ML18261A410
| ML18261A410 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos |
| Issue date: | 09/19/2018 |
| From: | Janine Katanic Division of Nuclear Materials Safety IV |
| To: | Feyrer M GE-Hitachi Nuclear Energy Americas |
| R. Browder | |
| References | |
| IR 2018001 | |
| Download: ML18261A410 (16) | |
See also: IR 05000018/2018001
Text
September 19, 2018
Mr. Matt Feyrer, Site Manager
Vallecitos Nuclear Center
GE Hitachi Nuclear Energy
6705 Vallecitos Road
Sunol, CA 94586-8524
SUBJECT: GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT
050-00018/2018-001; 050-00070/2018-001; 050-00183/2018-001 AND NOTICE
OF VIOLATION
Dear Mr. Feyrer:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on
July 31, 2018, through August 2, 2018, at your Vallecitos Nuclear Center in Sunol, California.
The inspection covered the following shutdown reactors under the subject licenses, Vallecitos
Boiling Water Reactor (VBWR), General Electric Test Reactor (GETR), and Empire State Atomic
Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR). A
preliminary exit meeting was conducted on August 2, 2018, with you and members of your staff,
and representatives from the Wilmington, North Carolina office. The NRC performed further
in-office evaluation of the violation identified during the inspection. Upon completion of the in-
office evaluation, the NRC inspectors presented the results of the inspection and the significance
of the violation identified during the inspection to you and members of your staff, during a final,
telephonic exit meeting on August 21, 2018. The inspection results are documented in the
enclosure to this letter.
During this inspection, the NRC inspectors examined activities conducted under your licenses
as they relate to public health and safety, the environment, and to confirm compliance with the
Commissions rules and regulations, as well as with the conditions of your license. Within these
areas, the inspection consisted of the examination of selected procedures and representative
records, tour of the reactors and supporting equipment, independent radiation surveys, and
interviews with personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with
the NRC Enforcement Policy. The current NRC Enforcement Policy is included on the
NRCs Web site at (https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding it are described in detail in the subject inspection report. The violation is being
cited in the Notice because it was identified by the NRC and corrective actions had not been
fully articulated on the docket at the time of the final exit meeting. Therefore, you are required
to respond to this letter and should follow the instructions specified in the enclosed Notice when
M. Feyrer 2
preparing your response. If you have additional information that you believe the NRC should
consider, you may provide it in your response to the Notice. The NRC review of your response
to the Notice will also determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements. If you contest the violation, you should provide a
response within 30 days of the date of this inspection report, with the basis for your denial, to
the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC
20555-0001, with copies to: (1) the Regional Administrator, Region IV, and (2) the Director,
Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosures, and your response will be made available electronically for
public inspection in the NRC Public Document Room or from the NRCs Agencywide
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs
Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response
should not include any personal privacy or proprietary, information so that it can be made
available to the Public without redaction.
Should you have any questions concerning this inspection, please contact Rachel Browder,
Senior Health Physicist, at 817-200-1452 or the undersigned at 817-200-1151.
Sincerely,
/RA/
Janine F. Katanic, PhD, CHP, Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Docket Nos.: 050-00018; 050-00070;
and 050-00183
License Nos.: DPR-1; TR-1; and DR-10
Enclosures:
1. Notice of Violation
2. Inspection Report 050-00018/2018-001;
050-00070/2018-001; 050-00183/2018-001
w/Attachment: Supplemental Information
cc:
S. Murray, GE Hitachi Nuclear Energy Americas LLC
G. Perez, Div. of Food, Drug, & Radiation Safety
Dr. R. Weisenmiller, California Energy Commission
Pleasanton Public Library
NOTICE OF VIOLATION
GE Hitachi Nuclear Energy Docket No. 050-00018
Vallecitos Boiling Water Reactor License No. DPR-1
Sunol, CA
During an NRC inspection conducted on July 31, 2018, through August 2, 2018, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the
violation is listed below:
NRC License No. DPR-1, Amendment 21, License Condition 3.a. states, in part, that the
licensee shall possess the facility in the condition described in the Final Report on
Deactivation of Vallecitos Boiling Water Reactor dated February 5, 1965.
