ML20138B364

Insp Rept 70-0754/85-02 on 850904-19.No Violations Noted. Major Areas Inspected:Mgt Organization & Controls,Operator Training & Retraining,Criticality Safety & Operations Review

ML20138B364
Person / Time
Site:	07000754
Issue date:	10/02/1985
From:	Brock B, Thomas R, Zurakowski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20138B358	List: ML20138B353 ML20138B364
References
70-0754-85-02, 70-754-85-2, NUDOCS 8510150345
Download: ML20138B364 (7)

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• ' U S. NUCLEAR REGULATOR" COMMISSION REGION V Report No. 70-754/85-02 Docket No.70-754 License No. ShH-960.

Safeguards Group:

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1 Licensee: General Electric Companyi 9 Vallecitos Nuclear Center ~ ...

P. O. Box 460 s 4 Pleasanton, California 94566 ,

Facility Name: Vallecitos-Nuclea'rCeNter s f

Inspection at: PleasantonICal'ifornin' +

Inspection conducted: ' November 4-6, 10, 18'and 19, 1985 Inspectors: * /# I B. L. Brock, Fuel Facilities Inspector Date Signed

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P. R. Zur kowski, Radiation Specialist tob/gr Date Signed Approved By: . , /d O~

R. D. Thomas, Chief.

Date ' Signed, Nuclear Materials' Safety Section Sununary:

Inspection on November 4-6, 10, 18 and 19, 1985 (Report No. 70-754/85-02)

Areas Inspected: A routine unannounced inspection was conducted of management organization and controls, operator training and retrainiuSr criticality q.

safety, operations review, radiation protection, emergency preparedness, and environmental protection.

The inspection involved a total'of 30 man-hours onsite by two NRC

. inspectors. During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 83822, 88050, and.88045'were covered.

Results: No violations were identified in-the seven subject. areas' inspected.

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rk DETAILS ' ***

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--g ; 4 1.. Persons Contacted.

9*W. H. King, Manager, Nuclear' Safety and Quality Assurance t*GGE. Csaningham, Senior' Licensing Engineer. ~ l

-J. I. Tenorio,, Manager, Remote Handling Operations W. Rf Lloyd;;SeniorcEngineer, Nuclear Safety .

v , F. . A. k Arlt,, Supervisor, Maintenance 'and Carpentry Shop

R. E.)GuesthSpecialist',' Facilities Protection

, E.iJ. Strain,1 Compliance Engineer , .. ,

, C.iDelisle/ Radiation Monitor Technician

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~R. Bagley,~ C;-cialistf Facilities Protection n D. C. < Bowden, . Seniog ".dpineer, Ndelearl Safety T.'.BJ.Garcia,' Radiation Monitor Technician

'R.' Butleitp Manager,. Radioactive Products and Services B: Streitz,3 Coordinator'.' Shipping and Accountability G Reser[ Process Instrument Technician

. E._ Rodriguez, Technician- "

^W. Caldison, Technicia'i

'2.. ! Management Ocaanization and Controls Thei licensee is . authorized;to use Special Nuclear Material (SNM) under License SNMJ960 in'accordar.ce with representations'and conditions contained in Appendix- A, License Conditions for the Vallecitos Nuclear Center," of the' licensee's submittal. dated April.20, 1984, except.as modified by the 'onditions c of this. License. .

,A. Organizational Structure Section 4 of- Append'i x A' of License SNM-960 requires that- the

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functions of the criticality safety. component and the radiation safety component shall exclude direct. responsibility for. operations involving the manufacture of; nuclear. products or processing nuclear-

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TM licensee's organizational. structure maintains this separation.of

< responsibility and its inherent checks' and. balances.

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B.- LSafety' Committee .1 i; .

7Section 4.4'of'the' license' conditions states that the functions ~of-l.

o - the ,Vallecitos Technological Safety Council (VTSC) shall include '

i. cresponsibility for review of reportable incidents,=new facilities'or

'ma'jor changes:to" facilities,~and for. contributing professional' advice.and counsel on criticalityfand' radiation' safety policy. The-

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VTSC shall review annually the site safety.'and; compliance program <

performance.to include'. effluent. releases'and occupational exposures l :s in: terms'of.ALARA and-focus o'n trends for corrective action if

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The. minutes oflthe VTSC were reviewed by the NRC inspector. The minutes addressed the terminatiori of the site- fire brigade and the

_ provision of additional training for building emergency team R -

. members,

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p s No;VTSC meeting was held in the second quarter of 1985. A statement indicating a review of~ activities and events of inte nst to the VTSC resulted in no meeting being scheduled was signed by the manager of nuclear safety and quality assurance who serves as secretary of the VTSC. <

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- The inspector's review of thie licensee's incident investigations indicated'the licensee's response appeared appropriate. However, the 'need for in-depth reviews was supported by another nonreportable incident involving onsite. contamination, with State licensed i materials,'outside of a restricted area. The review concluded the

. licensee's radiation safety and training programs are adequate; however, the' radiation safety program appears.to be.at the minimum staffing'. level (see Section 6, Radiation Protection, for details).

