M180214, GE-Hitachi Nuclear Energy - Unconditional Release of Route 84 Frontage Section of Vallecitos Nuclear Center (Vnc) Site
| ML18348A425 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos |
| Issue date: | 12/14/2018 |
| From: | Heckman D GE-Hitachi Nuclear Energy Americas |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M180214 | |
| Download: ML18348A425 (17) | |
Text
- HITACHI GE Hitachi Nuclear Energy David J. Heckman Yallecltas Ucenslns Lead Reaulatary Affairs 6705 Yalledtas Rd Sunol, CA 9451&
M180214 USA T 925 918 6116 December 14, 2018 Davld.hetkmanl@lse.com U.S. Nuclear Regulatory Commission Attn:DocumentControiDesk Washington, D. C. 20555-001 Subject Unconditional Release of Route 84 Frontage Section of Vallecitos Nuclear Center (VNC) Site
References:
Pursuant to 10 CFR 50.83(b), GE Hitachi Nuclear Energy Americas LLC (GEH) hereby requests NRC approval to release for unrestricted use a non-Impacted portion of the VNC site acreage.
This section of the VNC site Is not relevant to the licensing basis of the VBWR or EVESR facilities.
The enclosure to this letter provides results of evaluations and assessments performed In accordance with 10 CFR 50.83.
If there are any questions or additional information required, please contact me at the number above. .
Sincerely, David J. Heckman, Vallecitos Licensing Lead - Regulatory Affairs
Enclosure:
Unconditional Release of Route 84 Frontage ofVNC Site, December 2018 cc: NRC Region IV Administrator J. Parrott, NRC NMSS D. Hardesty, NRC NRR S. Anderson, NRC RIV Chief, Radiologic Health Branch California Department of Public Health PO Box 997414, MS 7610 Sacramento, CA 95899-7414 DJH 18-001
Enclosure M180214 Evaluation for Unconditional Release of Route 84 Frontage of VNC Site
Vallecitos Nuclear Center 6705 Vallecitos Road Sunol, CA 94586 December 2018 Unconditional Release of Route 84 Frontage of Vallecitos Nuclear Center Site Written By: David J. Heckman PMP; Vallecitos Licensing Lead Reviewed By: Scott Murray CHP; Facility Licensing
U.S. NRC M180214 12/14/18 Page 2 of 15 Executive Summary:
Vallecitos Nuclear Center (VNC), located at 6705 Vallecitos Road Sunol, California, includes only an estimated 135 acres, herein referred to as the site developed area, that has ever been used for principal licensed activities. GEH operates VNC as a research and development facility licensed under 10 CFR 50 and 70 as well as a State of California radioactive material license. Approximately seven acres of VNC property within an irregular construction easement along Vallecitos Road (State Route 84) is to be made available to Alameda County Transportation Commission (ACTC) to support road development and widening. This land has undergone an environmental assessment that includes analyses for radioactivity.
This assessment concludes that radiation levels within the easement do not exceed levels representative of background and that there are no radioactive materials detectable in the soil above levels common to the natural environment in the general area.
In 2015, 610 acres at the north end of the VNC property were surveyed and released for unrestricted use as communicated to the NRC in submittals recorded under Adams accession numbers ML15114A437 and ML15114A438. The 610-acre parcel has not been sold and remains part of the original VNC property. None of the seven acres that are the subject of this submittal are within that 610-acre parcel.
Reference is given to that submittal only as supplemental information that informs an overall conclusion as to the absence of radioactive contamination in undeveloped areas of the VNC property.
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U.S. NRC M180214 12114/18 Page 3 of 15 Overview:
The inceptive purpose of the GE-Hitachi Nuclear Energy Americas LLC (GEH) Vallecitos Nuclear Center (VNC) was to provide research and development and perform engineering studies of Boiling Water Reactors and their fuel. Over time many of the reactor related activities have ceased leaving only the R-33 Nuclear Test Reactor (NTR) still in operation. Three reactors at VNC: DPR-1 Vallecitos Boiling Water Reactor (VBWR), TR-1 GE Test Reactor (GETR), and DR-10 Empire State Atomic Development Agency Vallecitos Experimental Superheat Reactor (EVESR), are in SAFSTOR (SAFe STORage). The activities currently performed at VNC involve operation of the NTR and by-product material activities licensed under State of California license CA-0017-01. These include research and development activities and the manufacture of sealed sources.