Final Report on Deactivation of Vallecitos Boiling Water Reactor,Section V., states, in
part, that the condition, security and integrity of the retired facility will be checked during
the inspection, and the integrity of the reactor vessel will be verified. In addition,
Section II.A.3 specifies that a manometer located outside of containment will allow
monitoring of the water level of the pressure vessel and that periodic readings of the
manometer will be taken.
Licensee Procedure 6.2, Patrols and Inspections, Revision 7, implements the license
requirements as stated above, and establishes the periodicity of the inspections.
Specifically,Section IV.D., Annual Inspections and Radiation Surveys states, in part, that
an annual inspection, radiation and contamination surveys, and other surveillance activities,
including the interior of the containment building for Vallecitos Boiling Water Reactor
(VBWR) are required to be performed by the facility license, as described above. In
addition,Section IV.A., EVESR/VBWR Weekly Patrols states, in part, that a routine patrol
will be performed each week to check the VBWR reactor vessel water level.
Contrary to the above, the licensee failed to implement Procedure 6.2, Patrols and
Inspections, Revision 7, for the activities covering VBWR, as evidenced by the following
two examples:
1. On December 9, 2017, the licensee failed to follow Procedure 6.2 and inspect the
condition and integrity of the retired facility and verify the integrity of the reactor
vessel during the annual inspection, when water was identified in the basement of
VBWR. Specifically, during the annual inspection and radiological survey, there
was no assessment of structural integrity and radiological conditions of the facility
in order to assess and mitigate the associated environmental radiological risk from
the water in the basement. As a result of not taking any action, approximately
2,100 gallons of water remained in the basement of VBWR until June 21, 2018,
when the licensee pumped the water out of the basement.
2. Since May 2018, the licensee failed to take weekly readings of the manometer, to
measure the water level in the VBWR reactor vessel, as required. Specifically,
during calibration of the manometer in May 2018, the device was over pressurized
and broke and the manometer has not been replaced.
This is a Severity Level IV violation (Section 6.3.d.3).
Enclosure 1
Pursuant to the provisions of Title 10 Code of Federal Regulation (CFR) 2.201, GE Hitachi
Nuclear Energy is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-
0001, with a copy to the Regional Administrator, Region IV, 1600 E. Lamar Blvd., Arlington, TX
76011-4511, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation and should include for
each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity
level;
(2) the corrective steps that have been taken and the results achieved;
(3) the corrective steps that will be taken; and
(4) the date when full compliance will be achieved.
Your response may reference or include previously docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not received
within the time specified in this Notice, an order or a Demand for Information may be issued
requiring information as to why the license should not be modified, suspended, or revoked, or why
such other action as may be proper should not be taken. Where good cause is shown,
consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001, with a copy to the Regional
Administrator, Region IV.
Your response will be made available electronically for public inspection in the NRC Public
Document Room or in the NRCs Agencywide Documents Access and Management System
(ADAMS), accessible from the NRC Web site at: http://www.nrc.gov/reading-rm/adams.html.