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No, violations were identified.

3. operator Training and Retraining Section' 5.8' of Appendix A requires Area knagers assure that new employees receive instruction in criticality safety, plant operating and emergency procedures prior to working with special nuclear. materials, sThe criticality safety training may be conducted with the radiation safety training. - A written test.shall be completed, evaluated and the results forwarded-to the appropriate area manager.

The'inspectar found that appropriate training required by 10 CFR 19.12 is e

given to all new employees, visitors and contractors before they are.

allowed ~to. work in a radiation area. The appropriate requalification training and t.edical examinations!are given to. persons on a yearly basis who use SCSh in their work or for emergency purposes.. Use;oflother respiratory protective devices also require. training and a-medical examination prior to.use.

The advanced course in radiation and criticality safety required of

" radiation workers" has not been given in .over one year. Progress in this area will b'e reviewed durf ng the next inspection (85-02-01).

4. Criticality Safety ' j ~

'- ' Sections;5.0 and 6.0 of Appendix A to License SNM-960 require. assurance

.of criticality safety;through both administrative, technical and' ianalytical requirements. Y '

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< Section 5.5' of ' Appendix A;re' quires .that the. manager of the .

i criticality ^, safety? component <shall; assure that the analyses.in which-r-QM,ew' =y h,

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-,.. t g an error in an analysis could lead to conditions that do not fulfill

..the double contingency policy ~are identified and reviewed. .

One criticality analysis was made since the last inspection. The 4

analysis developed criticality limits and criticality control requirements for Cells (3 'and 4 of the Radioactive Materials:

. Laboratory 1(RML). . Additionally, an= amendment. reducing ~the boundary in a portion:of. a figure of. a storage"areatin :the . Building 104

, Warehouse was'made.;;The analysis was reissued in total to assure I all copies contained the" revised figure.

~'B. Audits s Section.5.7 of. Appendix., A requires that. th'e radiation safety- '

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c_omponent' and the criticality safecy. component ~cenduct inspections respective to compliance'with criticality control procedures and verification that. operations l conform to the. physical situations -on

. =which the'. calculations of criticality limits were based. Operations routinely processing-more than one safe batch of. fissionable .

material shall,be inspected on a quarterly basis'. All operations shall be inspected on an annual basis.

Thhlicenseehadconductediinspections'morefrequentlythan required, and maintained adequate inspection records. _The.

contamination control practices folloved the upgraded. procedures land'

.no' repetition of-increased contamination. levels without' appropriate-response has occurred. This closes item 84-02-03. '

C. Facility Changes and Modifications s

(1) The-Solid Radioactive. Waste Storage Yard modification involving-expanding surface level storage has been completed. -

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(2) The housekeeping in'the xperimental' Low: Enriched, Uranium Scrap <

Recovery' area was significantly,impro'ed. v The' change observed E warrants closing item 84-02-04.- ~ M-No violations were identified. '

5 '. _ Operations Review

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e .Section 2.2 of the" license' application states;that the licensee'fs policy.-

~ . .g .is'to-protect the' employees, the'public, and the environs from potential ^

' industrial, radiation,'and nuclear hazards that:could occur through; activitie.s conducted in each component's: facilities. Responsibility,for-3-

1 , implementing lthis basic policy has' been delegated through line managers '

,tolthewanager'andsupervisir.of'each[activityInwhichradioactive-

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materials.are' handled, used, & ' stored.

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The ' NRC7 inspector observed operations "in ' the ' Radioactive Materials t, Laborac~ory (RML);f 'N(poor health physics practices .were observed during '"

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• No violations were identified.

, 16. ' Radiation Protection -

Protection against radiation hazards associated with licensed activities-is. required by 10 CFR.Part 20.

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A. External Radiation Exposures J An: examination' by the inspectoi of Tthe 1985 Film (TLD)' badge results disclosed that most exposures 'were near the minimum level of

, detection with.a' few higher exposures received by persons working in the hot; cell area. The high' quarterly exposure of 1780 mrem in this

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. area was' examined,in detail. Jt was found that-the. employee's NRC-4

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and 5' foras'. werefappropriately. mai'n tained. The~second high

. ~ - quarterly > exposure of 800; mrem was also examined. These records

1. were also appropriately:maintiained. .

