ML20135D451
| ML20135D451 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 12/02/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20135D449 | List: |
| References | |
| 70-0754-96-02, 70-754-96-2, NUDOCS 9612090385 | |
| Download: ML20135D451 (13) | |
Text
._
4 ENCLOSURE i
U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:
70-754 License No.:
SNM-960 Report No.:
70-754/96-02 Licensee:
General Electric. Company (GE) 1 l
Facility:
Vallecitos Nuclear Center l
Location:
Pleasanton, California i
l Dates:
November 12-15 and 18,1996 l
inspector:
C. A. Hooker, Senior Fuel Facility inspector Approved By:
Frank A. Wenslawski, Chief l
Materials Branch
Attachment:
Supplemental inspection information 1
t l
l l
j t
l l
1 I
i 9612090385 961202 PDR ADOCK 07000754 C
PDR 1
i
, EXECUTIVE
SUMMARY
Vallecitos Nuclear Center NRC Inspection Report 70-754/96-02 This routine announced inspection included aspects of radiation safety, radioactive effluents, environmental protection, emergency preparedness, solid waste operations, and transportation of radioactive materials.
Radiation Protection
' The licensee was adequately controlling external and internal exposures, and the licensee had improved its procedures for respiratory protection training and fit-testing (Section 1.2).
i The licensee was adequately controlling loose radioactive materials, and l
contamination levels appeared ALARA (Section 1.3).
Emeraency Prenaredness The licensee's emergency procedures provided adequate guidance for responding to plant emergencies and notification of offsite authorities (Section 2).
Emergency response personnel were adequately trained, and emergency drills appeared to adequately exercise the licensee's emergency response organization l
(Section 2).
l Radioactive Effluents i
)
Radioactive effluents relea;ed to the environment were being maintained ALARA (Section 3).
Environmental Protection The licensee's operations did not appeac to have any negative impact on the l
i environment (Section 4).
Solid Waste Operations l
l The licensee's program appeared acequate for meeting regulatory requirements (Section 5).
Transportation of Radioactive Material The licensee was effectively implementing a program to assure compliance with regulatory requirements (Section 6).
l
)
l l
3-l Reoort Details Summarv of Plant Status l
The use of special nuclear material (SNM) included post-irradiation examination of low-enriched uranium reactor fuel elements in the Building 102 hot cell facility. There were no current activities involved with the use of SNM in Building 103. The major ongoing site activities involved the use of radioactive materials licensed by the State of California.
l Some of these activities consisted of the fabrication of Co-60 sources, preparation of Xe-133 for medical use, and examination of irradiated reactor hardware.
1 Radiation Protection 1.1 External and Internal Exoosure Control a.
Inspection Scope (83822) l The inspector discussed external and internal exposure controls with licensee personnel and toured licensee facilities to observe radiological work practices, the operation of new hot cellinterlock air sampling equipment, and the operation of air monitoring equipment. The inspector also reviewed selected records of air sampling data, whole body counts (WBCs), and vendor dosimetry results from January 1 through October 31,1996.
b.
Observations and Findinas i
The licensee has previously evaluated and determined that workers are unlikely to receive intakes of radioactive materials from routine operations that would exceed 10 percent of the applicable annual limit of intake specified in Appendix B of 10 CFR Part 20. Therefore, a committed effective dose equivalent is not included in the total effective dose equivalent.
External exposures continue to be primarily from activities associated with the use of state licensed material. The licensee's 1995 ALARA exposure achievements are described in NRC Inspection Report 70-754/96-01, dated June 19,1996. The highest exposures related to combined SNM and state licensed activities are of l
personnel associated with the licensee's Building 102 Remote Handling Operations (RHO) hot cell activities. The RHO manager's 1996 deep-dose equivalent (DDE)
ALARA goals were 2.6 rem for a maximum individual dose,30 person rem total dose, and 0.75 rem for the average dose. The maximum year-to-date DDE was 2.01 rem. The RHO manager expected to meet the established 1996 ALARA goals.
The review of air sampling data from fixed samplers located in general work areas indicated that airborne radioactivity was routinely less than 10 percent of the i
applicable derived air concentration limits specified in 10 CFR Part 20, Appendix B, Table I, Column 3.