To the extent possible, your response should not include any personal privacy, proprietary or
safeguards information so that it can be made available to the public without redaction.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 19th day of September 2018
2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos. 050-00018; 050-00070; and 050-00183
License Nos. DPR-1; TR-1; and DR-10
Report No. 050-00018/18-001; 050-00070/18-001; and 050-00183/18-001
Licensee: GE Hitachi Nuclear Energy
Facility: Vallecitos Boiling Water Reactor (VBWR)
GE Test Reactor (GETR)
ESADA Vallecitos Experimental Superheat Reactor (EVESR)
Location: 6705 Vallecitos Road
Sunol, California
Inspection Dates: July 31, 2018 - August 2, 2018
Inspectors: Rachel S. Browder, CHP, Senior Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Stephanie G. Anderson, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Chris D. Steely, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Accompanied By: Jack D. Parrott, Project Manager
Reactor Decommissioning Branch
Decommissioning, Uranium Recovery, and Waste Programs
Office of Nuclear Materials Safety and Safeguards
Approved By: Janine F. Katanic, PhD, CHP, Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Enclosure 2
EXECUTIVE SUMMARY
GE Hitachi Nuclear Energy
NRC Inspection Report 050-00018/18-001; 050-00070/18-001; and 050-00183/18-001
This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection
of licensed activities being conducted at the three permanently defueled reactors at the Vallecitos
Nuclear Center. In summary, the inspectors identified one Severity Level IV violation associated
with implementing Licensee Procedure 6.2, Patrols and Inspections, Revision 7, for the Vallecitos
Boiling Water Reactor (VBWR). Other than the one identified violation, the licensee was
conducting site activities in accordance with regulatory, license, and procedure requirements.
Decommissioning Performance Review at Permanently Shutdown Reactors
The licensee conducted its radiation control program in accordance with regulatory
requirements and license conditions, with one exception. The inspectors identified a violation
associated with the assessment of the structural integrity and radiological condition of VBWR
associated with the environmental radiological risk from the water in the basement and not
having the capability to measure the water level in the reactor vessel of VBWR. (Section 1.2)
2
Report Details
Summary of Plant Status
The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) continued to maintain the
three shutdown reactors, Vallecitos Boiling Water Reactor (VBWR), General Electric Test
Reactor (GETR), and Empire State Atomic Development Associates Incorporated Vallecitos
Experimental Superheat Reactor (EVESR) in a possession-only, safe storage (SAFSTOR)
condition, with no fuel remaining in the reactors or spent fuel pools. The condition of SAFSTOR
is a decommissioning alternative in which the licensee is authorized to maintain the facility in a
condition that allows the nuclear facility to be safely stored and subsequently decontaminated to
levels that permit release for unrestricted use within 60 years of permanent cessation of
operations. Licensees who choose the SAFSTOR option must meet all NRC financial and safety
regulations, both prior to and during the SAFSTOR period.
On April 24, 2015 (ADAMS Accession Number ML15114A437 and ML15114A438) the licensee
submitted a request for a partial site release of approximately 610 acres of non-impacted property
on the northern section of Vallecitos Nuclear Center (VNC) site, for unrestricted use pursuant to
Title 10 Code of Federal Regulation (CFR) 50.83(b). The NRC held a public meeting in
Pleasanton, CA on July 22, 2015, and published a notice of the receipt of the release request in
the Federal Register on July 20, 2015 (80 FR 42846). The NRC evaluated the request under the
provisions of 10 CFR 50.83, and approved the partial site release by letter dated May 3, 2016
(ML16007A348). The property continues to remain under the ownership of GEH.
On December 15, 2015, the licensee submitted a request for license continuance under
10 CFR 50.51(b) for reactor licenses DPR-1, DR-10, and TR-1 (ML15349A045). The licensee
also submitted a request on July 10, 2015 (ML15195A088) for an alternate decommissioning
schedule as described in 10 CFR 50.82(a)(3) and 50.82(b)(4)(i), using the exemption criteria
of 10 CFR 50.12.
On May 16, 2017, the NRC staff issued a request to GEH for additional information on the
structural integrity of the reactor buildings and how the integrity would be ensured during the
extended decommissioning period, in order to assess whether the request would result in undue
risk to public health and safety (ML17138A121). The licensee responded to this request by letter
dated July 31, 2017 (ML17212B019).
Based on this response and a site visit conducted by NRC on September 13, 2017, the NRC
determined that certain additional information must be provided by GEH to show how the
licensee is ensuring the confinement of residual radioactivity associated with the shutdown
reactors at the VNC and evaluating and monitoring the long term physical safety of the reactor
structures. The NRC requested more detailed information by letter dated January 18, 2018
(ML17312B359). On March 28, 2018 (ML18087A384) GEH provided a response indicating that
it would provide an interim status report for the hydrological and structural analyses in
approximately 6 months and anticipated completing the actions within approximately 12 months,
which would be March 2019.
