IR 05000073/2010201
| ML110240369 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 02/04/2011 |
| From: | Johnny Eads Research and Test Reactors Branch B |
| To: | Doreen Turner General Electric Co |
| Schoenebeck G, NRR/DPR, 415-6345 | |
| References | |
| IR-10-201 | |
| Download: ML110240369 (23) | |
Text
ary 4, 2011
SUBJECT:
GENERAL ELECTRIC VALLECITOS NUCLEAR CENTER - NRC ROUTINE, ANNOUNCED INSPECTION REPORT NO. 50-73/2011-201
Dear Mr. Turner:
On January 10-13, 2011, the U.S. Nuclear Regulatory Commission (NRC, the Commission)
conducted an inspection at the General Electric Vallecitos Nuclear Center (Inspection Report No. 50-73/2011-201). 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 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 Oversight Branch 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
ML110240369 NRC-002 OFFICE PROB:RI PRPB:LA PROB:BC NAME GSchoenebeck GLappert JEads DATE 1/20/11 1/25/2011 2/4/2011
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-73 License No: R-33 Report No: 50-73/2011-201 Licensee: General Electric Company Facility: Nuclear Test Reactor (NTR)
Location: Sunol, CA Dates: January 10-13, 2011 Inspectors: Gregory M. Schoenebeck Patrick Isaac Approved by: Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY General Electric Vallecitos Nuclear Center NRC Inspection Report No. 50-73/2011-201 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; operator requalification training; surveillance and limiting condition for operation (LCO); experiments; health physics; design changes; committees, audits and reviews; emergency planning; maintenance logs and records; fuel handling logs and records; and transportation. 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 condition for operation and surveillances required by Technical Specifications were being properly implemented.
Experiments
- There were several new authorized experiments since the last inspection. Experiment review and approval was done in accordance with Technical Specification requirements, licensee procedures, and 10 CFR 50.59 regulations.
-2-Health Physics
- The inspectors determined that the licensees health physics program and operations were in compliance with 10 CFR Part 20 regulations, licensee procedures, and Technical Specifications.
Design Changes
- Design changes were made in accordance with 10 CFR 50.59 requirements, Technical Specifications, and licensee procedures.
Committees, Audits, and Reviews
- The Vallecitos Technological Safety Council appears to generally provide 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 were maintained and 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 Nuclear Test Reactor.
Transportation
- Due to the nature of the Vallecitos Nuclear Center operations, there is typically no shipment of reactor licensed radioactive material. Since the last inspection, there was no transfer of radioactive material to or from the reactor license.
REPORT DETAILS Summary of Facility Status The General Electric Companys (the licensees) 100 kilowatt research reactor has been operated in support of neutron radiography, experiments, reactor operator training, and periodic equipment surveillances. During the performance based aspect of the inspection, the reactor was operated to support an extensive amount of radiography business for General Electrics respective clientele.
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
$ Standard Operating Procedure (SOP) 6.1 "Staffing Requirements" Revision 941, dated September 8, 2004
- SOP 9.1 Safety Responsibility and Authority Revision 945, dated September 8, 2004 b. Observations and Findings There were no changes to the organizational structure of the NTR since the last inspection (see NRC Inspection Report No. 50-73/2009-201). Current NTR licensed staff consisted of five 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. Conclusion The organization and staffing was consistent with TS requirements.
2. Operations Logs and Records a. Inspection Scope (IP 69001)
The inspectors 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 June 12, 2009 to present
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- Annual Report No. 50 for NTR, dated March 30, 2010
- Annual Report No. 49 for NTR, dated March 30, 2009
- Vallecitos Technological Safety Council (VTSC) meeting minutes, Third and Fourth Quarters 2009, dated January 14, 2010
- VTSC meeting minutes, First Quarter 2010, dated June 22, 2010
- VTSC meeting minutes, Second Quarter 2010, dated November 16, 2010
- VTSC meeting agenda, Third Quarter 2010, dated November 16, 2010
- NTR Monthly Surveillance Check Sheet, dated June 2009 to January 2011
- SOP 6.4 Daily Surveillance Check Sheet dated June 13, 2007
- NTR Daily Surveillance Check Sheet, dated June 2009 to January 2011
- NTR Control Room Data Sheet, dated June 2009 to January 2011
- NTR Memo M2010-007 re: Scram Report 10-01, dated October 15, 2010
- SOP 9.1 Safety Responsibility and Authority Revision 945, dated September 8, 2004 b. Observations and Findings The inspectors conducted observations of the reactor staff operating the reactor and reviewed the NTR Console Log, Control Room Data Sheet, and Operation Record forms. The inspectors noted that the licensed operators on duty were knowledgeable and competent. Observation of operational activities also confirmed that reactor operations were carried out in accordance with written procedures and TS requirements.