1 l
l i l
The inspector noted that the licensee had instituted the use of an automatic remote air sampling system for each major RHO hot cell (Nos.1-4) radiation control access lock. The sarnplers pulled air from the lock to a filter holder at the face of the hot cell. The samplers were interlocked with the outer lower door of the radiation lock, and sampling was initiated when the subject door was lowered for personnel access and automatically terminated when the door was re-closed. Each sampler was also equipped with a sample collection time totalizer. The inspector observed the operation of these samplers and no concerns were identified.
Prior to sole use of the automatic samplers, the licensee conducted comparison studies from several weeks of sampling data from lapel samplers and the lock l
samplers. The licensee determined that the lock samplers provided a more conservative assessment of airborne activity in the locks. The licensee's sampling data showed that, collectively, the running total derived air concentration-hours in the hot cell locks was less than 10 percent of the 10 CFR Part 20 annual limit of intake for the most restrictive radioactive nuclide (Sr-90 and Pu-239) applicable to i
i the facility. Lapel samplers were being used in the hot cell locks not yet equipped with automatic samplers. Personnel entries into these locks are not as frequent as the four major hot cell locks.
l l
Since current SNM activities primarily involve examination of irradiated fuel, i
bioassay sampling for uranium and plutonium have been discontinued. The licensee has established a trigger to institute such sampling based on the detection of Cs-137 (associated with irradiated fuel) in personnel WBCs that are performed onsite. The licensee also evaluates the beta-to-alpha ratio from air sampling data and wipe tests in determining the need for uranium and plutonium bioassay. WBCs were conducted either every 4 months or every 2 months, dependent on work assignments. Special WBCs are performed when there could be a suspect intake.
The review of selected WBCs indicated no worker had received any intake of Cs-137. Occasionally, trace amounts of Co-60 were observed.
l c.
Conclusions i
l The licensee was adequately controlling external and internal exposures.
l 1.2 Resoiratorv Protection Proaram a.
Inspection Scope (83822)
The inspector reviewed selected licensee procedures and records of training and fit testing. The inspector also observed the use of respiratory protection equipment during facility tours.
l l
i
! b.
Observations and Findinas The inspector noted that the licensee continues to use air purifying full-face negative pressure respiratory protection devices for routine tasks requiring respiratory protection. Air supplied hoods and full-face air supplied respirators are also used for special tasks.
I l
The inspector noted that the licensee had revised Safety Standard 5.3.3, l
" Respiratory Protection," to require routine users be re-trained and fit tested every 2 years. Previously, the licensee's requirement was that training and fit testing be conducted every 5 years. Medical clearances were performed annually and were also changed to 2 years as approved by a physician. This improvement in the safety standard was derived from observations made during previous inspections.
l The inspector noted that training, fit testing, and medical clearances for workers using respiratory protection equipment were current. During facility tours, no improper use of respiratory protection equipment was observed.
l l
c.
Conclusions The inspector concluded that the licensee's respiratory protection program was consistent with the licensee's procedures and the requirements of 10 CFR 20.1703.
1.3 Control of Radioactive Materials and Contamination a.
inspection Scope (83822) l The inspector reviewed selected radiation work permits (RWPs) and routine and l
non-routine survey records for Buildings 102,103, and 349. The inspector also reviewed selected survey instrument calibration and maintenance records for the past year. Worker activities, radiation warning postings, and controls were observed during facility tours.
b.
Observations and Findinas Contamination levels in the RHO hot cell radiation locks and access corridor continue to be maintained at a level where alpha contamination is not routinely 2
l detected, or at less than 2000 disintegrations per minute per square foot (dpm/ft ),
2
~
Beta contamination levels were typically maintained to less than 50,000 dpm/ft,
Instrument calibrations were performed at the required frequencies, and maintenance was logged on each instrument's data cards. During facility tours, the inspector observed that personnel survey instruments were conveniently located at exits from contaminated areas. All survey instruments examined were noted to be operational and currently calibrated.
I
l
- l The inspector noted that RWPs provided adequate instructions to workers and each worker had signed his/her acknowledgement on the RWP, indicating their
]
understanding of the RWP requirements. The inspector did not observe any task that was not being performed in accordance with the requirements and controls specified on the workers' RWP.
l The inspector noted that radiation and high radiation areas, and radioactive I
materials areas were posted and controlled as required by 10 CFR Part 20. Special status signs were present throughout each facility to warn personnel of elevated radiation levels. Housekeeping was generally good in the areas toured.
