ML20043H851
| ML20043H851 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 06/15/1990 |
| From: | Louis Carson, Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20043H846 | List: |
| References | |
| 70-0754-90-01, 70-754-90-1, IEIN-90-009, IEIN-90-9, NUDOCS 9006260517 | |
| Download: ML20043H851 (10) | |
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U. 5. NUCLEAR REGULATORY C0mlSS10N REGION V Report No. 70-754/50-01 License No. SNM 960 Priority 0 Categoiy Pu, ULR&D Safeguards Group V Licensee: General Electric Company Vallecitos Nuclear Center P. O. Box 460 Pleasanton, California 94566 Facility Name:
Vallecitos Nuclear Center Inspection at:
Pleasanton, California InspectionConducted: May 21-24, 1990 Inspectors:
O/dC 48Mfc C. A. Hooker, fuel facti 1tles Inspector Date Signed G,.C) L\\h 1
_ 6hde L. C. Cgn H. Ragation Specialist Date STg~n~e8 Approved by: C.hdia _
_(3hdeo.
G. P. 7 as, Chief Date 51gned Emerger)
Pre)aredness and Radiolo cal )rotection Branch Summary:
a.
Areas inspected:
This was a routine unannounced inspection of manacement and or0anization, radiation protection,iew, maintenance /a r,veillancecritica trainiiig/ retraining, operations rev 4
testing, and follow up on IE Information Notices.
The inspection also included tours of the licensee's facilities.
Inspection procedures 30703, 88005, 83822, 88015, 88010, 88020, 88025 and 92701 were addressed, b.
Results:
In the areas inspected the licensee's programs appeared adequate to the accomplishment of [ heir safety objectives.
One apparent violation was identified for failure to calibrate dose rate monitoring instruments on an annual basis, as detailed in Section J
3.a(1).
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,c-I' DETAILS 1.
Persons Contacted 1
Licensee; R. W. Darmittel, Mana
- J. H. Cherb, Manager,ger, lear Safet-Irradiation Processing Nuc (NS)
- G. E. Cunningham, Senior Licensing ngineer
- J. 1. Tenorio,ialist Safeguards and SecurityManager,RemoteHandingOper J. Nixon, Spec B. M. Murray, Radiological Engineer and Criticality Safety Specialist R. F. Begley, Supervisor, RHO E. J. Strain, Compliance Engineer
- W. Springsteen, Specialist
- Denotes those attending the. exit interview on'May 24, 1990.
In addition to the individuals noted above the inspectors met and held,
' discussions with other members.of the licen,see's staff.
2.
Management and Organization (88005)
This area was reviewed to determine the licensee's compliance with the requirements of the License Conditions, and licensee procedures.
a.
Organizational Structure The licensee continues to maintain-the independence of the criticality and radiation safety components from the manufacturing of nuclear products.or the processing of nuclear matericis.
There were no changes to Management and Organization structure as 4
illustrated in Appendix A However there were other onsite or,:Section 4.7 of-the License.
retirement of the Manager,ganizational changes, due to the expec,ted Reactor Operation and Su) port Services i
Department.
The manager h;d been responsible for slop operations, instrument and electrical (I&E) maintenance and facilities maintenance.
The Supervisor FacilitiesMaIntenance was assigned theresponsibilityfortheIEE!maintenanceandfaci1Ities maintenance and reported directly to the Manager Irradiation; ho Processing.
The Manager,; RHO, assumed the responsibility for s operations, e
-a b.
Procedure Controls 5
k The inspectors reviewed th'e licensee's prograr to assure that' procedures were current and periodical.ly reviewed. The NNC Safety Standards were reviewed on an annual basis by: the original. author or a designee.- The inspectors determined that changes to procedures-and periodic reviews were conducted in accordance with the, requirementsdelineatedinAppendixAoftheLicense.
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Internal Reviews and Audits i
Audit report "Sumary of 1989 Activities - VNC Nuclear Safety" was reviewed.
This report provided an overview of the VNC Nuclear Safetyactivitieswhichincludesqualityassurance(QA)ivities.,
audits internal audits, external audits and the associated act Tho gA audits center on activities in three areas product, services and
,rradiation processing support.
InternalaudItsconsistedof licensee annual reviews and inspections in specific areas in order to verify ccmpliance with the VNC Safety Standards (VSS).
Internal audit " Area Classification" was also reviewed.
This audit assessed whether the licensee effectively classifies radiation areas and properly posts labels and markings consistent with 10 CFR 20.
