ML20133H441
| ML20133H441 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 10/01/1985 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20133H437 | List: |
| References | |
| 50-070-85-01, 50-073-85-02, 50-70-85-1, 50-73-85-2, NUDOCS 8510170358 | |
| Download: ML20133H441 (12) | |
See also: IR 05000070/1985001
Text
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U. S. NUCLEAR REGULATORY COMMISSION l
REGION V
Report Nos. 50-70/85-01, 50-73/85-02
Docket Nos. 50-70 and 50-73
License Nos. R-33 and TR-1
Licensee: General Electric Company
P. O. Box 460
Pleasanton, California 94566
Facility Name: Nuclear Test Reactor (NTR) and General Electric Test
Reactor (GETR)
Inspection at: Vallecitos Nuclear Center
Inspection conducted: August 12-15, 1985
Inspector: .
b
M. Cillis, Radiation Specialist
/c !/ P[
Date Signed
Approved By: $hMuk -
G.P.Y@as, Chief
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to/s/
~
Da'te Signed
Facil(itibsRadiologicalProtectionSection
Summary:
Inspection on August 12-15, 1985 (Report. Nos. 50-70/85-01 and 50-73/85-02)
Areas Inspected: Routine unannounced inspection by a regionally based
inspector of GETR/NTR facility operations, radiation protection program,
environmental monitoring program. emergency preparedness programs, review and
audits, standard operating procedures, training, surveys, operating logs and
records, transportation activities, reactor operator and senior reactor
operator requalification program, surveillances, experiments, organization,
Information Fotices (ins), followup items, and a tour of the facility. During
this inspection, Inspection Procedures 40750, 41745, 42745, 61745, 69745,
82745, 83743, 86740, 92701 and 92717 were performed. The inspection involved
26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> of onsite time by one inspector.
Results: Of the sixteen areas inspected, one apparent violation involving
failure to conspicuously post a radiation area (see paragraph 8.b(2)) and one
unresolved item involving NTR licensed operator activities (paragraph 2.a.)
were identified.
gO170358851001
g ADOCK 05000070
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DETAILS
1. Persons Contacted
R. W. Darmitzel, Manager, Irradiation Processing Operation
- G. W. Titus, Facility Manager, GETR/NTR
- W. King, Manager, Nuclear Safety and Quality Assurance
- D. C. Bowden, Supervising Engineer
G. Cunningham, Senior Licensing Engineer
L. Irwin, Supervisor, Instruments and Electrical Maintenance
- W. B. Johnson, Senior Reactor Operator
- E. Strain, Nuclear Safety Engineer
B. Kreutel, Reactor Operator
S. Jackson, Reactor Operator
R. E. Gest, Specialist - Facility Protection
R. R. Synder, Senior Reactor Operator
J. E. Delzell, Radiation Monitor
R. F. Begley, Specialist - Facility Protection
E. W. Hagberg, Specialist - Facility Protection
2. Organization and NTR Operations
a. NTR
The licensee's organizational structure related to NTR operations
was examined.
The Manager of NTR is responsible for the operation, maintenance and
repair of the NTR facility. Reactor operations are performed by two
licensed reactor operators (R0s) and two licensed senior reactor
operators (SR0s). The NTR Manager is also in the process of
obtaining an SR0's license. J
The examination disclosed that the R0's licenses (OP-6288-1 and
OP-6289-1) and one SR0 license (S0P-1272-7) contained the following
minimum conditions:
RO "Another individual must be present when you are
performing licensed duties."
SRO "Another individual must be present when you are
manipulating the controls."
The special license conditions were added because of medical
conditions of the involved licensed operators. Copies of the
licenses were made available to the facillty licensee.
During the inspection, the inspector observed reactor operations
were performed by involved R0s and SR0s without another person being
constantly present in the control room. This observation was
discussed with the licensee's staff. The licensee NTR operating
staff stated that they were not certain what the license conditions
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meant. They added that no steps or policies were established by
themselves or General Electric management for assuring another
person was present whenever they performed licensed duties and/or
manipulated the controls of the NTR.
I The inspector informed the licensee that the R0/SRO license
conditions require that another person be present that is capable of
taking appropriate action should the operator become incapacitated
because of his/her medical condition. The licensee's internal
review and audit staff informed the inspector that they were in the
process of interpreting what the license conditions meant at the
time of this inspection. They stated that they had came to the same
conclusion that was provided to them by the inspector and were about
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to take action to inform NTR management of their interpretation.