The inspectors verified that reactor operating characteristics, and other TS and procedure required entries, were logged in the operating log and checklists as required. A review of the logs and records indicated that TS operational limits had not been exceeded. Operations records confirmed that shift staffing met the minimum requirements for duty personnel.
c. Conclusion Operational activities were consistent with applicable TS and procedural requirements.
3. Procedures a. Inspection Scope (IP 69001)
The inspectors reviewed the following to ensure that the requirements of TS Section 6.4, Operating Procedures, were being met concerning written procedures:
- SOP 9.1 Safety Responsibility and Authority Revision 945, dated September 8, 2004
- Administrative Procedure 9.2 "Standard Operating Procedures" Revision 995, dated September 10, 2008
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- Administrative Procedure 9.4 Change Authorization Revision 561, dated February 7, 1986
- NTR Commercial Procedures Manual, dated September 22, 2008
- SOP 8.3 Abnormal Operation, Revision 889, dated October 7, 1996
- SOP 6.7 Startup Summary Revision 652, dated January 26, 1988 b. Observations and Findings Oversight and review of procedure implementation was provided by licensee management. NTR staff members conducted TS activities in accordance with applicable procedures. Records showed that procedures for potential malfunctions (e.g., radioactive releases and contaminations, and reactor equipment problems) were available as required.
The inspectors reviewed procedure changes that were initiated since the last inspection and determined that the changes were appropriately reviewed and approved by NTR management. The inspectors confirmed that when a procedural change was required, the change was documented using the Change Authorization (CA) process in accordance with SOP 9.4. The inspectors verified that when changes were required, special attention was placed on 10 CFR 50.59 considerations.
c. Conclusion Procedure administrative review, revision, adherence to, and implementation satisfied TS 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, 2010
- Senior Reactor Operator/Reactor Operator Requalification Operating Examination for 2010
- NTR Memo re: NTR 2010 Reactor Operator Requalification Program Administration, dated March 4, 2010
- NTR Memo re: Designation of NTR Requalification Program Administrator, dated March 16, 2009
- Requalification Training Records for 2009 - 2010 Requalification Cycle
- NTR Console Log Books, from June 12, 2009 to present
- Administrative Procedure 9.14 Reactor Operator Requalification Program Revision 855, dated November 15, 1994
-4-b. Observations and Findings Current NRC-licensed staff consisted of five SROs and one RO. One of the five 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 Examination by Facility Licensee. The inspectors verified that physical examinations of the operators were conducted biennially as required. The inspectors 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. Conclusion 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 inspectors reviewed the following to ensure that the surveillance requirements and limiting conditions for operation (LCOs) specified in TS Section 4.0 were met:
$ SOP 6.4 "Daily Surveillance Check Sheet" Revision 985, dated June 13, 2007
$ SOP 6.5 "Monthly Surveillance Check Sheet" Revision 644, dated November 16, 2006
- Completed NTR Daily Surveillance Check Sheet, dated June 2009 to January 2011
- Completed NTR Control Room Data Sheet, dated June 2009 to January 2011
$ Completed Preventative Maintenance forms, dated January 5, 2009 to present b. Observations and Findings The inspectors noted that daily, monthly, and annual checks, tests, and/or calibrations for TS-required surveillance items were completed as required. The LCO verifications were completed on schedule and in accordance with licensee
-5-procedures. All of the recorded results were within the TS and procedurally prescribed parameters. The records and logs were noted to be complete and were being maintained as required. The procedures for the surveillances provided clear and concise direction and control of reactor operational tests and surveillances.
c. Conclusion The LCO 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 inspectors reviewed selected aspects of:
- Annual Report No. 50 for NTR, 2008
- Annual Report No.49 for NTR, 2007
- NTR SOP #10.1 Experiment Type Approval (ETA)
- Change Authorizations, various for 2008 and 2009
- NTR SOP #10.6 Cable-Held Retractable Irradiation System, dated December 29, 2010
- NTR SOP #10.7 Neutrography of Nonradioactive Material, dated December 12, 2004
- VTSC Meeting Minutes for 2008 b. Observations and Findings The inspectors reviewed the process for the conduct of experiments at the facility.