In 2015, 610 acres (Fig. 1: Areas "C1" and "C2") at the north end of the VNC property were surveyed and released for unrestricted use as communicated to the NRC in submittals recorded under Adams accession numbers ML15114A437 and ML15114A438 (Reference 2). None of the seven acres that are the subject of this submittal are within that 61 D-acre parcel. Reference to the 2015 survey is provided only to inform an overall conclusion as to the absence of radioactive contamination in undeveloped areas of the VNC property. That 61 0-acre parcel has not been sold and the property boundary remains unchanged since the original property purchase in 1956. The 135-acre site developed area is situated in the southwest quadrant (Fig.1: Area "A") of the property between the 400 and 600-foot topographic contours. This area contains all principal facility structures and is fenced and posted "No Trespassing" with a security gate at the access point from Vallecitos Road (State Route 84).
Figure 1: Overhead view of VNC Site Layout GEH Class I Public Information
U.S. NRC M180214 12114/18 Page 4 of 15 VNC is within the Livermore Upland physiographic area and is largely undeveloped grasslands with hills ranging in elevation from approximately 400 to 1,200 feet above mean sea level. The property slopes to the southwest and drains through ditches to Vallecitos Creek which discharges to Arroyo de Ia Laguna near the north end of Sunol Valley - two or three miles southwest of the property.
The site is near the center of the Pleasanton quadrangle of Alameda County approximately 35 air miles east-southeast of San Francisco and 20 air miles north of San Jose (Fig. 2). The land surrounding the site is primarily dedicated to agriculture and cattle grazing. The few residences near VNC are mostly west of the property. The nearest sizeable towns are Pleasanton, located 4.1 miles to the north-northwest, and Livermore, located 6.2 miles to the northeast. A Union Pacific railroad line runs about two miles west of the site. There is light industrial activity within a 10-mile radius of the plant. San Jose (20 miles south),
Oakland (30 miles northwest), and San Francisco (35 miles northwest) are major industrial centers.
The VNC property is entirely on the north side of Vallecitos Road which is a two to four-lane paved highway currently being improved and widened in a California Department of Transportation project in cooperation with the Alameda County Transportation Commission (ACTC). Approximately seven acres of VNC property encroaches into an irregular construction easement that fronts Vallecitos Road and is to be made available to the ACTC to support this project.
FIGURE 2: Area Map (Not to Exact Scale)
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U.S. NRC M180214 12/14/18 Page 5 of 15 Methodology:
Because VBWR was licensed as a power reactor and EVESR has similar possession-only license conditions, a 10 CFR 50.83 release request will be followed. Other licenses have different requirements, but the 50.83 requirements are bounding and should sufficiently demonstrate the adequacy of the release. For this report, the requirements from 10 CFR 50.83 are presented in italics at the beginning of each section. Then a description, encompassing both VBWR and EVESR possession only reactor facilities at VNC, is provided on how that requirement is met. Mention is made to NTR where relevant to the requirement.
Section 1: (a)(1) Evaluate the effect of releasing the property to ensure that--
(i) The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D; Direct dose measurements on VNC property near Vallecitos Road have been consistent with background (Ref. 5). Dose rates will continue to reflect background at the new property line with no increase in exposure to the public. Soil within the easement does not contain radioactive material that exceeds background screening levels according to analysis performed for the ACTC by Baseline Environmental Consulting (Ref. 1).
(ii) There is no reduction in the effectiveness of emergency planning or physical security; The southern site boundary has no unique function in the VNC security or emergency plans. The improvements to Vallecitos road resulting from the forfeiture of the easement can be expected to enhance accessibility to VNC with a commensurate improvement in response times for VNC employees and local support organizations.