The NTR Facility Manager took immediate action to provide a backup
person to provide surveillance whenever the NTR is operated by
individual having medical restrictions identified as a condition of
their license. The licensee also took immediate steps to modify his
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procedures accordingly.
The inspector informed the licensee that 10 CFR Part 50.54(i)
- requires that
- "the licensee shall not permit the manipulation of
l the controls of any facility by anyone who is not a licensed
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operator or senior operator as provided in Part 55 of this chapter."
10 CFR Part 50.30 and 55.31 states that licenses are issued in such
form and may contain conditions and limitations as it deems
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appropriate and necessary. Part 55 requires that the conditions and
limitations of the license be complied with.
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The inspector added that both the operator and licensee have the
responsibility of assuring the license conditions are followed.
Although other individuals were present at the NTR facility the
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inspector informed the licensee that authorizing the R0s/SRO to
operate the NTR without another person being present in the control
- room represents a potential violation. The licensee representative
observed that the license conditions do not specifically require
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4 that the individual be continuously present in the control room.
I In view of the above facts and since the licensee implemented
- appropriate compensatory measures this matter will be considered an
, unresolved item pending in office NRC review (50-73/85-02-03).
b. GETR
Five Specialist - Facility Protection (S-FP) are assigned to provide
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continuous coverage on a 168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> week basis at the Vallecitos
Nuclear Center (VNC). The S-PF coordinate their responsibilities
from the GETR control room. The S-FP staff is responsible for
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providing surveillances of other activities performed at the VNC
site. When the control room is unoccupied the area is locked and
necessary alarms are electronically monitored by the VNC security
force.
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The S-fps are responsible for acting as the initial response
Emergency Operations Coordinator (EOC) for all emergencies at VNC
(See paragraph 12). The S-fps are also responsible for performing
the health physics functions at GETR.
No violations or deviations were identified.
3. Independent Reviews and Audits
a. General
Technical Specifications, Section 6.2 for the NTR requires that
periodic examinations and verifications shall be performed of
facility operations, maintenance and shall be performed by
individuals that do not have direct responsibility for operation of
the reactor. Section 9.2, " Review and Audit" of the GETR Technical
Specifications requires a similar review and audit function be
performed at GETR.
b. NTR
NTR audit reports dated January 2, 1985 and April 18, 1985 were
reviewed and were found to be consistent with TS, Section 6.2. The
audits were performed for the purpose of showing NTR activities were
accomplished in accordance with the TS that were approved in
December 1984.
The audits appeared to provide an indepth review of licensee's
activities that have occurred since the TS were approved. The
inspector noted that the audits did not include an examination of
the licensee's radiation protection program and emergency plan.
The above observation was discussed at the exit interview. The
inspector emphasized the importance that licensee audits include an
examination of the radiation protection program.
No violations or deviations were identified.
c. GETR
A GETR audit report dated October 4,1984 was reviewed and was found
to be consistent with Section 9.2 of the TS.
The audit report identified that GETR's Standard Operating
Procedures (S0Ps) were essentially obsolete and were no longer being
followed. The report recommended that. new procedures be established
and that the Technical Specifications be modified to reflect the
current status. A request for amending the license was submitted to
the NRC on June 26, 1985. No significant progress had been made to
establish a new set of SOPS. Discussions with the licensee's staff
disclosed that new procedures would be developed upon approval of
the license amendment by NRR.
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The inspector emphasized the need for developing new procedures or
- . updating the current procedures. This item will be examined during
a subsequent inspection (50-70/85-01-02 and 50-73/85-02-02).
i 4. Logs, Records, and Documents
GETR and NTR facility operations and radiation protection surveillance
records, logs, procedures and related licensee documents for the period
of October 1983 through July 1985 were reviewed. Specifically selected
portions of the following documents were reviewed:
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GETR/NTR. Radiation Protection Survey Records
Personnel Dosimetry, Reports ,
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- Training Records (General Emplo'yee Training, Emergency Preparedness
Training, and Reactor Operators Requalification Training) ,
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GETR/NTR Surveillance Records
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Preventative Maintenance Sheets
Console Logs ]
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Control Room Data Sheets !
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Daily Operational Check Sheets ;
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Monthly Operations Check Sheets
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i Scram Reports
Equipment Service Log
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GETR/NTR Technical Specifications
Instrument Calibration Records
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Review and Audit Reports ;
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i As part of the above review, the inspector specifically verified
i conformance with the NTR Technical Specifications, Section 2.1, " Safety
i Limits", Section 3.1, " Reactor Core Parameters," Section 3.2, " Reactor ,
! Control and Safety System" and Section 4.1, " Surveillance Requirements". l
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The results of the above record reviews are discussed in the subsequent -
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No violations or deviations were identified. !