When the licensee prepares to conduct a new experiment it goes through the CA process (VNC Standard 2.0) to independently review the proposed type of experiment (or substantive changes thereto). The first step of the process is to submit an Experiment Type Authorization (ETA) which screens the proposal and approves the concept for the new type of experiment at the NTR. The ETA package consists of a detailed description which fully describes the experiment type, experiment facilities, possible materials, and reactor configuration as applicable. Numerical limits and restrictions on the experiment type are also specified. Additionally, the ETA package addresses all potential hazards including reactor, radiological, and industrial safety concerns. The safety analyses address items such as: reactivity effects, reactor effects, radiological safety (including As Low As Reasonably Achievable (ALARA) considerations),
chemical reactions, and compliance to regulatory and procedural requirements.
All credible off-normal conditions, accidents, malfunctions and personnel errors
-6-are also to be considered. Each ETA is reviewed and approved by the NTR SRO, Specialist, Industrial Safety (if experiment involves industrial safety considerations), Manager of Regulatory Compliance, and NTR Site Manager before the experiment may be conducted.
For each ETA package, an Experiment Approval Form (EAF) is developed. The EAF is structured to contain sufficient information to ensure compliance of an individual experiment to the ETA. The EAF delineates whether or not the individual experiment is routine or non-routine. If the experiment falls within the specifications for an experiment that is repetitive in nature and involve materials and configurations that are well characterized and analyzed in accordance with an ETA (i.e., routine experiment), the SRO may sign the EAF, thereby approving the experiment. If the experiment falls out of this classification, either an addendum to the appropriate ETA may be written or a new ETA may be generated with new limits, restrictions, and conditions which supersedes the original ETA.
The final step in the experimental review process is the generation of a CA in the event a modification is made to an NTR system. The review of the CA includes the safety analysis which defines nuclear industrial hazards and plans for their control. Additionally, the review provides the bases for the determination that the proposed change is allowed by the applicable license and technical specifications and may be performed without obtaining a license amendment in accordance with 10 CFR 50.59(c)(1). The licensee had not implemented a new procedure requiring review and approval by the NTR manager since the last inspection.
In 2009, there were three new experiments requiring Facility Manager, Regulatory Compliance, and VTSC approval as requested. These included:
- CA 293 authorized the irradiation of iridium in the Horizontal Facility to map the reactivity effects of iridium
- CA 297 served as the ETA for isotope irradiation in the Horizontal Facility
- CA298 served as the ETA for isotope irradiation in the CHRIS Facility The inspectors found that the CAs were very thorough in detail and had significant forethought. As an example for the experiment involving the irradiation of the iridium, precautions included (but not limited to):
- Reactivity estimates and implications; in this instance the amount of reactivity is a negative contributor and the worst case scenario was identified as the inability to achieve criticality
- The requirement for finger dosimetry to be worn by personnel handling the experiment fixtures
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- Having a radiation monitor present acting as a safety monitor when removing the Iridium Reactivity Standard Fixture In most cases, the CA appeared to adequately assess the safety consequences however it was unclear if it explicitly addresses all the evaluation criteria of 10 CFR 50.59 (c)(2). The Regulatory Compliance Manager had noted that they are making modifications to their change and experiment review process and indicated that they would incorporate a better evaluation process which explicitly addresses said regulation. The inspector has opened an Inspector Follow-up Item (IFI) 50-73/2011-201-02 to track this update.
c. Conclusion There were several new authorized experiments since the last inspection.
Experiment review and approval was done in accordance with TS requirements, licensee procedures, and 10 CFR 50.59 regulations.
