ML20137X922

Insp Rept 70-0754/97-01 on 970331-0403.No Violations Noted. Major Areas Inspected:Mgt & organization,operations,non- Reportable Operational Events,Operator Training,Maint & Surveillance Testing

ML20137X922
Person / Time
Site:	07000754
Issue date:	04/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137X899	List: ML20137X895 ML20137X922
References
70-0754-97-01, 70-754-97-1, NUDOCS 9704220250
Download: ML20137X922 (12)

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! ENCL'OSURE U.S. NUCLEA'R REGULA"a" COMMISSION REGION IV l

Docket No.: 70 754 License No.: SNM-960 Report No.: 70-754/97-01 i

Licensee: General Electric Corppany Facility: Vallecitos Nuclear Center (VNC)

Location: Pleasanton, California

{ Dates: March 31 and April 1-3,1997 l*

Inspector: C. A. Hooker, Senior Fuel Facility inspector Approved By: Frank A. Wenslawski, Chief i Materials Branch

Attachment:

Supplemental Inspection information 9704220250 970416 PDR ADOCK 07000754, C PDR ,,

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EXECUTIVE

SUMMARY

Vallecitos Nuclear Center 3

NRC Inspection Report 70-754/97-01 This routine announced inspection included aspects of management and organization, operations, non reportable operational events, operator training, and maintenance and surveillance testing.

Manacoment and Oroanization

• Personnel changes in the licensee's organization had no advarse impact on the safety of licensed activities (Section 1.1).

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• The licensee was adcquately reviewing its safety programs (Section 1.2). f

• The lack of timeliness in responding to internal inspection findings and issuance of safety inspection reports indicated a need for improvement in the implementation of ,

the site management safety inspection program (Section 1.2).

Ooerations Review i

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• The licensee was effectively implementing its criticality safety program requirements t

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• The licensee had plans to. replace its criticality monitoring system which will be an improvement over the existing system (Section 2.3).

Non Reportable Ooerationalivents

• The licensee's procedures adequately provided the means for identification, review, 4

and reporting of operational events (Section 3).

• Internal reporting of an incident was not timely (Section 3).

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Ooerator Trainina

• The licensee maintained an effective operator / technician training program (Section 4).

Maintenance and Surveillance Testina

• Maintenance and surveillance activities were thorough and timely (Section 5).

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I Report Details Summa.ty of Plant Status 1 Current activities with special nuclear material (SNM) consisted of 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.

Other ongoing site activities involved the use of radioactive materials licensed by the State i of Califomia Gome of these activities consisted of fabricating Co-60 sources, processing )

of Xe-133 for medical use, and ext c ation of irradiated reactor hardware.

1 Management Controls and Organization j 1.1 Personnel Chanaes 4

a. trLsoection Scope (88005)

The inspector reviewed and discussed recent personnel changes with licensee I personnel. i

b. Observations and Findinas Personnel changes involved the replacement of: (1) the regulatory compliance (RC, manager who retired on July 1,1996, with a senior engineer from within the RC group; (2) the senior licensing engineer who retired September 1,1996, with the nuclear safety engineer (NSE); and (3) the radiation monitoring specialist who retired on March 1,1997, with a senior radiation monitor. The NSE's position was posted for filling, and the vacancy in the monitoring staff had been filled with a technician from the hot cell facility who transferred as a traines into the radiation monitoring j component. In addition to the personnel changes, the licensee was anticipating some onsite organizational changes, but the details of these changes had not been 1 finalized at the time of the inspection.

Relative to these changes, the criticality safety and radiological engineering j functions of the NSE were to be retained under his new position as lit dng engineer. The site training function of the previous licensing engineer % '. been assigried to the new radiation monitoring specialist who also was to at iire the role of emergency planning. l The inspector verified that the personnel in the new positions met the qualifications specified in Section 4.3.2, Appendix A (License Conditions), of the license i application. The inspector also noted that the licensee was preparing an update for ]

Section 2, " Organization and Administration," Appendix B (Demonstration Volume) of the license application that will be submitted to NRC. The inspector did not l

identify any concerns relative to the personnel changes.

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c. Conclusions The inspector concluded that the personnel changes in the licensee's organization {

had no adverse impact on the safety of licensed activities. '

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1.2 Safety Committens, Audits, and Procedures

a. Inspection Scoce Minutes of quarterly Vallecitos Technological Safety Council (VTSC) meetings, RC's annual review of its 1996 safety programs, and site management safety inspections l were reviewed. The inspector also reviewed the licensee's control of safety '

standards, nuclear safety procedures, and operating procedures,

b. Observations and Findinas The VTSC functions as an independent review body for onsite incidents, provides advise and counsel on criticality and radiation safety policy, and reviews major facility changes. Membership of the VTSC and quarterly VTSC meetings were consistent with Section 4.4, Appendix A of the license.