The provision of seven acres will not require changes in license bases as existing mentions identify the site in terms of approximate acreage.
Because no changes are necessary to the Emergency Plan, the Physical Security Plan, or to make editorial adjustments to those plans, further evaluation pursuant to 10 CFR 50.54(p) and 10 CFR 50.54(q) is not required.
(iii) Effluent releases remain within license conditions; The project will result in the southern site boundary being moved closer to the site developed area where all licensed activities take place but will have no effect on effluent releases. Adjustments may be necessary to at least one liquid effluent sample station and one environmental air monitoring station during construction (Fig. 2) and traditional vegetation sample points along Vallecitos Road will be relocated; however, these adjustments will have no impact on effluent releases or on monitoring results (Ref. 5).
(iv) The environmental monitoring program and offsite dose calculation manual are revised to account for the changes; VNC is not required to have an offsite dose calculation manual. The site monitoring plan meets the requirements set forth in California Regional Water Quality Control Board (CRWQCB) Water Discharge Permit No. R2-2008-0079 and 10 CFR 20, Appendix B. Environmental impact air monitoring as performed for the active test reactor (NTR) was confirmed to be sufficient as documented in an associated License Amendment Request for NTR in letter TAC 15-002, from Tom Caine to US NRC dated February 16, 2015 (Ref. 8). No revision to VNCs environmental monitoring program is necessary.
(v) The siting criteria of 10 CFR Part 100 continue to be met; Both VBWR and EVESR have permanently ceased operations and are maintained in a possession only SAFSTOR status. The site acreage is not explicitly used in any of the analyses supporting the licensing basis of either. The operating NTR is bounding relative to 10 CFR 100 for the VNC site. NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, clarifies that risk to public health and safety is greater from a design basis event (DBE) than from any event that can be mechanistically postulated. Since movement of this section of the property line has no relevance to a DBE, VNC continues to meet applicable criteria.
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U.S. NRC M180214 12114/18 Page 6 of 15 Figure 2: Potentially Impacted Effluent Sample Locations (vi) All other applicable statutory and regulatory requirements continue to be met. Yes.
Section 2: (a)(2) Perform a historical site assessment of the part of the facility or site to be released; VNC is located near the center of the Pleasanton quadrangle of Alameda County, California. The site is east of San Francisco Bay, approximately 35 air miles east-southeast of San Francisco and 20 air miles north of San Jose. The properties surrounding the site are primarily used for agriculture and cattle graising with some residences, which are mostly to the west of the property.
Approximately seven acres of VNC property encroaches into an irregular construction easement that fronts the north side of Vallecitos Road. This frontage is being afforded to the ACTC to support improvements and widening of the road. Because this land is far from the site developed area and is coincident with public land, no planned work with radioactive materials has ever taken place within this area.
Consistent with the MARSSIM approach (NUREG-1575, Section 2.5.5), this area is concluded to be non-impacted based on the following four sources of information:
A. Visual inspection B. Historical records C. Process knowledge D. Results of sentinel measurements GEH Class I Public Information
U.S. NRC M180214 12/14/18 Page 7 of 15 MARSSIM*type review:
A. Visuallnspection:
Figure 4: Southwest corner of property bordering Vallecitos and Little Valley Roads.
Retention basins are shown. Setback of property will disturb the heavy vegetation to right.
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U.S. NRC M180214 12/14/18 Page 8 of 15 Figure 5: VNC property frontage along Vallecitos Road.
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U.S. NRC M180214 12/14/18 Page 9 of 15 This land is mostly undeveloped grassland road frontage with a small area landscaped to provide an aesthetic entrance to VNC. There is no evidence of pre-existing industrial structures indicative of radiological work. A walkdown of the subject area indicated that two rigid sample stations (Fig. 2) may be impacted as the project progresses.