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5. Operators Requalification Program :
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The inspector verified that the licensee's reactor operator (RO) and l
i senior reactor operators (SRos) requalification program for 1983, 1984, !
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i and 1985 was performed in accordance with the NRC's approved program of
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December 1979. The verification was accomplished through the review of
training records, reactor operations records, R0 and RSO written
j examinations, and discussions with the licensee's staff.
No violations or deviations were identified. !
6. Experiments
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The inspector reviewed the Nuclear Test Reactor Standard Operating
Procedure (SOP), Chapter 10, " Experiment Operations", including all
changes, revisions and new experiments approved since the last
inspection. The inspector determined that required approvals of new
experiments and changes to experiments had been performed it accordance
with the Technical Specifications, Section 6.2.3. The inspector found
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that potential hazards and reactivity effects had been considered and
appropriate radiation protection measures were defined.
j No violations or deviations were identified.
q 7. Procedures
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An examination of Standard Operating Procedures (SOP) associated with the
administration of surveillance activities at GETR and operations of the
NTR was conducted.
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The inspector verified on a sampling basis that the procedures provided
for use by operators at the NTR console were the latest revisions and
- that they had been reviewed and approved in accordance with the NTR
Technical Specifications.
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The examination did not disclose any discrepancies with the
implementation of the NTR operating procedures. The examination
disclosed that radiation protection procedures required by
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Section 6.3.1(h) of the NTR Technical Specifications were not being
followed. In particular the required weekly neutron surveys of the NTRs
North Room have not been taken since January 1985 as specified in Nuclear
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Safety Procedure (NSP) No. 3450, "NTR Work Routines". The health physics
technician assigned at the NTR was not familiar with the requirement.
, The technician's supervisor was unaware that the required surveys were
- not being performed. Discussions with the staff revealed that they felt
the need to perform weekly neutron surveys was too frequent; however, the
procedure was never changed to reflect the need to reduce the frequency
for conducting the survey.
! The inspector observed a note in the procedure file that was signed by
- the Supervising Engineer responsible for implementing the radiation
program. The note, dated January 9, 1985, eliminated procedure NSP
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No. 3400, "GETR Work Routines". The note added that the procedure will
be changed to reflect reduced survey requirements at GETR on a time
permitting basis. The procedure had not been changed as of August 15,
i 1985. The inspector noted the Specialist-Facilities Protection (S-FP)
i assigned to' provide continuous three shif t coverage at the Vallecitos
i Nuclear Center established their own work routine surveillance program
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'for GETR. The inspector noted that all of the S-FP appeared to be
following the unof ficial program that had been established.
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The inspr.ctor noted that the licensee's internal review and audit group
had identified that GETR procedures were obsolete (see paragraph 3(b)).
The above observations were brought to the licensee's attention at the
exit interview. This item will be examined during a subsequent
inspection (50-70/85-01-02 and 50-73/85-02-03).
No violations or deviations were identified.
8. Environmental Monitoring
.) The licensee's environmental monitoring program for NTR/GETR was
examined.
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i The examination revealed that the licensee's environmental monitoring
program is a site wide program which includes measurements of
radioactivity in air, soils, wells, vegetation, and streams. The program
also includes direct radiation measurements that is accomplished with an
array of thermoluminescent dosimeters. The results of the environmental
monitoring surveillance programs accomplished during the period of
January 1984 through March 1985 were reviewed.
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The examination disclosed that there is no ef fect on the environs as a
result of GETR/NTR operations.
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No violations or deviations were identified.
9. Radiation Protection
a. Surveys
10 CFR Part 20.201, " Surveys", requires that licensee's perform
evaluations of the radiation hazard that may be present. Further it
- requires that when appropriate such evaluations include measurements
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A review of GETR/NTR survey records for the period of 1984 through
July 1985 was conducted. Discussions related to the radiation
- monitoring programs at these facilities were held with the
licensee's staff.
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- The licensee's radiation protection monitoring program consists of
the following:
Direct radiation measurements using portable and fixed type
, instruments.
Contamination surveys.
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Effluent Monitoring (e.g., liquids, gases and particulate).
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Continuous Air Monitors (CAMS) and fixed typed air samplers are used
for performing effluent monitoring of airborne ef fluents at both
GETR/NTR.