The RCs' annual review of 1996 activities (report dated March 24,1997) included site radiation exposures, radiation monitoring activities, external audits, site training program, criticality safety activities, ernergency preparedness and response program, radiological engineering activities, licensing activities, environmental protection program, facilities protection component activities, SNM accountability, and site security activities. This annual review was consistent with the requirements of the license and licensee procedures.

The licensee conducts site management safety inspections to implement its industrial safety requirements and review housekeeping practices. The inspector l noted that an annual safety inspection of the Building 103 area was performed on l June 25,1996, and the report was issued to Building 103 management on July 26, 1996. Although no serious safety or compliance items were identified, there were a  ;

number of minor housekeeping and/or good safety practice findings that required corrective action and response to the audit within 30 days. As of the date of the NRC inspection, Building 103 management had not responded to the audit findings.

The inspector also noted that an annual managenient safety inspection had been conducted of the Building 102 area in September 1996, and no report had been issued at the time of the NRC inspection. The inspector discussed the lack of timeliness in responding to safety audit findings and timely issuance of safety inspection reports with licensee management. The licensee acknowledged the inspector's observation.

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The inspector noted that changes to and periodic reviews of licensee safety standards, nuclear safety procedures, and applicable operating procedures were i accomplished in accordance with the requirements of the license. I

c. Conclusions The licensee was adequately reviewing its safety programs. The lack of timeliness in responding to internal inspection findings and issuance of safety inspection reports indicated a need for ilaprovement in the implementation of the site management safety inspection program.

2 Operations Review 2.1 Criticality Safety Proaram and insoections

a. Insoection Scone (88015 and 88020) 1 The inspector reviewed the status of the licensee's criticality safety program and inspections conducted by the criticality safety specialist, and audits conducted by l the radiation monitoring staff for the past year. I

b. Observations and Findinas The inspector noted that there had been no changes in operations that required a new criticality safety analysis during the past year. Since site activities do not l involve liquid processing systems or the handling of large quantities of enriched uranium, criticality safety continues to be based on safe batch limits.

Licensee inspections and audits were consistent with current activities and the requirements of Section 5.7, " Criticality Safety inspections," Appendix A, of the license and licensee procedures. No safety problems were identified by the licensee's inspections and audits.

c. Conclusions The licensee's criticality safety audits were consistent with the requirements of the license and licensee procedures.

2.2 Conduct of Ooerations

a. Inspection Scone 88020 The inspector toured and discussed current operations in the Building 102 hot cell facility and the Building 103 metallurgy / chemistry laboratories. The inspector also reviewed selected SNM inventories of criticality limit areas in Building 102 and Building 103.

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b. Observations and Findinas~ >

. For Building 103, the licensee's SNM inventory was being maintained below the i suberitical area value that exempts them from having to maintain a criticality i monitoring system (CMS). A major portion of the SNM inventory in Buildhg 103 consisted of non-irradiated low enriched fuel samples and fuel pellets stored in  ;

various laboratories and the Suilding 103 fuel storage vault. There were no current ,

projects involving the use of SNM. SNM containers in the vault were properly I labeled and the door to each storage cubicle was latched to reduce the potential for unsafe movement of SNM in the event of an earthquake.  !

l In Building 102, the licensee's inventory records indicated there was less than a safe batch of SNM (U-235)in each of the hot cells where irradiated fuel was being examined or stored. Criticality limit areas within the hot cells were adequately defined, criticality controls were adequately incorporated in the hot cell operating procedures, and the operators were quite knowledgeable of the criticality controls  !

for their assigned work area.

During facility tours, the inspector noted that criticality control lirnits were  !

appropriately posted where SNM was maintained or authorized. >

c. Conclusions The licensee was effectively implementing its criticality safety program in accordance with the requirements of Appendix A of the license and licensee procedures.

2.3 CMS and Source Checks

a. insoection Scooe (88015. 88020. and 88025) -

The inspector reviewed and discussed the details of Change Authorization (CA)

No. 96-07, " Install New Criticality Monitoring System," dated May 21,1996, approved August 8,1996. The inspector also observed the monthly source and functional chack of the CMSs. Records of monthly CMS function tests conducted during the past year were also reviewed.

b. Observations and Findinas Currently, the only areas where a CMS is required is at the waste storage facility and the Building 102 main corridor area. The CA was for the replacement of the existing lithium-iodide neutron' detection system with a new gamma detection system. The licensee's pre-1974 system is also sensitive to gamma radiation which results in occasional false alarms with changes in gamma background radiation levels from movement of byproduct material. Also, the current system has been difficult to maintain due to the lack of available spare parts.