3
1 Decommissioning Performance Review at Permanently Shutdown Reactors
(Inspection Procedures as listed below)
1.1 Inspection Scope
The inspection objective is to determine if site activities for the shutdown reactors were
being conducted safely and in accordance with regulatory requirements and license
commitments. Areas reviewed included the licensees organization, surveillance
requirements, and radiological surveys of the three shutdown reactors.
1.2 Observations and Findings
a. Organization, Management, and Cost Controls at Permanently Shutdown Reactors
(IP 36801)
The licenses for the three shutdown reactors require in part, that activities involving
access to the facility area and use of any area shall be conducted under the direction of
a designated facility manager with functional responsibility and commensurate authority
to maintain the facility in a safe and secure condition at all times. The NRC inspectors
reviewed the licensees organization and discussed the organizational structure with
members of the licensees organization The VNCs organization was structured under
two divisions, identified as Operations and Support. The VNC Site Manager had
operational and support experience as a result of past work experience in multiple areas
within the GE Hitachi system. The Manager reported to Services Operations in
Wilmington, North Carolina. The inspectors observed there was good communications
and support between the VNC facility and operations in Wilmington, North Carolina.
Based on discussions and observations, the NRC inspectors determined that the
individual fulfilling the licensed responsibility as the facility manager for the defueled
reactors, adequately met the license condition requirements.
The NRC inspectors reviewed the routine activities performed at the three defueled
reactors and reviewed the organization structure that supported those activities. Based
on the review and discussions with licensee representatives, there had not been any
significant changes to the organization or new personnel hired to perform the routine
radiological safety activities at the shutdown reactors. There had been a reduction in
staff across the site, due to retirements and attrition. The licensee recently hired a
contractor to perform instrumentation and control functions under facilities maintenance.
The inspectors observed that the staff have a great deal of historical knowledge of
processes that may not be completely captured in training documents or procedures.
The inspectors discussed with management that it would be beneficial to incorporate the
information as deemed appropriate for certain tasks, including the use and calibration of
the manometer. In addition, the historical knowledge could further be captured to
corroborate and support the historical site assessment, as part of any future
decommissioning activities.
The licensee is required under 10 CFR 50.48(f) to maintain a fire protection program to:
(1) reasonably prevent fires from occurring; (2) rapidly detect, control, and extinguish
those fires that do occur and that could result in a radiological hazard; and (3) ensure
that the risk of fire-induced radiological hazards to the public, environment, and plant
personnel are minimized. The inspectors observed fire hydrants with fire department
pumper connections and hose connection stations with hoses, in close proximity to the
4
three shutdown reactors. The licensee also has fire protection reservoir tank and piping
connections throughout the site. Since the licensee was not required to maintain fire
detection or suppression equipment, then the capabilities at the facility were determined
to be sufficient to meet the regulatory requirement. The licensee maintained trained and
knowledgeable staff in the area of fire protection.
b. Decommissioning Performance and Status Review at Permanently Shutdown Reactors
(IP 71801) and Class III Research and Test Reactors (IP 69002)
i. Vallecitos Boiling Water Reactor (Power Reactor)
Vallecitos Boiling Water Reactor (VBWR) is a possession-only reactor under License
No. DPR-1, Amendment 21. It was a 50 megawatt (MW) power reactor that achieved
full power operations in 1957, after receiving its Construction Permit No. CPPR-3 on
May 14, 1956. It was shut down on December 9, 1963, for an extended period of time
and subsequently was deactivated. All fuel has been removed from the facility.
