activities and Product/Environment Interactions, Rev. 7, issued March 2008

-6-GE VNC NSP No. 9000, Environmental Protection, Rev. 4, issued August 1999 Documentation of dose calculations using the EPA COMPLY program version 1.6 for 2012 and 2013 of gaseous effluents GE VNC Annual Report, 2012 Effluent Monitoring and Environmental Surveillance Programs, dated February 28, 2013 GE VNC Annual Report, 2013 Effluent Monitoring and Environmental Surveillance Programs, dated February 28, 2014

• Annual Reports for License R-33, Docket 50-73, for the periods of January 1, 2012 through December 31, 2013 b. Observation and Findings The inspectors reviewed the records documenting treated sanitary and industrial wastewater disposal for the past 2 years. This water was either held in retention basins or disposed of by using an on-site irrigation system. No liquid was released off-site in accordance with policy and procedure. The results of the water disposal were acceptably documented in Annual Effluent Monitoring and Environmental Surveillance Program reports, as well as in the licensees Annual Operating Reports submitted to the NRC.

On-site and off-site monitoring was accomplished using analyses of groundwater, vegetation, stream bottom sediments, and air. Environmental optically-stimulated luminescent (OSL) dosimeters were also used in accordance with the environmental surveillance program and applicable procedures. Gaseous effluent monitoring was accomplished using exhaust stack monitoring. On-site and off-site laboratories were used to perform the analyses of the various samples. The results of these analyses indicated that there were no releases of radioactivity and no doses in excess of any regulatory limits. These results were also acceptably reported in the reports mentioned above.

b. Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

5. 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:

• Annual Reports for License R-33, Docket 50-73, for the periods of January 1, 2012 through December 31, 2013

• Change Authorization 302, dated August 22, 2012

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• Change Authorization 303, dated August 23, 2012

• SOP 9.4 Change Authorization, reviewed December 21, 2012 b. Observations and Findings The licensee conducted maintenance activities at the reactor facility, which included the replacement of two Compensated Ion Chambers. All changes were reviewed and approved by the SRO/NTR Manager, Regulatory Compliance, Safety Committee, and the VNC Site Manager as required.

c. Conclusion Design changes were made in accordance with 10 CFR 50.59 requirements, TS, and licensee procedures.

6. 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 Safety Review Groups:

• Annual Reports for License R-33, Docket 50-73, for the periods of January 1, 2012 through December 31, 2013

• Vallecitos Technical Safety Committee (VTSC) Committee Meeting Minutes from 2012 to present

• Environmental Health and Safetys Regulatory Compliance Quarterly Audits from 2012 to present 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 inspectors also verified that Regulatory Compliance, the independent group auditing the facility operations, maintenance, and administration, was completing the periodic examination, as required by TS Section 6.2, within a 2-year cycle.

c. Conclusion The VTSC provided the oversight required by the TS.

7. Transportation a. Inspection Scope (IP 86740)

The inspectors reviewed the following to verify compliance with regulatory and procedural requirements for shipping or transferring licensed material:

-8-Selected records of radioactive material transfers for 2012 and to present GE VNC VSS, Standard No. 7.5, On-Site Transfers of Radioactive Material, Rev. 6, issued April 2010 GE - Hitachi Nuclear Energy Americas, LLC, Radioactive Material License issued by the California Department of Public Health, License No. 0017-01, Amendment No. 74, expiration date December 6, 2009 (in timely renewal with the State of California)

a. Observations and Findings Records showed that radioactive material produced in the reactor and destined to be shipped off site was typically transferred to the facilitys State of California Broad Scope License. This radioactive material was then shipped under that license; State of California Department of Public Health, Radioactive Material License No. 0017-01, Amendment No. 74, expiration date December 6, 2009.

Radioactive material to be used on site was also transferred to the broad scope license and distributed by EH&S. A list of authorized personnel was maintained by the licensee. The program for radioactive material transfer and transport was consistent with established procedural requirements. The transfer forms indicated the material had been surveyed and distributed to the appropriate authorized individuals as required. The material irradiated in the reactor was used/analyzed by contractor personnel or by licensee personnel in separate laboratories.

Some material was radiographed at the reactor facility after which it was held for decay. When the radiation/radioactivity levels were appropriate, this material was shipped back to the entities requesting the radiography services.

b. Conclusion Radioactive material produced in the reactor was typically transferred to the licensees state broad scope license and shipped under the auspices of that license or transferred to other authorized contractor or licensee users on site for use in laboratories in accordance with procedure.

8. Exit Interview The inspectors presented the inspection results to licensee management at the conclusion of the inspection on June 4, 2014, with a subsequent re-exit meeting on June 13, 2014. 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. It was discussed that any proprietary material provided to the inspector during the inspection that was removed from the facility would be disposed of appropriately.

PARTIAL LIST OF PERSONS CONTACTED Licensee J. Ayala Radiation Protection Supervisor and Interim Radiation Safety Officer D. Boorn Instrument Technician, Facilities and Maintenance Department GE VNC Site Manager E. Hagberg Radiation Monitoring Technician, Environmental Health and Safety Department T. McConnell Operations Specialist and Senior Reactor Operator D. Thomas NTR Manager D. Lutz VTSC, Chairman INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Transportation ITEMS OPENED, CLOSED, AND DISCUSSED OPENED None CLOSED None DISCUSSED None

-2-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 EH&S Environmental Health and Safety EPA Environmental Protection Agency GE General Electric Company IP Inspection Procedure No. Number NRC U.S. Nuclear Regulatory Commission NSP Nuclear Safety Procedure NTR Nuclear Test Reactor OSL Optically-Stimulated Luminescent Rev. Revision RWP Radiation Work Permit SOP Standard Operating Procedure TLD Thermoluminescent Dosimeter TS Technical Specifications VNC Vallecitos Nuclear Center VSS Vallecitos Safety Standard VTSC Vallecitos Technological Safety Council