B. Historical Records:
Site records were reviewed and provide no evidence that radiative materials have never been used in the subject area along Vallecitos Road. Annual environmental reports along with environmental radiological surveys and sampling along the southern property line support a conclusion that no radioactive materials have ever been used in this area. A review of licensing documents reveals licensed activities have never been approved for the subject area but have been limited to the site developed area, which is roughly one-half mile distant from Vallecitos Road.
No documented survey or environmental sample result indicates the presence of non-naturally occurring radioactive material in the project area.
A Hazardous Materials Soil Investigation (Ref. 1) was recently conducted by Baseline Environmental Consulting for this area. This assessment included pertinent findings of the 2015 report supporting unrestricted release of the 610-acre plot on the north end of the VNC property (Ref. 2) and built upon Baseline Environmental Consultings Initial Site Assessment, prepared in 2016 for the ACTC (Ref. 3).
Details of this investigation are in Section D.
C. Process Knowledge A survey was taken of current and past site personnel. Subjects have all filled senior management positions at VNC and represent uninterrupted process knowledge from 1965 until present. There are no known events that occurred in the project area that involved work with radioactive materials.
Name Title Approximate Service Years at VNC Joe Tenorio Site Manager 1965 - 2001 & 2007- 2013 Matthew Feyrer Site Manager 1989 - 1995 & 2016 - Present Carlos Martinez Senior Operation Management 1994 - Present Michael Schrag Facilities Manager 2004 - Present D. Results of Sentinel Measurements (1) General Assumptions and Methods The most credible scenario whereby the south end of the property could have been contaminated by radioactive material used at VNC would result if such material was carried in fine particles in airborne releases from the reactors or facilities in the site developed area, distributed evenly across the property, and then consolidated over time by precipitation runoff.
As part of an environmental assessment, Baseline Environmental Consulting collected soil samples from 16 locations along Vallecitos Road (Fig. 6) at depths between 0 and 6 inches and analyzed them for gross alpha and gross beta activity (Ref. 1). These locations were selected because they are local low points where contamination might be expected to consolidate.
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U.S. NRC M1B0214 12/14/18 Page 10 of 15 Figure 6: Approximate locations for 16 gross alpha/beta samples.
Gamma spectroscopy analysis was then performed using U.S. Department of Energy methods on the sample yielding the highest gross alpha activity and two samples yielding the highest gross beta activity.
- To provide confirmation and increase statistical significance, the data resulting from the analysis of these soil samples was then combined with that of the 11 samples from the 2015 north property survey (Ref. 2); previously determined to be representative of background radiation levels.
The distributions of gross alpha and gross beta results from the combined 27 soil samples were first analyzed on quantile-quantile (Q-Q) plots (Figures 7 and B) to visually identify potential data outliers that could represent localized areas of elevated radiation or "hot spots" in the project area. Any identified hot spot samples were further analyzed by gamma spectroscopy to determine if non-naturally occurring isotopes were present. The one-tailed 95 percentile upper confidence limits (95%
UCLs) for the mean gross alpha and gross beta were then calculated using the United States Environmental Protection Agency's (USEPA's) ProUCL version 5.1 software and the results were compared to the Livermore National Laboratory (LLNL) recommended background screening levels (Ref. 6).
{2) Summary of Analysis Results Soils in the project area do not appear to be affected by radiological materials associated with operation of the GEH facility and would not be expected to pose a health risk to construction workers or the environment. Detailed analytical results are included in Table 1.
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U.S. NRC M180214 12/14/18 Page 11 of 15 Table 1: Analytical Results (pCi/g) for Soil Samples Taken 7/19/2018 Sample ID Gross Gross Cesium-137 (Figure 6) Alpha Beta S01 10.5 16.2 -
S02 14.8 12.5 <0.100 S03 10.3 8.60 -
S04 8.00 8.13 -
S05 8.95 13.3 -
S06 7.34 10.8 -
S07 14.3 13.7 -
S08 14.4 16.7 -
S09 8.06 33.2 <0.100 S10 11.9 37.9 0.105 S11 7.12 6.19 -
S12 6.38 9.33 -
S13 9.5 19.7 -
S14 14 12.3 -
S15 12.2 12.9 -
S16 13.3 15.3 -
95% UCL1 10.8 13.42 -
LLNL Background Screening Limit 11 21 -
NCRP Residential Screening Limit - - 5.4 NCRP Construction Worker Screening Limit - - 12.6 Table 1 Notes:
Samples analyzed for gross alpha & beta by EPA Methods 900.0/SW846 9310/SM 7110B Modified & gamma spectroscopy by U.S. Department of Energy Methods HASL 300, 4.5.2.3/Ga01R.