The survey data appeared to be consistent with the results provided
- in the licensee's annual reports for 1983 and 1984.
The examination identified some areas of the radiation monitoring
program needing improvements even though the program appeared to be
consistent with 10 CFR Parts 20.201 and 20.401. The inspector noted
that one of two CAMS located at GETR appeared to be malfunctioning.
For example, the count rate over a period of six to eight months
fluctuated from 1500 counts per minute (cpm) to over 20,000 cpr.
The other CAMS count rate remained constant. The licensee's staff
stated that grab air samples taken adjacent to the CAM did not
indicate any activity greater than background. The staff was unable
to explain the cause for the fluctuating count rate. They thought
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it may be due to an electronic problem or increase in background.
. The inspection also disclosed a calibration curve for converting the
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CAMS readings in counts per minute to airborne concentration levels
in microcuries per milliliter was not available. The Shift S-fps
did not know how to convert the CAMS readings to units of
radioactivity as defined in 10 CFR Part 20.5.
The above observations were brought to the licensee's attention at
the exit interview. The licensee stated that the inspectors
observations would be evaluated.
No violations or ' deviations were identified.
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b. Posting and Labeling
1. NTR
The inspector verified that the licensee's posting and labeling
practices were consistent with 10 CFR 19.11, "Pocting of
Notices to Workers" and 10 CFR 20.203, " Caution Signs, Labels,
Signals and Controls.
2. GETR
The inspector verified that the licensee's posting practices
were consistent with 10 CFR Part 19.11.
10 CFR Part 20.203, " Caution Signs, Labels, Signals, and
Controls" requires that radiation areas, as defined by 10 CFR
Part 20.202(b)(2), shall be conspicuously posted with a sign or
- signs bearing the radiation caution symbol and words
Caution - Radiation Area. 10 CFR Part 20.203 states that
I licensee's may provide any additional information which may be
i appropriate in aiding individuals to minimize exposure to
radiation or radioactive material,
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On August 15, 1985, the NRC inspector observed that individuals
leaving the GETR control room could enter a radiation area with
whole body dose rates up to 16 millirem per hour without
observing a " Caution Radiation Area" sign. The Radiation
levels were confirmed by the inspector and licensee
representative. An NRC ion chamber, Model R02A, Serial
No. 1024, due for. calibration on August 28, 1985, was used to
verify the radiation levels.
The inspector also noted that the licensee's practices for
posting of areas havir.g loose surface radioactive material were
inconsistent. For example, an area in the demineralizer room
having loose surface contamination levels was identified with a
large plastic sign. The sign clearly indicated the area had
loose surface contamination. An area (e.g. , tank farm resin
pad) located approximately 20-30 feet away also had loose
surface contamination but was not identified with a similar
sign. However, the area was posted with radioactive material
area and high radiation area signs. Discussions with the
licensee's staff disclosed that normally contaminated areas are
identified with the radioactive material area sign. The
inspector pointed out that the normal radioactive material sign
does not provide sufficient information to alert personnel as
to whether or not an area may have loose surface contamination.
The inspectors observations were brought to the licensee's
attention during the inspection. The licensee took immediate
steps to correct the posting discrepancies that were brought to
their attention. The licensee's corrective actions were
verified by the inspector on August 15, 1985.
All other areas visited during the inspection appeared to be
consistent with 10 CFR Part 20.203 requirements.
The above observations were discussed at the exit interview.
The licensee informed the inspector that personnel would be
instructed of appropriate posting practices and that methods
for identifying areas having loose surface radioactive material
would be evaluated.
The inspector commended the licensee's staff for the immediate
steps taken to correct the posting deficiency. The licensee
was informed that failure to conspicuously post the radiation
area was considered as a violation (50-70/85-01-03). The
inspector added that no~ response was necessary in view of the
timely manner the item was corrected.
c. Training
General Employee's Training
The licensee's general employce's training (GET) program for
assuring compliance with 10 CFR Part 19.12, Instructions to workers
was examined.
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The inspector noted that the GET program has been taped on a video
cassette. The inspector observed presentations of the video tape to
workers during the inspection. Records of visitors and workers
viewing the tape are maintained by the licensee.
The inspector concluded that the licensee's GET program was
consistent-with 10 CFR Part 19.12.
No 'vlo1ations or deviations were identified.
d. Solid Waste
No solid wastes are directly shipped from GETR/NTR. Possession of
all wastes generated at GETR/NTR is transferred to the by product
materials license ~ issued by the-State of California and then
' disposed under that license.