Inconsistencies and deficiencies identified during the audit were immediately corrected.
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Based on review of licent,ee audits and reviews and discussions with-cognizant licensee representatives, the inspectors determined that i
there activities were performed in accordance with the requirements delineated in Appendix A of the license.
d.
Safety Comittee 4
The detailed annual sumary of VNC activities discussed in the above aragraph is reviewed by the Vallecito Technological Safety Council VTSC).
The VTSC verifies.that results of the sumary satisfies the NM-960 license requirements for annual review of site safety and compliance performance.
The inspectors examined VTSC meeting minutesfromtheThirdQuarterof1989andtheFirstQuarterof 1990. A letter was provided to the inspector indicating that activities in the Fourth Quarter of 1989 did not necessitate a VTSC meeting.
The inspectors noted that the VTSC appeared to conduct appropriate investigations and follow-up of corrective actions.
l The licensee's performance in this area appeared adeguate to the l
accomplishment of their safety objectives. No violations or deviation were identified.
3.
RadiationProtection(83822)
The inspectors examined the licensee's program for compliance with the requirements of 10 CFR Parts 19 and 20, License Conditions, licensee l
l procedures and recomendations outlined in various industry standstds.
a.
Instruments and Equipment l
. License Condition No. 7 of the License authorizes, in part, the use of licensed materials in accordance with statements,ditions for therepresen and conditions contained in Appendix A " License Con Vallecito Nuclear Center," of the licen,see's submittal dated April 20, 1984.
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3 Section 8.2 " Equipment and facility Design Criteria and Guidelines,"
of Appendix A states that "Desian Criteria and guidelines for specific facilities are set forth in Table 1 of this Appendix."
Section 8.7 " Instrument Calibration " of Appendix A states that "Monitoringinstrumentsshallbecalibrateduponinitial acquisition,aftermajormaintenance,andatleastannually."
lable 1 of Appendix A under " Alarms, Interlocks and Safety features," lists the use of continuous dose rate meters in the vicinity of % cells to provide in immediate alarm in case of high radiatiori stoi 'of the cells.
During a "our. Building 102 the inspectors observed that the stationars r lation dose rate instrument in the vicinity of the hot cells, in'a > sted from their calibration tags, that calibrations were performed in excess of one year ago.
The inspectors observed that five stationary dose rate instruments were located throughout the facility.
Durin representatives,g discussions with cognizant licensee the inspectors were informed that there was no' s)ecified routine calibration frequency for these instruments, and t1at calibrations were only performed upon initial installation and when they appeared not to be operating properl.
Based on review of licensee records the inspectors observed that the dose rate instrument (EberlineRM-13S/N397withanRD-7Adetector) located in the vicinity of Hot Cell No. I was last calibration on January 28,1986;.thedoserateinstrument(EberlineRM-16S/N313withan RD 17A detector) located in the vicinity of Hot Cell No. 3 was,
last calibration on July 30 1988 (EberlineRM-16S/N309withanRb'andthedoserateinstrument 17Adetector)locatedinthe vicinit(ion,nocalibrationdatecouldbeidentifiedforthEHot-of Hot Cell No. 5 was last calibration on March 10 1988.
In addi Cell Access Corridor dose rate instrument (Victoreen Remote area monitoring unit S/N 14B).
The inspectors were also informed that there was no program to perform field source checks of these-instruments to determine system operability.
The inspectors subsequently ttlephoned the instrument vendor who recommended that this model of instrument be calibrated annually in accordance with ANSI N323 " Radiation Protection Instrumentation Test and Calibration."
failure to perform annual calibratir,s of the Hot Cell area continuous dose rate instruments was itantified as an 6pparent violation of License Condition No. 7 (7b 754/90 01-01),
The licensee representative disagreed with the inspectors' I
conclusion that this was a. violation of their license conditions based on their position that these instruments are used for indication only.
During tours of the RHO facility, the inspectors also observed that two of the hot cell dose rate instruments were set to alarm at 10
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millirem per hour (mrem /h) and the underwater storage pool area dose rate instrument was set to alarm at 100 arem/h instead of the 5.0 mrem /h and 20 mrem /h, respectively listed in Appendix A, Table 1 of the license.
It was disclosed to the ins)ectors that certain i
routine operations frequently increased t1e ambient b J. ground radiation levels and the alarm set points of these 'er,truments were adjustedaccordin,glybytheoperatorsandtoreadjustedafter completion of the task.