The possession-only facility license DPR-1, License Condition 4, states in part, that
there should be an audible control device maintained on the doors to the containment
building. In addition, License Condition 5, authorizes GE Hitachi to dispose of
component parts or devices from the VBWR facility in accordance with the provisions of
10 CFR Part 20. The licensee removed extensive components from the facility between
October 2007 and November 2008. All reactor systems have been removed except for
the reactor vessel. The only water remaining in the facility was inside the reactor vessel.
The inspectors determined that the licensee was maintaining the audible control device
on the doors to the containment building. The licensee operated a portable dehumidifier
inside containment building of VBWR. The condensed water was ultimately transferred
to the onsite waste evaporator plant for processing.
The inspectors and Headquarters Project Manager entered the basement level to
observe the structure of VBWR. The inspectors observed some cracking in the
concrete and several places that indicated water mineral seepage down the walls of
the structure. Further evaluation of the structure integrity will be performed as part of
the Agencys evaluation to assess GEHs request for license continuance.
The inspectors noted that the licensee had not recorded the weekly water level of the
reactor vessel for VBWR on the EVESR/VBWR Weekly Patrols document as specified in
Licensee Procedure 6.2, Patrols and Inspections, Revision 7, since May 2018. The
licensee explained that the manometer had been over-pressurized and broke, and another
manometer had not been installed. The licensee implemented Procedure 6.2, Patrols and
Inspections to meet the requirement to take periodic readings of the manometer as
required by license DPR-1, Amendment 21, License Condition 3.a., which referenced the
February 5, 1965, report Final Report on Deactivation of Vallecitos Boiling Water Reactor.
The licensee explained that the reactor vessel was a closed system and that the
reactor vessel had not been opened since the fuel had been removed. Based on
historical recordings of the manometer, the licensee indicated that the water level in
the reactor vessel had remained at approximately 95 inches of water. The NRC
concluded that this was a low safety significance because of the steady value of the
reactor vessel water level over a long period of time, coupled with the reduction of
radionuclides due to decay since the facility was shutdown.
5
The February 5, 1965, report also requires, in part, that the condition, security and integrity
of the facility would be checked by the licensee during the periodic inspection and the
integrity of the reactor vessel would be verified. The inspections were performed annually
in accordance with Licensee Procedure 6.2, Patrols and Inspections, Revision 7. The
licensee performed the annual patrol and inspection of VBWR on December 9, 2017, and
documented on the survey form that there was no entry into the basement due to rain water
in basement. The licensee subsequently submitted the annual report for VBWR as
required by License Condition 2., on March 29, 2018, and the survey form was included as
part of the annual report (ML18088A736). The licensee had not initiated a condition report,
had not taken any further action to verify the integrity of the reactor vessel or assessment of
the structural integrity of the facility, and had not performed a sample analysis to determine
if there were any radiological constituents present in the water.
Once the NRC reviewed the report and held a telephonic conference call with the licensee
on April 17, 2018, the licensee subsequently analyzed a water sample from the basement
of VBWR containment for gross beta, gross alpha, and tritium. The results were included in
a supplement to the Annual Report No. 53 for Year 2017, for VBWR, dated June 20, 2018,
(ML18171A068). The results are summarized in Table 1, below. The licensee pumped
approximately 2,100 gallons of water from the basement to the mobile tank to the onsite
waste evaporator plant for processing, on June 21, 2018.
Table 1
Gross Beta Gross Alpha Tritium
Water Sample Results
(pCi/l) (pCi/l) (µCi/ml)
April 2018 346 87 < MDC
MDC 185 74 1.54E-05
pCi/l = (picocuries per liter)
MDC = minimum detectable concentration
The NRC determined these two examples were evidence of a failure to implement
Procedure 6.2, Patrols and Inspections, Revision 7, for the activities associated with
VBWR, which is a violation of license requirements. (VIO 0500018/2018001-01)
ii. ESADA Vallecitos Experimental Superheat Reactor (Power Reactor)
The ESADA Vallecitos Experimental Superheat Reactor (EVESR) is a possession-only
reactor under License No. DR-10, Amendment No. 7. The EVESR was a light water
moderated, steam cooled, superheat, experimental research reactor that used slightly
enriched uranium dioxide as fuel. It operated at a maximum of 17 MW thermal and was
initially licensed in 1963. It achieved full power operation in 1964, and was shut down on
February 1, 1967, and subsequently deactivated. All fuel and other special nuclear
material had been removed and shipped offsite. In addition, a significant amount of
equipment used to operate the reactor, such as nuclear instrumentation, piping, pumps,
and valves had been removed.