7. Health Physics a. Inspection Scope (IP 69001)
The inspectors reviewed the following to verify compliance with 10 CFR Part 20 requirements:
- Annual Report No. 51 for the Year 2009, dated March 2010
- Commitment to a Safety Conscious Work Environment, dated January 22, 2008
- New Employee Radiological Safety Orientation (NERSO), dated January 2008
- Videos for Initial Radiological Safety Orientation (IRSO) and Hazard Communication at VNC
- General Emergency Response Handbook (used for general orientation),
undated
- NTR Stack Noble Gas Release Calculation, dated January 30, 1998
- ALARA Committee Agenda, February 12, 2009
- VNC Nuclear Safety Survey Record, various 2010
- VNC ALARA Committee Meeting Minutes for 2010 and 2009
- Effluent Monitoring and Environmental Surveillance Programs
- Landauer Radiation Dosimetry Report records for NTR staff, 2010 and 2009 b. Observations and Findings Upon visiting the facility, the inspectors watched two orientation videos and took two exams for radiation safety and basic emergency preparedness which allowed unescorted VNC access to the NTR. Both the videos and exams adequately covered the hazards and measures necessary for basic radiation protection at GE VNC.
-8-The inspectors reviewed radiation and contamination survey records for the 105 Building and the NTR Reactor Cell when the reactor was shut down. Daily smear surveys indicated readings were less than the minimum detectable activity for the survey equipment used in the periphery areas around the reactor (e.g.,
North Room, South Cell, Reactor Cell, NTR Lunch Room, etc.). The surveys were generally taken in the morning and would include a survey of the South Cell and North Room after a neutron radiography run. Depending on power history and time after shutdown, the radiation surveys in the Reactor Cell show two areas of high radiation, 3.1 rem/hr (above the reactor core barrel) and 1.7 rem/hr (on contact with the demineralizer), and are the most contributing sources of dose accumulation during the scheduled work outage which takes place early 1st quarter of the production schedule. Typical radiation levels at power in the control room are typically 1 mrem/hr and can be as high as 3 mrem/hr when the shutter is in the open position.
The inspectors observed a radiation survey taken on contact with a film slide that was immediately removed from the South Cell Post neutron radiography after a 2 minute irradiation; the level of radiation on contact was 30 mrem/hr with contributions consisting mainly from a beta source.
The control room operators remain as the individuals who receive the highest amount of dose as the reactor control panel is in close proximity to the high radiation area established in the South Beam Cell and the Reactor Cell.
Additionally, they are in close proximity to the neutron radiography slides that are moved along a metal track into and out of the South Beam Cell by qualified radiographers In 2009, the highest annual dose to the full time NTR Operations personnel was 0.644 rem and the lowest was 0.507 Rem. The average exposure to the personnel was 0.550 rem per person and the collective radiation exposure for the NTR personnel in 2009 was 2.552 Person-Rem. In 2008, the highest annual dose to the full time NTR Operations personnel was 0.786 rem and the lowest was 0.457 Rem. The average exposure to personnel was 0.512 rem per person and the collective radiation exposure for NTR personnel in 2008 was 2.559 Person-Rem.
To implement the ALARA concept, the ALARA committee continues to not only strive for setting collective dose goals (based on projected workload), but also implements a philosophy for reducing dose at the VNC, including the NTR.
Since the ALARA Committee is relatively new, they are still working on fine tuning the collective goals to meet the projected accumulated dose based on NTR Management input for their workload. As mentioned above, the collective radiation exposure for NTR personnel in 2009 was 2.559, and it exceeded the goal of 1.850 Person-Rem. When the inspector discussed this with the RSO, he had indicated that the goal was exceeded by the outage maintenance and increased experimental testing at the NTR which was unforeseen. The RSO discussed that when VNC groups do not meet the target goal they try to determine the cause for the higher than anticipated aggregate dose and correct if
-9-possible. In 2010, the target goal was 2.888 Person-Rem and based on the 3rd Quarter dose results (2.102 Person-Rem), the RSO determined that they should be on track to meet the established goal. With the increase in production and neutron radiography, the RSO indicated that the NTR group may be tracked on a more frequent (i.e., monthly) basis to determine if they are in congruence with the ALARA goal. The RSO and NTR Site Manager are still trying to determine ways to reduce the amount of dose received to the operators, but have not found a viable infrastructure solution (e.g., shielding wall around the operator, etc.). The licensee intends to increase reactor operations staff to allow the minimization of exposure time in the radiation fields. Another area which the licensee is considering for ALARA measures is to reduce the amount of reactor cell dose to NTR staff members during the outages.
In 2008 and 2009, environmental records showed that there was no alpha, beta or gamma activity attributable to activities at the NTR facility which was found on or in vegetation in the vicinity of the site; there was no release of radioactivity in water or to groundwater greater than the limits specified in 10 CFR Part 20, Appendix B; and the results of samples collected from off-site locations indicate normal background for the regional area.