The RPG manager provided a demonstration of the warning system for the high racN,a access control gate to the toof of Building 102. The inspector noted that when this properly posted and locked gate was opened, the local warning light and j
the warning annunciator light in the RHO supervisor's office were appropriately j
activated. No concerns were identified by the inspector.
c.
Conclusions i
The inspector concluded that the licensee was adequately controlling radioactive materials and that contamination levels appeared ALARA.
i 1.4 Trainina a.
Inspection Scope (83822)
During facility tours the inspector observed work activities, held discussions with facility workers, and reviewed licensee training records, u.
Observations and Findinas The inspector noted that new employees received training that included the fundamentals of radiation protection, criticality safety, hazardous chemical safety, fire protection, emergency requirements, and security. Refresher training on the fundamentals of radiation safety was provided annually, in addition to the l
licensee's formal general employee training programs, the Building 102 RHO I
manager continues to schedule formal monthly safety / training meetings that cover various aspects of radiological safety, criticality safety, non-radioactive hazardous materials safety, radioactive waste and transportation requirements, and industrial i
l safety.
Based on observations during facility tours and discussions with operators, the inspector did not identify any concerns related to radiation protection training of workers.
l l
l i
1 i c.
Conclusions l
The inspector concluded that the licensee's training program was consistent with the requirements of 10 CFR 19.12, and Section 7.3, " Radiation Safety Training,"
Appendix A of the license. Workers appeared knowledgeable of radiation safety practices and procedures.
2 Emergency Preparedness 2.1 Emeraency Proaram and Eauioment Based on the review of onsite activities and the licensee's evaluation that there
{
could be no significant offsite radiological consequences from likely and unlikely accidents, in 1991 the NRC discontinued the requirement for the licensee to maintain a Radiological Contingency Plan relative to SNM activities. However, in Section 4.5, " Compliance Policy," Appendix A of the licensee's renewal application i
dated December 1,1992, the licensee included a commitment to maintain procedures for responding to emergencies.
a.
Inspection Scoce (88050)
The inspector discussed the licensee's emergency preparedness program with licensee personnel and reviewed applicable emergency response procedures, emergency response training records, and drills. The inspector also examined selected emergency response equipment.
b.
Observations and Findinas The licensee maintained procedures for responding to bomb threats, fires, criticality events, civil disorders, radiation emergencies, natural disturbances (earthquake, tornado and hurricane), breach of security, transportation of radioactive materials, major power outages, chemical or oil spills, and hazardous materials / waste emergencies. The licensee's procedures adequately outlined their emergency response organization, responsibilities of emergency response personnel, classification of events, and notification of outside agencies.
Inspection Report 70-754/95-02, dated November 16,1995, described that Section 7, "Ciassification of Emergencies," of the licensee's procedures did not include notification of local authorities or the NRC for an Alert classified emergency.
For an event classified as a Site Area Emergency, the procedure required notification of offsite authorities, the NRC Region IV Office, and the NRC Region IV Walnut Creek Field Office. However, the NRC Operations Office was not included in the notification. The inspector noted that the licensee had revised its procedures to include the appropriate notifications for both of the above situations.
i
1
! l The inspector noted that annual drills and critiques were conducted as required by the licensee's procedures. The review of records of onsite drills and critiques indicated that personnel were familiar with their assigned responsibilities and identified deficiencies were addressed. The licensee quarterly exercised their
)
l communication with offsite support agencies.
)
i The inspector noted that the emergency cabinets contained equipment and supplies l
as delineated in the licensee's procedures. Emergency cabinets were routinely l
inspected and inventoried by the safety staff in accordance with established l
procedures. Radiation survey instruments examined were currently calibrated and operational. Self contained breathing apparatuses were neatly maintained and all air tanks were full.
l During facility tours the inspector observed that the placement of fire extinguishers appeared appropriate. The inspector also observed the testing of the Building 103 fire sprinkler system alarm. No concerns were identified. Emergency exits and pathways were well marked and easily identifiable, c.
Conclusions l
The licensee's emergency procedures provided adequate guidance for responding to l
plant emergencies and notification of offsite authorities. Emergency response l
personnel were adequately trained, and emergency drills appeared to adequately f
(
exercise the licensee's emergency response organization. The licensee's emergency response equipment was maintained in a state of operational readiness.