The inspectors toured the facility with Headquarters Project Manager and licensee
representatives. The inspectors confirmed there was an alarm device functioning on the
airlock door to the containment building that provided an alarm at the 300 feet elevation
area alarm panel and at the Central Alarm Station. Prior to the inspection, the licensee
explained that the sump located outside and adjacent to the containment structure had
6
alarmed at the Central Alarm Station, due to the pump not working. The licensee
corrected the problem with the sump pump and reset the alarm. The licensee utilized a
portable dehumidifier to remove condensation from inside the EVESR building. The
licensee had temporary lighting installed and it was operating sufficiently to ensure the
passageways and stairways were safely lit.
iii. General Electric Test Reactor (Research and Test Reactor)
The General Electric Test Reactor (GETR) is a possession-only reactor under License
No. TR-1, Amendment No. 17. The reactor was a 50 MW thermal experimental test,
development, and isotope production reactor that utilized highly enriched plate fuel and
was initially licensed to operate in 1959. The reactor was shut down in 1977 and
subsequently deactivated. All fuel and isotope production targets containing special
nuclear material have been removed from the facility and shipped offsite. The reactor,
systems and piping, and spent fuel pool have been drained of water. The licensee
explained that the containment polar crane was functional, and only required re-
certification for it to be considered operable.
The tank farm located outside the control room building had three underground tanks
and one above ground tank, with each one having a capacity of 25,000 gallons. The
licensee stated the underground tanks were monitored on a quarterly basis. As needed,
the water from the tanks was transferred by piping to the above ground tank and the
water was subsequently transported by a mobile tank to the onsite waste evaporator
plant for processing.
The licensees Environmental Monitoring Manual, Revision 2, specified that the
monitoring well (B-2) located outside of the GETR control room, would be sampled in
June and December each year, for gross beta, gross alpha, and tritium. The licensee
documented the results in the 2017 annual report for GETR, submitted to the NRC on
March 29, 2018 (ML18088A736). The sample results are provided in Table 2, below. In
addition to the 2017 sample results, the June 2016 sample result is provided for
reference, since the December 2016 sample had been lost in transit. In addition, the
licensee sampled the (B-2) well in March 2018, and the results are included in Table 2,
below.
Table 2
Month Gross Beta (pCi/l) Gross Alpha (pCi/l) Tritium (pCi/l)
June 2016 458.0 151.0 < MDC
June 2017 4.49 1.70 1656.0
December 2017 2.69 25.57 133.0
March 2018 0.00 8.86 949.0
MDC was not reported
The emergency preparedness program was not reviewed because the license does not
have a requirement to implement an emergency preparedness program. The license
stipulates that GETR is already in SAFSTOR mode and there are no accidents that
could significantly affect occupational or public health and safety. The licensee does
implement a common, site-wide emergency preparedness program that is routinely
inspected in conjunction with the other NRC licenses.
7
c. Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
(IP 37801) and Self-Assessment, Auditing, and Corrective Action at Permanently
Shutdown Reactors (IP 40801)
The licensee is not subject to the quality assurance criteria under 10 CFR Part 50,
Appendix B, and does not have a requirement to implement and maintain a quality
assurance program under any of the three shutdown reactor licenses; therefore
IP 37801 was not performed for the shutdown reactors.