The facility did not discharge radiological effluent waste to the sewer system in 2009.
c. Conclusion The inspectors determined that the licensee health physics program and operations were in compliance with 10 CFR 20 regulations, licensee procedures, and TS.
8. Design Changes a. Inspection Scope (IP 69001)
The inspectors reviewed the following to ensure that design changes were made, reviewed, and approved per the licensees administrative procedures and the TS, an in accordance with 10 CFR 50.59:
- SOP 9.1 Safety Responsibility and Authority Revision 945, dated September 8, 2004
- Administrative Procedure 9.3 Engineering Releases Rev. 992, September 10, 2008
- Administrative Procedure 9.4 Change Authorization Rev. 561, February 7, 2006
- Annual Report No. 50 for NTR, dated March 30, 2010
- Annual Report No. 49 for NTR, dated March 30, 2009
- NTR Preventive Maintenance Index and Completion Records, Year 2010
- NTR Preventive Maintenance Index and Completion Records, Year 2009
- Completed PM forms, dated January 5, 2009 to present
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- CA 299, South Cell Door Shutter Interlock Switch Re-location, dated May 28, 2010
- CA 270, Lot-N & Temperature Recorder Replacement/Spares, dated June 2, 2005 b. Observations and Findings The inspectors reviewed applicable records and interviewed licensee personnel with regards to the design change process at the NTR. The inspectors verified that the CAs included a 10 CFR 50.59 safety analysis. The inspectors also verified that the CAs were reviewed and approved by the NTR management and the VTSC, with emphasis on safety of the reactor facility and reactor staff, as per the licensee procedures.
c. Conclusion Design changes were made in accordance with licensee procedures, TS, and 10 CFR 50.59 requirements.
9. Committees, Audits, and Reviews a. Inspection Scope (IP 69001)
The inspectors reviewed the following to ensure that the independent reviews stipulated in TS Section 6.2 were being completed:
- Annual Report No. 50 for NTR, dated March 30, 2010
- Annual Report No. 49 for NTR, dated March 30, 2009
- Charter of Vallecitos Technological Safety Council (VTSC), dated December 2008
- VTSC meeting minutes, Second Quarter 2009, dated September 25, 2009
- VTSC meeting minutes, Third and Fourth Quarters 2009, dated January 14, 2010
- VTSC meeting minutes, First Quarter 2010, dated June 22, 2010
- VTSC meeting minutes, Second Quarter 2010, dated November 16, 2010
- VTSC meeting agenda, Third Quarter 2010, dated November 16, 2010 b. Observations and Findings A charter was established for the VTSC and the inspectors verified that the council was following all aspects of the charter. The VTSC membership satisfied the council's procedural rules. The VTSC had quarterly meetings and a quorum was always present as required. Review of the minutes indicated the VTSC provided guidance, direction and oversight. The minutes provided an acceptable record of VTSC review functions and of VTSC safety oversight of reactor operations.
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TS Section 6.2.4 requires performance of a periodic independent audit examination and verification of facility operations. The last documented audit was on October 20, 2008. The licensee did not appear to have a process to ensure that the required audit was performed consistently on a periodic basis.
The individual who last performed the audit has been transferred and no new person was assigned the task. The licensee was informed that failure to conduct the audit as required by the TSs was identified as an Unresolved Item (URI)
pending corrective actions and implementation of controls to prevent recurrence.
This issue will be reviewed during a future inspection (URI 50-73/2011-201-01).
The licensee has agreed to initiate a tracking program and perform the audit as part of their corrective actions.
c. Conclusion The VTSC appears to generally provide 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 inspectors reviewed selected aspects of:
- VNC Site Emergency Procedure No. A-5 Rev. 5, dated December 23, 2009
- VNC Reactor Facilities Radiological Emergency Plan, October 1981 (Revised November 2007)
- Vallecitos Nuclear Center Respiratory Protection Qualification, October 14, 2008
- Respiratory Protection and Fit Test, Annual Test, 2010
- Building Emergency Team Training, 2010
- Memorandum of Understanding (MOU) between Alameda County Sheriffs Office and GE VNC, September 23, 2009
- VNC Emergency Drill Audit Checklist, various for 2010 and 2009
- VNC Emergency Drill Critique, various for 2010 and 2009
- Nuclear Energy/Vallecitos EHS Audit Tracking System, various for October 29, 2009 b. Observations and Findings 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 VNC via the licensees intranet.