3 Radioactive Effluents a.
Insoection Scoce (88035)
The inspector reviewed selected records.of liquid and gaseous effluent sampling data from January 1 through November 14,1996, and cbserved sampling and sample counting ooerations for a retention basin discharge.
i b.
Observations and Findinas l
The inspector noted that there had been no changes in the licensee's processing of l
radioactive liquid waste. Radioactive liquids are either solidified or collected and transported in a stainless steel tank to the Building 349 waste evaporator facility for processing. Concentrates from the evaporation process are solidified for waste disposal. Effluent waters from the evaporator are collected in monitoring tanks for j
analysis and ultimately disposed of by evaporation through a boiler. The inspector noted that the sampling data before evaporation indicated no detectable 4
radioactivity above the action levels specified in Section 10, Appendix A of the l
license.
I
_m
~
1 f
I
.g.
I Non-contact (with radioactive material systems) industrial waste water is collected in three retention basins (Nos. 2 4) and is either pumped to a small onsite lake or discharged to an offsite creek (Vallecitos Creek) as authorized by a Nate discharge l
permit. Basin 1 continues to be used for collecting treated non-radioactive sanitary l
l waste, which is sampled and analyzed prior to being sprinkled on the licensee's L
property. The sampling data for each basin discharged indicated no detectable l
l radioactivity above the action levels specified in Section 10, Appendix A of the license. On November 14,1996, the inspector observed sampling of Basin No. 2, laboratory preparation of the sample, and the counting operation prior to discharging the basin to Vallecitos Oreek. No concerns were identified.
Stack gaseous effluent sampling data indicated that releases were well below the action levels specified in Section 10, Appendix A of the license and the limits I
specified in 10 CFR Part 20, Appendix B, Table 2, Column 1. Offsite doses from l
gaseous effluents are described below.
e c.
Conclusions The inspector concluded that radioactive effluents released to the environment were being maintained ALARA.
4 Environmental Protection l
a.
insDection Scope i
t i
The licensee's Effluent Monitoring and Environmental Annual Summary Report for 1995, vendor sample analysis reports for 1996, and the licensee's environmental air sampling counting results were reviewed.
b.
Observations and Findinas The licensee's annual effluent and environmental report was issued in accordance l
with Condition No. S-6 of the license and included a summary of the radioactive and nonradioactive releases from the site The report also included measurements of radioactive and nonradioactive constituents from neighboring streams, wells, j
soils, and vegetation. Sample analytical results were noted to be less than or l
slightly above detection limits. The data presented in the report indicated that there had been no negative impact on the environment. No errors or anomalies were noted in the measurement data provided in the report. However, the inspector noted apparent typographical errors in the units of the action levels specified in l
Section 10, Appendix A of the license for Cs-137 in stream bottom samples, and gross alpha and beta for vegetation samples. Specifically, the action level specified in the license for Cs-137 in stream bottom samples is 1.5E-5 picocuries per gram (pCi/gm) as opposed to microcuries per gram for the other set action levels with i
similar exponents.. The action levels for gross alpha and gross beta in vegetation i
samples are listed as 1.OE-5 pCi/gm and 5.OE-5 pCi/gm, respectively. These action 1
l
l 1 l
levels are considerably below what would be considered as the minimum detection l
level achievable in industry. The licensee acknowledged the error and stated that they would submit a license amendment to correct the matter. It is noted that Cs-137 is actually regulated by the State of Califomia.
The inspector observed that the licensee had calculated the annual dose from 1995 gaseous effluent discharges in accordance with the criteria used by the Environmental Protection Agency (EPA) in 40 CFR Part 61, Subpart 1. The dose was calculated using EPA's COMPLY computer code. The licensee's calculated effective dose equivalent for the maximally exposed individual was 0.3 millirem.
c.
Conclusions The licensee's operations did not appear to have a negative impact on the environment.
5 Waste Generator Requirements and Waste Storage a.
Inspection Scoce (84850 and 84900)
The inspector discussed solid waste operations with cognizant licensee personnel and reviewed selected licensee procedures.
b.
Observations and Findinas Radioactive waste shipments primarily involve byproduct material under the jurisdiction of the State of California. The licensee had made no waste shipments containing SNM during the past year. Solid waste under a state license was being packaged, sent to a vendor for further processing (incineration / compaction), and ultimately for burial at the Barnwell disposal facility. The licensee had adequate storage space for waste.