1 Includes samples from 2015 GEH Radiological Survey Report (Ref. 2) 2 Excludes two data outliers (Samples S09 & S10)
(3) Gross Alpha Results As per Figure 7, gross alpha data presents a normal distribution with no data outliers. This indicates that samples collected from the project area are generally consistent with the background gross alpha levels reported during the 2015 radiological survey. Gross alpha results from the 27 samples had a 95% UCL of about 10.8 pCi/g, which is below the LLNL recommended background screening level of 11 pCi/g.
A gamma spectroscopy was performed on the sample having the highest gross alpha activity and yielded no indication of elevated levels of non-naturally occurring radioisotopes such as cesium-137.
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U.S. NRC M1B0214 12114/18 Page 12 of 15 Figure 7: Gross alpha results.
Q-Q Plot for Gross Alpha Samples 12 8 ...
6
- 1.8 *12 -ll s 0.0 0,6 1.2 1.8 Theoretical QuantDes (standard Nonnal)
(4) Gross Beta Resuhs As per Figure B, gross beta data also appears to have a normal distribution but for two samples with elevated gross beta levels. One of these samples was collected near the entrance to the facility (sample 51 0) and the other from the extreme east end of the property (sample 509).
These potential data outliers were confirmed using the Rosner outlier test procedure in the ProUCL software. Because these two data outliers were statistically unique, they were evaluated separately from the other samples. The 95% UCl- for the gross beta levels of the remaining 25 samples was 13.4 pCi/g, which is below the LLNL recommended background screening level of 21 pCi/g.
Gamma spectroscopy was performed on the two soil samples with elevated gross beta levels.
Based on the gamma results, there were no elevated levels of non-naturally occurring isotopes at either location. Cesium-137 was detected slightly above the laboratory reporting limit of 0.1 00 pCi/g in the sample taken at the entrance to the facility. The indicated level (0.1 05 pCi/g) is well below the National Council of Radiation Protection (NCRP) and Measurements (Ref. 7) recommended residential and construction worker screening limits of 5.4 pCi/g and 12.6 pCi/g, respectively.
Because these sample locations were both in drainage swales, the elevated gross beta levels may be due to the accumulation of sediments affected by background radiation sources (naturally-occurring isotopes and atmospheric fallout).
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U.S. NRC M180214 12/14/18 Page 13 of 15 Figure 8: Gross beta results.
Q-Q Plot for Gross Beta Samples 3il 15 10 ..
5
-1.8 _, 2 .06 0.0 0.6 1.2 1.8 Theoretical QuantDes (standard Norm..)
(5) Sentinel Measurement Conclusions
- Gross alpha results were below the LLNL recommended background screening level of 11 pCVg.
- Gross beta results were below the LLNL recommended background screening level of 21 pCi/g.
- Gamma spectroscopy evaluation identified cesium-137 in only one sample. The 0.105 pCi/g reading is well below the NCRP recommended residential screening limit of 5.4 pCi/g and reflective of natural background variations in fallout deposition.
Conclusion of MARSSIM tvpe review None of the four reviews indicate that radioactive material was ever used in VNC property fronting Vallecitos Road or that the area was contaminated with radioactive material as a consequence of principal activities. The area is characterized as per NUREG-1575, Section 2.5.5, as non-impacted.
Section 3: (a){3) Perform surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402 for impacted areas. Not applicable. The subject area is a non-impacted area.