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I Currently, the licensee is authorized an exemption from the prescribed alarm set points of 10 CFR 70.24(a)(1). The new gamma detection system planned for installation is designed to meet the requirements of 10 CFR 70.24(a)(1), therefore the exemption will not be required. The licensee's analysis for placement of the new detectors is based on the guidance in Appendix B, " Calculations of Detector Radius of Coverage Versus Alarm Trip Point," to the draft revision to ANSI N 16.2-1976, " Criticality Accident Monitoring System." From independent calculations, the inspector did not identify any discrepancies or concerns relative to j the licensee's analysis. The licensee had purchased the new system that was undergoing inspection and testing in the instrument repair and calibration facility.

Regarding the monthly source check and functional test of the CMS, the inspector  !

observed that pre-announcements were made and adequate controls were used to (

ensure that no SNM transfers were made during the testing. Adequate radiological controls were used when using the Am-241 neutron source for checking response of the CMS detectors. The source checks included verification of each detector's response, the effectiveness of the audible alarm system, and verification that the l I

Building 1028 main alarm indicating panel was operational.

c. Conclusions  ;

The licensee was adequately maintaining its CMS. The planned replacement of the l existing CMS will be an improvement over the existing system.

1 3 Non Reportable Operational Eunts

a. Insoection Scone (88002)

The inspector reviewed licensee procedures and selected incident investigations that l occurred during the past year. Specific procedures and events reviewed were: l l

• VNC Safety Standard No. 3.0, " Reports to Regulatory Agencies."

• VNC Safety Standard, No. 31, " Investigation of incidents."

• Nuclear Safety Procedure No.10400, " Reporting of Unusual b Circumstances." i N l

• Nuclear Safety Procedure No.10500, " Incident Investigation Review and Recommendation Follow-up."

• Incident Investigation No. 96-4 (Category 1, Type ll), " Block Drop on Foot,"

dated October 25,1996.

• Response to Investigation No. 96-4, " Block Drop on Foot," dated October, 1996.

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• Report, " investigation of Shattered Vacuum Gage in Building 103, Lab 116,"

dated September 26,1996.

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b. Observations and Findings l The licensee's procedures adequately provided the means for identification, review, and reporting of operational events.

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Incident Investigation No. 96-4 involved a minor personnel injury that occurred ,

when a steel door (approximately 1150 pounds) to the hardness testing blister on j the side of Cell No. 5 (metallography cell) was dropped when being re-installed.

After maintenance to the hardness tester, the door was being re-installed using a L small electric fork truck and slings attached to the top of the door. When a technician moved the sling attached to the door to the hook of the lifting bar on the  ;

fork truck, the force applied to the sling caused the door to fall over and pin the technician's foot under the door. Fortunately, the configuration of lifting hardware .

for the door (permanently welded) prevented the technician's foot from being

seriously damaged. A subsequent offsite medical examination only identified skin scrapes and bruised tissue. Root cause for the event was appropriately identified j and corrective actions appeared adequate to prevent recurrence.

Regarding the shattered vacuum gage (glass ionization tube) incident, this event occurred when a portion of a vacuum annealing system was pressurized on

September 4,1996. A laboratory technician had loaded non-irradiated low enriched

{ fuel pellets into the vacuum annealing furnace for drying before performing  ;

corrosion studies. The annealing furnace is located inside a fume hood and the  :

! vacuum and the remaining system equipment is located just outside the hood. The  !

3 technician inadvertently turned on the diffusion vacuum pump instead of the annealing furnace and left the room to perform work at another building. Since the diffusion pump was not intended to be used, its cooling water had been valved out,

which resulted in overheating and pressurization of the system. The pressurization caused the vacuum gage to be ejected from its twist tight locking port onto the i floor where it shattered and made an explosion type noise that was heard by j personnel outside the lab.

The subject laboratory is a normally clean lab. Since only sintered fuel pellets are j involved in the studies, the vacuum annealing system is a relatively clean system.

i Subsequent surveys of the laboratory by the involved technician did not identify any radioactive contamination outside of the fume hood. A routine survey performed in  ;

the laboratory by a radiation monitoring technician (unaware of the incident), shortly  !

after the event, did not identify any loose radioactive materials in the lab. Although the incident did not result in any release of radioactive material, no personnel injury occurred, there was no impact on criticality safety, and the incident did not require

reporting to the NRC, the inspector noted that the licensee's internal dissemination l of the matter a, L wared untimely

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• VNC Safety Standard No. 3.0 cutlines the licensee's policy for internal reporting of incidents and occurrences that may be subsequently reportable to regulatory agencies. The procedure calls for prompt notification of RC and j that the area manager is to assure that RC is notified. However, RC was not

notified until October 199S following issuance of the investigation report.

c. Conclusions The licensee's procedures adequately provided the means for identification, review, and reporting of operational events. However, the event involving the shattered vacuum gage was not timely reported to the RC component. <

< 4 Operator Training and Qualification

a. Insoection Scope (88010)

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The inspector interviewed operators during facility tours and reviewed records of training classes and training tests for the past year. '

b. Observations and Findinas The inspector noted that there had been no changes in the licensee's training program during the past year. The inspector noted that new employees received

! training that included the fundamentals of radiation protection, criticality safety, 4 hazardous chemical safety, fire protection, emergency requirements, and security.