The RHO manager continues to be the primary person responsible for radioactive waste processing and transportation activities at the facility. All of the radioactive solid wastes generated onsite are transferred to RHO f acilities for inspection and processing. Based on the review of the licensee's procedures and discussions with the RHO manager, no concerns were identified in the licensee's ability to:
(1) classify waste pursuant to 10 CFR 61.55, (2) ensure that waste met the characteristics of 10 CFR 61.56, and (3)' prepare waste manifests and mark packages in accordance with the requirements delineated in 10 CFR Part 20.
C.
Conclusions The inspector concluded that the licensee's procedures were consistent with NRC requirements for waste disposal.
^
l
! 6 Transportation of Radioactive Materials a.
Inspection Scope (86740)
The inspector reviewed selected licensee procedures, records of SNM shipments for the past year, and the licensee's annual quality assurance audit of transportation activities, b.
Observations and Findinas The licensee had made only two shipments of SNM during the past year. One shipment of 6 non-irradiated low enriched fuel rods that were received from the GE-Wilmington, North Carolina fuel fabrication facility on July 19,1996, and returned to the Wilmington facility on August 12,1996. The other shipment involved a limited quantity of low enriched uranium powder samples sent to the Wilmington facility on September 20,1996.
Based on the examination of licensee receipt and shipping packages, the inspector noted the licensee performed receipt surveys pursuant to 10 CFR 20.1906, transfers of special nuclear material were conducted in accordance with the requirements delineated in 10 CFR 70.42 and the regulatory requirements of 10 CFR Parts 71, and 49 CFR Parts 171 through 189 for transporting radioactive materials were being met.
Quality Assurance Audit,95:03,"V&MO Certified Shipping Containers," was conducted in December 1995 to verify the requirements defined in the licensee's NRC approved quality assurance program (QAP-1). The inspector noted that the audit covered the requirements of Subpart H to 10 CFR 71. The audit identified no findings that required corrective actions.
c.
Conclusions The inspector concluded that the licensee was effectively implementing its regulatory requirements.
7 Followup (92702)
(Closed) Violation 70-754/9601-0: Failure to maintain the required efficiency rating of the Building 103 radioactive effluent exhaust filtering system. Based on l
discussions with cognizant licensee personnel, the review of licensee records, and l
observations during facility tours, the inspector verified that the licensee had completed the corrective actions, as stated in its timely letter dated July 18,1996.
The inspector noted that the test results following repairs indicated that the filtering system met the license efficiency specification. The licensee had initiated a data base system to assure maintenance problems involving required safety systems l
, 1 l
were followed to closure.' An appropriation request had been approved to replace the system.
8 Exit Interview The inspector presented the inspection results to members of the licensee management at the conclusion of the inspection on November 18,1996. The
[
licensee acknowledged the findings presented.
l Although proprietary information was reviewed during this inspection, such information is not knowingly described in this report.
i l
l l
l l
l 4
l l
l l
l.
ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee F. Arlt, Manager, Facilities Maintenance C. Basset, Manager, Nuclear Safety C. Hill, Supervisor, Remote Handling Operations A. Mindt, Specialist, Radiation Monitoring B. Murray, Nuclear Safety Engineer G. Stimmell, Manager, Vallecitos and Morris Operations J. Tenorio, Manager, Remote Handling Operations INSPECTION PROCEDURES USED IP 83822: Radiation Protection IP 88035: Radioactive Waste Management IP 88045: Environmental Protection IP 88050: Emergency Preparedness IP 84900: Low-level Waste Storage IP 84850: Inspection of Waste Generator Requirements IP 86740: Inspection of Transportation Activities IP 92702: Followup on Corrective Actions for Violations and Deviations ITEMS CLOSED Closed 70-754/9601-01 VIO Failure to maintain the required efficiency rating of a radioactive effluent exhaust filtering system LIST OF ACRONYMS USED ALARA as low as is reasonably achievable dpm/ft disintegrations per minute per square foot DDE deep-dose equivalent EPA Environmental Protection Agency GE General Electric Compar.y pCi/gm pico curies per gram RHO Remote Handling Operations RWP radiation work permit SNM special nuclear material WBCs whole body counts