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U.S. NRC M180214 12/14/18 Page 14 of 15 Section 4: (b) For release of non-impacted areas, the licensee may submit a written request for NRC approval of the release if a license amendment is not otherwise required. The request submittal must include--
(1) The results of the evaluations performed in accordance with paragraphs (a)(1) and (a)(2) of this section; See Sections 1 and 2 responses.
(2) A description of the part of the facility or site to be released; See Section 2 response.
(3) The schedule for release of the property; The property will be released as soon as approval is received from the NRC. The property will then be expediently afforded to the ACTC.
(4) The results of the evaluations performed in accordance with § 50.59; and: Both VBWR and EVESR have permanently ceased operations and are being maintained in a possession only SAFSTOR status. The subject site acreage is not explicitly used in any of the analyses supporting the licensing basis of either VBWR or EVESR. Results of 10 CFR 50.59 analysis are provided below.
Would the installation, change, test, or experiment:
- 1. Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated; No, the change has no impact on frequency of occurrence of any previously evaluated accident.
- 2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated; No, the change does not increase the likelihood of a malfunction of an SSC.
- 3. Result in more than a minimal increase in the consequences of an accident previously evaluated; No, consequences of an accident as per current licensing at VNC is not affected.
- 4. Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated; No, changing the property line does not increase the consequences of a malfunction of an SSC.
- 5. Create a possibility for an accident of a different type than any previously evaluated; No, the change does not create the possibility of a new or different kind of accident than any previously evaluated.
- 6. Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated; No, the change does not increase the possibility of a malfunction.
- 7. Result in a limit for a fission product/contamination barrier being exceeded or altered; or: No, the change does not impact a fission product/contamination barrier.
- 8. Result in a departure from a method of evaluation used in establishing the design bases or in safety analyses. No, the change in site size does not result in a departure from a method of evaluation.
(5) A discussion that provides the reasons for concluding that the environmental impacts associated with the licensee's proposed release of the property will be bounded by appropriate previously issued environmental impact statements. The proposed property to be released is an area that has never been used for licensed activity. The land is undeveloped grassland road frontage with a small area landscaped to provide an aesthetic entrance to VNC.
The land is downhill from the site developed area but is monitored as part of VNCs ongoing groundwater monitoring effort. No deviation will result from this action that is not bounded by previously issued environmental impact statements.
Section 5: (c to f) are either not applicable or describes work to be performed by the NRC.
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U.S. NRC M180214 12/14/18 Page 15 of 15
References:
- 1. Baseline Environmental Consulting, Hazardous Materials Soil Investigation. November 2018. SR 84 Expressway Widening and SR 84/I-680 Interchange Improvements Project: GE-Hitachi Parcels 096-0350-001-07 and 096-0350-001-02.
- 2. Release of North Section of Vallecitos, California Site (with enclosures), April 2015; ML15114A437 and ML15114A438
- 3. Baseline Environmental Consulting (Baseline), 2016. Initial Site Assessment, SR 84 Expressway Widening and SR 84/I-680 Interchange Improvements Project, Alameda County. August 1.
- 4. Baseline, 2018. Hazardous Materials Survey Plan, SR84 Widening and SR84/I680 Interchange Improvements Project, GEHitachi Parcels: Assessor's Parcel Numbers 096035000107 and 096035000102. June 29.
- 5. Annual Report, 2017 Effluent Monitoring and Environmental Surveillance Programs, February 28, 2018 ML18059A825, ML18059A826
- 6. Livermore National Laboratory (LLNL), 2008. Background Values of Gross Alpha and Gross Beta in Soil for Lawrence Livermore National Laboratory Lawrence. March.
- 7. National Council of Radiation Protection and Measurements, 1999. Recommended Screening Limits for Contaminated Surface soil and Review of Factors Relevant to SiteSpecific Studies.
NCRP Report No. 129. January 29.
- 8. TAC 15-002; Technical Specification Change to Support Potential VNC Site Land Sale; Tom Caine to Document Control Desk, February 16, 2015. Docket No. 50-73 License No. R-33.
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