Refresher training on fundamentals of criticality and radiation safety was provided annually. In addition to training and qualification on operating procedures, the Building 102 remote handling operations manager continues to sche' ale formal monthly safety / training meetings for all site personnel that cov ; various aspects of radiological safety, criticality safety, non-radioactive hazardous materials safety, radioactive waste and transportation requirements, emergency response, and industrial safety. Following each training class and formal safety meeting, employees are tested on the subject matter covered.

Operators / technicians were adequately knowledgeable of the criticality safety, radiation safety, and SNM accounting controls as applicable to their assigned task.

c. Conclusions i

The licensee's training program was consistent with the requirements of Appendix A of the license and licensee procedures. Operators appeared knowledgeable and adequately qualified to perform their assigned tasks. Overall, the trair.ing program appeared effective.

i 5 Maintenance and Surveillance Testing

a. insoection Scope (88025)

The inspector toured the licensee's facilities to observe the status of safety equipment and reviewed the records for the past year of: (1) monthly fire protection system inspections and alarm tests, (2) daily Building 102 operations safety checks, (3) semiannual electricalinterlock tests of the Building 2 hot cell doors, and (4) annual calibration of hot cell differential pressure photchelic gauges.

The inspector also reviewed CA No. 96-08, " Replace Building 103 Final Filter System," dated June 20,1996.

b. Observations and Findinas

. The inspector found that calibrations and surveillance tests were performed in accordance with the requirements delineated in Appendix A of the license and/or licensee procedures. No safety concerns were identified as a result of the review. ,

1 During facility tours; the inspector noted that air sampling devices, ventilation  !

system magnahelic and hot cell photohelic gauges, and area radiation monitoring equipment appeared fully operational. Fire extinguishers and other fire safety i equipment appeared operational and in good condition. Housekeeping was l generally good in the areas toured. The inspector did not observe any safety I equipment that was out of service or the appearance of needed maintenance, i

The replacement of the Building 103 final high-efficiency particulate air (HEPA) filtering system was scheduled to take place in approximately two weeks. The new HEPA filtering system that was being built offsite was the same design used for the Building 102 facility. The new system will consist of two bankc of 20 HEPA filters each with a design that allows testing and replacement of individual filters without impacting building operations. The current system has been in use since the )

1950's and has required considerable maintenance to maintain the license required efficiency rating. The inspector noted thet the CA adequately described the design criteria and safety analysis for replacement, l

c. Conclusions Maintenance and surveillance activities were generally thorough and timely, and identified problems were adequately corrected. The replacement of the Building 103 final HEPA filtering system will greatly enhance the reliability of this system to perform its intended safety function.

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Exit Meeting Summary -

The inspector presented the inspection results to members of the licensee management at

the conclusion of the inspection on April 3,1997. The licensee acknowledged the findings l presented.

4 E Although proprietary information was reviewed during this inspection, such information is

- not knowingly described in this report.

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g ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION

!' PARTIAL LIST OF PERSONS CONTACTED Licensee 1

F. Arlt, Manager, Facilities Maintenance C. Basset, Manager, Nuclear Safety C. Hill, Supervisor, Remote Handling Operations M. Rogers, Specialist, Radiation Monitoring

8. Murray, Nuclear Safety Engineer G. Stimmell, Manager, Vallecitos and Morris Operations J. Tenorio, Manager, Remote Handling Operations INSPECTION PROCEDURES USED 1

IP 83822: Radiation Safety IP 88002: Operational Event Review and Feedback Programs at Fuel Cycle Facilities IP 88005: Management Organization and Controls IP 88010: Operator Training / Retraining IP 88015: Criticality Safety IP 88020: Operations Review IP 88028: Maintenance / Surveillance Testing 1

i LIST OF ACRONYMS USED CA' Change Authorization '

CMS criticality monitoring system  ;

HEPA high-efficiency particulate air NSE nuclear safety engineer ,

RC Regulatory Compliance j SNM Special Nuclear Material i VTSC Vallecitos Technological Safety Council j i

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