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Training for facility operators, staff, and members of the VNC having emergency response duties includes completing an initial training program and the performance of annual review and an exam. The inspectors noted through record reviews that the training and examination was completed satisfactorily. .
Through drill scenario and record reviews, the inspectors 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. Conclusion 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 inspectors reviewed selected aspects of:
- NTR Preventive Maintenance Index and Completion Records, Year 2010
- NTR Preventive Maintenance Index and Completion Records, Year 2009
- Completed PM forms, dated January 5, 2009 to present
- CA 299, South Cell Door Shutter Interlock Switch Re-location, dated May 28, 2010
- CA 270, Lot-N & Temperature Recorder Replacement/Spares, dated June 2, 2005 b. Observations and Findings The inspectors reviewed the maintenance records related to 2009 and 2010 scheduled and unscheduled preventive and corrective maintenance activities.
Routine/preventive maintenance was controlled and documented in the NTR Preventive Maintenance Log. This review indicated that all maintenance activities were consistent with the requirements in 10 CFR 50.59 and documented in the maintenance and/or operations log.
After all maintenance items were completed, system operational checks were performed to ensure the affected systems were operable before returning them to service c. Conclusion
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Maintenance logs, records, and performance satisfied TS and procedure requirements.
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. Conclusion 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 NTR, dated March 30, 2009
- Radwaste Transfer Record R-36, dated January 24, 2008
- VNC Radwaste Certification Form R-96, dated January 24, 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. Most material transferred on the site is in the form of 55-gallon drums (with lead liner) containing solid low-level waste and NTR resin cartridges. When these types of material are transferred onsite from the NTR, the facility staff adheres to SOP #9.7 Radwaste Handling. A series of three forms are typically filled out for the documentation of the radioactive waste transfers to Building 102-Engineering and Materials Services (EMS) and/or to the Hillside Storage Facility (HSF) (Radwaste Transfer Record Form R-36), Waste
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container certification (Form R-96), and radwaste inventory for all waste removed from the NTR facility.
Occasionally, radiography operations may involve the shipment of special nuclear material (SNM) to the North Building where, by procedure, it can be temporarily transferred from one VNC Criticality Limit Area to the NTR 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 the past, shipping transfer of SNM has occurred when it was determined that it needed to be stored onsite for a period greater than the aforementioned time requirement. Typically, these are radiography operations of GE Hitachi Boiling Water Reactor fuel elements to determine defects. Since the last inspection there was no fuel element radiography which involved the transfer of SNM to and from the R-33 license.
c. Conclusion Due to the nature of the VNC operations, there is typically no shipment of reactor licensed radioactive material. Since the last inspection, there was no transfer of radioactive material to or from the reactor license.
14. Exit Interview The inspectors presented the inspection results to licensee management at the conclusion of the inspection on January 13, 2011. The inspectors 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 inspectors during the inspection.
PARTIAL LIST OF PERSONS CONTACTED Licensee VNC Manager D. Thomas NTR Manager D. Krause EHS and Regulatory Compliance Manager D. Hall Radiation Monitoring Specialist INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Transportation ITEMS OPENED, CLOSED, AND DISCUSSED OPENED 50-73/2011-201-01 URI Failure to perform a periodic independent audit examination and verification of facility operations.
50-73/2011-201-02 IFI Review the evaluation criteria employed by the licenses of design change and experiments for consistency with 10 CFR 50.59 criteria CLOSED None 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 CA Change Authorization EA Experimental Authorization ECP Estimated Critical Position ETA Experiment Type Approval GE General Electric Company IFI Inspector Follow-up Item IP Inspection Procedure LCO Limiting Condition for Operation MOU Memorandum of Understanding NRC U. S. Nuclear Regulatory Commission NTR Nuclear Test Reactor Rev. Revision
-2-RO Reactor Operator RC Regulatory Compliance RWP Radiation Work Permit SNM Special Nuclear Material SOP Standard Operating Procedure SRO Senior Reactor Operator TS Technical Specifications URI Unresolved Item VNC Vallecitos Nuclear Center VTSC Vallecitos Technological Safety Council