The licensee implemented its corrective action program under Procedure CP-16-108,
Corrective Action Program, Revision 10.1. The procedure was utilized by all the
nuclear sites and facilities under GE Hitachi oversight, including VNC. However, the
licensee does not have a requirement under any of the three shutdown reactor licenses
to implement a corrective action program; therefore, the corrective action program itself,
was not reviewed during this inspection.
The inspectors reviewed corrective actions that were generated in accordance with the
licensees procedure. Specifically, the inspectors reviewed condition report (CR) 28719,
that was initiated to remove the water from the VBWR basement, which had been
completed by facilities maintenance. The last action was to formerly investigate the
source of the water intrusion into VBWR, with a completion date of November 30, 2018.
The licensee did not initiate a condition report on the over-pressurization of the
manometer. The inspectors discussed with the licensee, the benefits of documenting
the occurrence of the over-pressurization to address if there were any possible
deficiencies in the procedures, processes, or training, since the individual who had
previously performed the activity had recently retired.
d. Occupational Radiation Exposure (IP 83750)
The three shutdown reactor licenses stipulate that a radiation survey shall be conducted
annually, and that GETR would be served by the health physics program established in
other NRC licenses, specifically the research and test reactor (R-33) and the special
nuclear materials license (SNM-960).
Each of the shutdown reactors have license conditions that require annual reports be
performed and submitted to the NRC, as required. The licensee performed its
surveillances in accordance with Licensee Procedure 6.1, Access Control, Revision 8,
which provided a step-by-step instruction for conducting entries into the three shutdown
reactors. Based on the observed entries that were conducted and the documentation
generated to support the entries, the inspectors determined that the licensee had
adequately implemented its instruction for entering the shutdown reactors, which
ensured safe access to the facilities. The dose rates, radiological contamination levels,
and air sample results were consistent with historical data documented in previous
annual reports. The results indicated that all radiological measurements remained low
and the licensee did not identify any unexpected anomalies in the air quality of the
shutdown reactors. The inspectors used Ludlum Model 2401-S survey instrument
(NRC No. 079765, calibration due date October 21, 2018) to conduct independent
radiation surveys. The survey results were consistent with the licensees survey data for
the shutdown reactors.
8
The Licensee Procedure 6.2, Patrols and Inspections, Revision 7, provided the
instructions to ensure that the three shutdown reactors were inspected regularly and that
periodic radiation and contamination surveys were conducted to ensure compliance with
each of the three reactor licenses and 10 CFR Part 20 requirements. The licensee was
required to perform weekly patrols that consisted of items including, but not limited to
external door locks, ground water sump levels, postings, and power to the 300 feet
elevation area alarm panel. The licensee performed quarterly routines at GETR that
included radiation survey measurements and verification of radiation signs and barriers.
Finally, the licensee performed annual inspections and radiation survey measurements
inside each of the three shutdown reactors. The 2017 annual report for the three
shutdown reactors was submitted to the NRC on March 29, 2018, (ML18088A736) and
supplemented on June 20, 2018 for the VBWR license (ML18171A068). The inspectors
discussed with licensee management that the representation of Licensee Procedure 6.2,
should reflect the facility components and systems that should be inspected. For
example, the procedure described a containment sump alarm in VBWR, which was not
present.
The regulation under 10 CFR 20.1101(c) requires licensees to assess the radiation
protection program content and implementation. The licensee performed Self-
Assessment Number VNC-2018-02 on March 19-22, 2018, for the 2017 annual review of
the radiation protection program. The assessment was performed by the Radiation
Protection Program Leader, from the GE Hitachi, Wilmington, North Carolina office, so
there was independence in the performance of the assessment. The licensee did not
identify any deficiencies or make recommendations associated with the shutdown
reactor licenses program. The assessment identified a couple of deficiencies and made
several recommendations associated with other permits and licenses authorized at the
facility. These were documented in CR 28660. The inspectors determined that the
licensee performed a thorough assessment of its radiation protection program.