No violations or. deviations were identified.
e. Liquid _ Releases
The inspection disclosed that 'no activities are performed at GETR
which generate liquid effluent wastes. Liquid effluents from the
NTR facility are collected with effluents from other facilities in
the site retention basin. The basins are sampled and the samples
are analyzed prior to release. A review of the reported data
revealed that the effluents are well within the permissible release
limits allowed by 10 CFR Part 20.106, " Radioactivity in Effluents to
Unrestricted Areas".
No violations or deviations were identified.
f. Instrument Calibration
An examination of the licensee's program established for the
calibration of portable radiation detection instruments was
conducted. The inspector verified the calibration data associated
with five portable instruments that were selected at random during a
tour of the licensee's facilities. A review of the records
confirmed that the instruments had been calibrated as shown on the
stickers affixed on each instrument.
The examination disclosed that the licensee's calibration program
appeared to be consistent with ANSI N323-1978, " Radiation Protection
Instruments Test and Calibration".
No violations or deviations were identified.
g. Personnel Monitoring Program
The licensee's personnel monitoring program was examined and was
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found to be consistent with 10 CFR Part 20.202, " Personnel
l Monitoring."
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Personnel monitoring exposure records for the period of 1983 through
March 1985 were examined. The inspector noted the highest annual
exposures received was 2565 mrem.
No violations or deviations were identified.
10. Transportation Activities
The licensee transfers possession of any material to be shipped to the
State of California by product material license prior to shipment. All
radioactive material shipments from the General Electric site are
normally accomplished under the State of California license.
No violations or deviations were identified.
11. Licensee Evaluations of Information Notices
The inspector verified that the licensee had developed an acceptable
method for evaluating IE Information Notices.
No violations or deviations were identified.
12. Licensee Actions on Previous Inspection Findings
a. Elg
(Closed) Followup Item (50-73/83-01-01 and 50-73/83-01-02). The
licensee's corrective actions related to these items were reviewed
and were found to be satisfactory. This matter is closed (83-01-01
and 83-01-02).
(Closed) Licensee Letter of 01-11-80. The licensee's corrective
actions related to this item was reviewed and was found to be
satisfactory. This matter is closed (01-11-80).
No violations or deviations were identified.
b. GETR
(Closed) Followup Items (50-70/81-02-01 and 50-70/81-02-02). The
licensee's actions related to these items were reviewed and were
found to be acceptable. This matter is closed (81-02-01 and
81-02-02).
No violations or deviations were identified.
The licensee's capabilities for responding to emergencies as described in
the emergency plan that was developed for demonstrating compliance with
10 CFR Part 50.54(q) was examined.
The inspection disclosed that the licensee's plan which was approved by
NRR, became effective on September 10, 1984. The plan was established as
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a generalized plan for all facilities located at VNC. Applicable
facility emergency procedures have been developed. Periodic drills and
exercises have been conducted as prescribed in Section 10.1 of the plan.
The inspector observed the emergency equipment described in Section 8.0
during the inspection.
Interviews were held with the licensee's staf f for the purpose of
verifying the effectiveness of training that is provided pursuant to
Section 10.1 of the plan. The licensee's representative responsible for
providing the training was in attendance during the inspector's
interviews. The interviews identified that the training was provided as
required by the plan; however, it did not appear to be ef fective. The
interviews disclosed most of the S-fps were not particularly
knowledgeable of their responsibilities. The licensee's representative
accompanying the inspector stated that it appeared like improvements in
training were needed. The inspector also noted that records of the
training that was provided were not maintained.
The inspector emphasized the importance of improving training
effectiveness and documentation at the exit interview. This item will be
examined during a subsequent inspection (50-70/85-01-01, 50-73/85-02-01).
No violations or deviations were identified.
14. Unresolved Items
An unresolved item is a matter about which more information is required
in order to ascertain whether it is an acceptable item, an open item, a
deviation, or a violation. An unresolved item is discussed in paragraph
2.a.
15. Exit Interview
The inspector met with the licensee's representatives (denoted in
paragraph 1) at the conclusion of the inspection on August 15, 1985. The
inspector summarized the scope and findings of the inspection. The
licensee was informed of the violations described in paragraph's 2(a) and
8.b(2). The inspector commended the licensee's staff for the corrective
actions taken to resolve the potential violation and the unresolved item.
The open items related to procedure compliance, obsolete procedures and
emergency plan training were brought to the licensee's attention. The
inspector emphasized the importance for resolving the open items in a
timely manner.
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