It a)peared to the inspectors that the i
alarm setpoints for some of tie area dose rate meters had not been e
readjustedinatimelymanner.
Thelicenseedidreadjustthe setpoints during the tour.
The inspectors noted that there was no formal tracking mechanism for alarm setpoint changes and assurance that the alarm setpoints had been returned to their original setting. This matter was discussed during the inspection and at the exit interview.
The inspectors observations were acknowledged by i
the licensee.
The licensees evaluation of this matter will be reviewed during a subsequent inspection and is considered an open item (70-754/90-01-02).
b.
External Exposure Control The inspectors reviewed selected personnel external exposure records.
The licensee's external exposure monitoring program consisted of monthly and quarterly film badges processed by a i
contract laboratory certified b Accreditation Program (NVLAP). y the National Voluntarf Laboratory Self reading pocket ion chaC *s were utilized for exposure estimations between film badge 3
processing.
Occupational external radiation exposure history records of licensee personnel and contractor film badge results appeared to be consistent.
Personnel exposures were primarily from operations involving the use byproduct material.
The inspectors verified that forms NRC-4 and NRC-5, or equivalent, and administrative exposure extension forms were processed and maintained in accordance with NRC requirements and licensee procedures.
Tasks involving non-routine operations required an 1
independent radiation safety. evaluation, and mock-up training to minimize the associated exposure risk and were reviewed by members l
l of the nuclear safety group.
Letters documenting exposures pursuant to 10 CFR 19.13-had been prepared and sent to terminated individuals.
Of the records examined, the inspectors noted that no i
individualhadexceededthe10CFR20.101(a)limitwithout.the required verification and no worker had exceeded the limit specified in10CFR20.101(b).
The licensee program in this matter appeared adequate to keep external exposures ALARA.
L c.
Internal Exposure Control (1) Bioassay The inspectors reviewed selected urine sample measurement data and licensee whole body (WBC)' count results to assess the effectiveness of the licensee s respiratory protection pro The licensee's uranium bioassay program was primarily base (ram.
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U-235). portable low enriched (equal to or less than 10 percent nontrans Urine sampling frequency was either quarterly r
semiannually or annually based on each individual's wor,k activity.
Selected urine sample measurements collected of f
personnelfromNovember17{orsno,tedthatthesampleswere 1989 through January 25, 1990, i
l were reviewed.
The inspec i
I analyzed by a contracted laborator.
Gross beta and enriched uranium measurements were performe radiochemical analysis l-and total uranium measurements were tained by the fluorometric method., The urine sample measurement data indicated that all results were below the minimum contracted i'
l detectable levels of 0.2 disinteg/1 for enriched uranium andrations per m liter (1 for gross beta, 2.0 d m 0.5 micro) grams /1 for total uran um.
L The licensee's WBC pr gram was primarily based on their use of I
byproduct material, onepersonnel.wereevaluatedmonthlythe quarterly or annua 11 dependin ontheirjobactivities, WBC Procedure 5350, Whole Bod Counter" was discussed with the l
WBC specialist who seemed know edgeable on the operational aspects of the program.
(2) Air Sampling The inspectors reviewed selected elements of the licensee's i
airbnrne sampling program which included air sampler calibrations and sample counting results.
The ins)ectors noted, from review of the air sample calibration cieck sheets, that the licensee had tested about 155 air samplers during the-month of April 1990.
Air samplers were calibrated semiannually in accordance with VNC Procedure 4350 " Flow Calibration of Air.
I Samplers"byaNationalInstituteof$tandardandTechnology (NIST) traceable calibrated rotometer.
Air sampling data from the Bld. 102 Remote Handling 0 erations (RHO) Facility and the buildin 103 Laboratory Facilit for the period of February 26, 1990, tirough March 26, 1990, were reviewed.
The air sample data indicated that workers were not being ex?osed to intakes of radioactive materials which would i
exceed tie 40-MPC-hour control measure requiring an evaluation pursuantto10CFR20.103(b)2).
The. air sample data indicated that workers exposure from a rborne activit was being maintained ALARA.
Samples were analyzed b the analytical i
chemistry counting laboratory that utilize an automatic al ha/ beta counting system, Daily source checks were performed a IST certified sources.
and recorded.
During facility tours the inspectors observed that air sampling stations appeared lo be sufficient in number, and reasonably representative of the work area being sampled.
En ineering controls. to contain loose radioactive material were ev dent.