During 2017, the licensee monitored 199 employees and the radiation exposures
received at the facility were under other authorized licenses and permits. Since the
licensee was not performing any work activities at any of the three shutdown reactors,
there was no personnel exposure monitoring required for the shutdown reactors. The
licensee used lab coats, booties and gloves to minimize contamination inside the
shutdown reactors. The inspectors observed that the licensee effectively maintained
step-off pads for contamination control at the exit points from each of the three shutdown
reactors. In addition, the postings were adequate and in compliance with the
requirements under 10 CFR Part 20.
e. Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750) and
Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
The licensee submitted its 2017 Annual Effluent Monitoring and Environmental
Surveillance Program report on February 28, 2018 (ML18059A825 and ML18059A826)
with a supplemental report dated May 11, 2018 (ML18131A011) as required by various
site licenses and permits issued by the NRC and the State of California. The licensee
does not have a specific requirement to implement an effluent and environmental
monitoring program under any of the three shutdown reactor licenses. During 2017, the
licensee did not perform any activities at the shutdown reactors. As a result, there is no
data from the shutdown reactors required to be reported in the annual report.
9
The licensee stated that the last maintenance performed on the GETR stack was in
2011, and the stack was tested at that time. Although the ventilation system remained
operational, the licensee did not operate the system during 2017. The licensee
analyzed one groundwater well (B-2) that is located outside of GETR, next to the
control room. The results were published in the 2017 annual report for GETR and
summarized in Section (b.iii.) of this inspection report.
The licensee was not performing any work activities at the shutdown reactors, and
therefore, no wastes or transportation activities were conducted during this inspection
period. Therefore, IP 86750 was not performed.
f. Inspection of Remedial and Final Survey at Permanently Shutdown Reactors (IP 83801)
The licensee was not performing any work activities at the shutdown reactors, and
therefore, no remediation or final status surveys were performed during this inspection
period. Therefore, IP 83801 was not performed.
1.3 Conclusions
The licensee conducted its radiation control program in accordance with regulatory
requirements and license conditions, with one exception. The inspectors identified a
violation of license requirements associated with the assessment of the structural
integrity and radiological condition of VBWR associated with the environmental
radiological risk from the water in the basement and not having the capability to measure
the water level in the reactor vessel of VBWR.
2 Exit Meeting Summary
On August 21, 2018, the NRC inspectors presented the final inspection results to
Mr. M. Feyrer and other members of his staff, as well as with Mr. S. Murray from the
Wilmington, North Carolina office. The inspectors asked the licensee whether any
materials examined during the inspection should be considered proprietary. No
proprietary information was identified.
10
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
M. Feyrer, Site Manager
B. Lockwood, GM Operations
J. Smyly, Environmental, Health and Safety Manager
S. Murray, Manager, Facility Licensing
J. Ayala, Radiation Protection Supervisor
M. Schrag, Facilities Manager
H. Stuart, Radiation Monitor Technician
INSPECTION PROCEDURES
IP 36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors
IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
IP 40801 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors
IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors
IP 83750 Occupational Radiation Exposure
IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials
IP 69002 Class III Research and Test Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000018/2018001-01 VIO Failure to implement Procedure 6.2, Patrols and
Inspections, Revision 7, for activities associated with
VBWR.
Closed/Discussed
None
LIST OF ACRONYMS
CFR Code of Federal Regulations
CR Condition Report
EVESR Empire State Atomic Development Associates Incorporated Vallecitos
Experimental Superheat Reactor
GEH GE Hitachi Nuclear Energy Americas, LLC
GETR General Electric Test Reactor
MW Megawatt
NRC U.S. Nuclear Regulatory Commission
VBWR Vallecitos Boiling Water Reactor
VNC Vallecitos Nuclear Center
Attachment
SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword
By: RSB Yes No Non-Sensitive Publicly Available NRC-002
OFFICE DNMS/FCDB FCDB C:FCDB
NAME RSBrowder SGAnderson JFKatanic
SIGNATURE /RA/ /RA/ /RA/
DATE 9/18/18 9/19/18 9/19/18