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(3) Respiratory Protection Although the licensee claimed no credit for respirator use,d.
portions'of the respiratory protection program were reviewe The inspectors reviewed VNC Safety Standard, 5.3,3
" Respiratory Protection," records of personnel training and qualifications, and discussed the program with the senior licensing engineer that provided oversite of the licensee's training programs.
The records review indicated that personnel had the proper medical clearances, had been respirator fit tested and had lassed the required training prior to using
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T1e facility for respirator fit testing and i
maintenance was also toured during the inspection.
Respirators fit testing was performed by using the qualitative fit. test method as opposed to the 0uantitative method.
Personnel res onsible for maintenance and repairs of respiratory equ pment were trained and certified by the manufacturer of the equ pment being used.
d.
Control of Radioactive Materials and Contamination,' Surveys, and MonitorinD During facility tours, the inspectors observed that adequate operating portable survey instruments were conveniently located at exits from contaminated areas.
Personnel survey equipment was also located at the exits of operating areas and/or building exits.
The inspectors examined records of selected surveys conducted from 4
October 1989 through April 1990 of the Building 103 laboratories and corridors; and the Building 102 hot cell operating area, manipulator l
repair and decontamination areas,in normally contaminated areas the basement; and the Building 102A area.
Contamination levels i
appeared to be maintained ALARA and consistent with 10 CFR 20.201 requirements.
The documentation indicated that appropriate surveys were conducted and records were maintained.
Management: reviewed surveys on a periodic bases, r
During the RHO facility tours, the inspectors noted that licensee used alarming photohelic gages to measure the negative pressure of.
l the hot cells.
Appendix A Table 1 of the license indicates that I
the hot cells are maintaine,d at a negative pressure 0.02 inches of water from the operating area in order to provide a positive flow of 125 linear feet per minute through the hot cell openings.
The inspectors noted that the photohelic gages were set'to alarm at about 0.02 inches of water, and were visually checked and readings recorded by RHO personnel daily.
However there was no calibration program or other checks to verify operability and verification of the alarm setpoint.
This matter was discussed with licensee management during the inspection and at the exit. interview.
The licensee informed the inspectors that they would investigate this matter.
The licensee's action regarding this matter will be reviewed during a subsequent ~ inspection, which is considered as an openitem(70-754/90-01-03).
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Records of annual licensee in-line HEPA filter testing for Buildings 102 and'103 performed in 1989 and 1990, and VNC Procedure 5200
" Testing and Maintenance of Site Absolute Filters" were examined.
i The procedure requires the following be performed: annual aerosol testing for retention of 0.3 micron diameter homogenous dioctyl i
sebacate (DOS) particles, monthly differential pressure (DP) hoods.
test for in-line filters and semiannual flowrate measurements of
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The HEPA filter test results indicated that-the filtering efficiency was being maintained equal to or greater than 99,95 percent.
Hood i
flow measurements indicated that the flow rates were being i
maintained equal or greater than 125 linear feet per minute.
The inspectors determined that the licensee appeared to be maintaining i
l ventilation systems in accordance with their procedures and license requirements.
During facility tours the inspectors made independent radiation measurements using an Eberline R0-2 portable survey meter, S/h 2691, due for calibration on July 19, 1990.
The-inspectors noted that radiation and high radiation areas and radioactive materials areas werepostedandcontrolledasrequIredby10CFRPart20.
The licensee seemed to be maintaining their previous levels of performance in this area and their program appeared adequate to the accomplishmentofitssafetyobjectives.
However, weaknesses were identified regarding calibration of the hot cell dose rate instruments and keeping t1eir alarm setpoints consistent with the license requirements.
One apparent violation was identified.
4.
Criticality Safety (88015)
The inspectors reviewed the licensee's program for compliance with'10 CFR i
Part'70, License Conditions, licensee procedures, and recommendations outlined in various industry standards, t
There had been no changes in operations that required a criticality-safety analysis since the last inspection in this area (Report No.
70-754/89-02).
Since the last inspection, the licensee has greatly reduced the number of activated criticality limit areas (CLAs).- The deactivation of these areas was performed under the licensee's Change Authorization (CA) system.
Specialnuclearmaterial(SNM)beingstored and not in use had been relocated to.the Building 103 vault for either' long term storage, ultimate disposal or transfer to the GE Wilmington, NC facility.
Within the confines of Building 103, about 11 CLAs were
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deactivated.-
The SNM in the Building 105 shop area hood was transferred
-i to Building 102 for ultimate disposal, and the hood was scheduled to be i
disposed of.
Althou h the.CLA posting was removed from these areas
.theircriticalitysafetyanalyseswerebeingmaintainedforreactivation.
if the need should occur.
Reactivation of any of the CLAs~will. require a licensee internal documented request.and appropriate management approval.
The inspectors noted from review of licensee recordf that criticality inspections conducted by the Criticality Safety Specialists, and audits.
conducted by. the radiation monitoring staf f had been performed at the
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required frequency during the past year.
No problems had been identified as a result of the inspections and audits.
Therehadbeennochangesinthecriticalitymonitoringsystems(CMSs) from that described in previous inspections.
During facility tours, the inspectors observed that each of the CMSs appeared to be functional in the areas where they were required.
Alarm. set points were observed to be r
appropriately set in accordance with the licensee's procedures.
Records of CMS function tests conducted during the past year indicated that each system had been tested monthly as required..The function tests of each i
unit included verification of detector response, the audible alarm system and that the Building 1028 main alarm indicating panel was operatlngproperly.
l During facility tours, which also included the Building 103 vault the i
inspectors observed no unsafe criticality safety practices.
Criticality i
control limits appeared to be appropriately posted where SNM was being used, handled and stored.
Each storage container observed was labeled as.
to the type and quantity of material it contained.
The licensae's performance in this area appeared adequate to the accomplishmentoftheirsafetyobjectives.
No violations or deviations were identified.
5.
Operations Review (88020)
This area was reviewed to determine if operations were being conducted in accordance with the requirements of the license, licensee procedures, and recommendations outlined in various industry standards.
The inspectors found that the general state of housekeeping in the RHO facility was good.
The Bldg. 102A filter room and some of the Bldg. 103 laboratories were untidy; however, der the SNM-960 license that required the licensee promptly corrected the problem.
There was an operation un i
the licensee to issue a CA pursuant to their VNC Safety Standard 2.0.
The CA included a safety analysis to determine if the proposed change involve an unreviewed safety question.
This change involved the installation of a dissolution apparatus and a coulometric measuring system in Hot Cell No. 3.
The equipment was used to measure uranium oxidation states in samples of irradiated. uranium oxide.
The licensee's program with regard to reviewing modifications appeared to accomplishitssafetyobjectives.
No violations or deviations were identified.
6.
Operator Training /Retrainina (F.010)
The inspectors examined the licensee's training and retraining program for compliance with Appendix A Section 5.8 of the license.
The licensee maintained an updated master. llsting of radiological safety training of and individual training folders on each employee.
all VNC employees,inees were undergoin Currently, two tra the " Radiation Monitoring Technician (RMT) Certification Trainin Program".
The inspectors reviewed the qualifications of the tra nees and found that they met the
9 requirements of the-license for RMTs.
Selected training records of employee's who work in the RHO facility were reviewed including the results of examinations.
Also theinspectorsintervIewedtheRHOarea managertodeterminewhatspecIalizedtrainingheprovidestotheworkers in the RHO facility.
The inspectors found that the RHO area manager's training program records of training given and examinations demonstrated thattheseindivIdualshadbeenprovidedadequatetrainingtoaccomplish their assigned tasks.
No violations or deviations were identified.
7.
Maintenance / Surveillance Testing (88025)
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The inspectors examined records of component surveillance testing and maintenance conducted at VNC.
The VNC facilities maintenance group has recently installed a preventative maintenance (PM) software program for the mechanical systems.
At the time of this inspection, some 100-components were on the PH schedule, and the I&E maintenance group was expected to incorporate their calibration program into the PM program.-
The surveillance test log for the Bldg 102A emergency diesel generator was examined.
The diesel generator was operated on a monthly basis, and the diesel generator maintenance log book appeared to be current and up to date.
Other aspects of the licensee's surveillance testing program l
were discussed in Section 3 of this report.
The licensee's program in this area appeared adeouate to accomplish its safetyobjectives. No violations or deviations were identified.
8.
Follow-up on IE Information Notices (9270.1) t The inspectors verified that the licensee had received and reviewed IE Information Notices No. 90-09 and 90-31 for applicability to their facility.
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9.
ExitInterview(307031 The ins)ectors met with the license representatives, denoted in Section 1 at tie conclusion of the inspection May 24, 1990.
The scope and fIndingsoftheinspectionweresummarized.
The observations described in the report were discussed with the licensee.
The inspectors discussed the apparent violation described in
'Section 3 and stated that the licensee's-position regarding this matter L
would be given further inoffice review for resolution, l
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