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. Bioassay.Results' '

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l An examination by'the inYpecho/ of- the 1985l urinalysis results for . 1 plutonium disclosed no positive.results. . Approximately twenty urinalyses of this type are performed per year. '

Approximately 30 urinalysis forl uranium per month are conducted. ~ An examination of these records by. the inspector for .1985 to date

' disclosed no significant exposures. -

C. PockhtDosimete)s1Calibratkon ,

, , An item noted in a 1984 licensee investigation report was-examined in detail by the inspector. This report disclosed that a: licensee

, worker received'an accumulated dose of12325'arem during the first

' quarter of 1984 f as measured by'his TLD badge, but only 960 = mrem as 4-

- measured by his' pocket dosimeter. . A second item' noted in a July 1

'1985 report disclosed a-similar incident'with-a pocket dosimeter!

film badge, combination. -Because.of a possible generic problem associated with the' issuance and/or= calibration of pocket dosimeters i

. discussions were held with licensee pers_onnel responsible for these' -

actions. It was found_that the lat pocketi dosimeter in' question is

,- still in use and has been-functioning:properlys ~After the incident

it was recalibrated and found to be within 10% of the calculated value.' ! Each calibration since that date has confirmed the 'above statement.';Similar'results were obtained with the.2nd dosimeter. *

! . Discussions with the licensee technician responsible for pocket

j. ' dosimeter calibration and an examination ofLthe-techniques and- -

equipment used'in these calibrations ~ disclose'd.no poor.or inaccurate .

,-techniques. . Discussions were also held with'~the Building 102; ,

technician responsible for issuing pocket dosimeters and. returning 1 them-for calibration. These discussions'and an examination of'the'. -

_ associated records- disclosed:that. pocket dosimeters have been"

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returned for. calibration in a timely manner. .There was'no, evidence.

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. indicating that damaged or-inaccurate' pock'et dosimeters have been

'finadvertantly returned to service.' No' generic' link associated with ii

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5 the issuance and calibration of pocket dosimeters and discrepancies

^with TLD readings was found by the inspector.

D. Retiling of Access Corridor to Hot Cells The health physics preparations and actual retiling operation in the access corridor adjacent to the hot cells was observed by the inspector. Discussions with health physics personnel and the retiling craftsman indicated that wipe and air sampling, use of protective clothing, radiation surveys and job related safety training were performed in accordance with the licensee's procedures, 10 CFR 20 and good health physics practice. It was noted that the health physics technician had made appropriate evaluations prior to, during and af ter the job was completed.

Surveys were made and records were maintained.

7. Emergency Preparedness Section 4.9 of the license application addresses the plans for a prompt response to various types of emergencies.

The. licensee fire brigade _has been terminated. The Building Emergency personnel are receiving training that has now been expanded to include the use of the 1.5"_ fire hoses to improve their fire control capability.

The licensee has. broadened the training program to include the use of two offsite sources. <This training is to be completed by the end of October 1985. This will be reviewed during the next inspection (85-02-02).

The licensee and the California Division of Forestry (CDF) in Sunol are cooperating in'an effort to keep the CDF abreast of the status of the licensee's site. The NRC inspectorivisited the CDF and discussed the status of their. familiarization visits to the licensee's site. The CDF provided p,hidance to the licensee for updating the pre-plans used for familiarizing thel CDF, fire; fighters with pertinent building specific information.' The,, licensee indicated the pre plan updating would be completed by the end of the year. This will be reviewed during the next inspection.(85-02-03).

, , 'v Duringithe'sitetour,theNRCinspe'ctornotedthatfireextinguisher inspections were current., 'I 1 Noviolationskereidentified.-

8. Environmental Protection The licensee has been authorized, pursuant to 10 CFR 20.106(b), to release radioactive materials in accordance with Section 8.11, " Airborne Effluent Control," of Appendix A of the application.

The licensee conducts an effluent monitoring and environmental surveillance program and issues semiannual effluentLmonitoring reports as required by 10 CFR 70.59(a)(1). An examination of these reports by the inspector indicates the licensee's releases are within regulatory limits.

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- - ~ The.NRC inspector collected five sediment samples from pond and stream bottoms and seven soil samples from various onsite locations. The twelve

saeples were sent"to the Radiological and Environmental Sciences

' Laboratory (RESL), a Department.of Energy facility, for independent

.  : analyses. The results of the analyses'will be included in the next t

,. inspection report.

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No violations were identified. +

.9.  : Exit' Meeting I

,lTheresults.ofthFinspectionwere:discussedwiththemembersofthe '

licensee's staf.f^ identified in Section 1, the topics included:

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theareasinsppeted ,3_

.t closure of three openlitems

'84 02-01-sia,ffl l'eiel foritraining and environmental monitoring A

84-02-03 controli ofc conta' min'ation levels in processing. areas

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184-02-04 housekeeping in-the Experimental Low Enriched Uranium Scrap Recovery area

• termination of'the fire brigade

• ' preparation of' pre plans for the CDF ,

samples taken for independent analysis

~* ENRC interest in participating lin sampling the pits prior to their filling (an operation not expected for several years)-

the results of the in-depth review of the training program and -the "

radiation. safety program j The licensee commented that new employees received required training  !

expeditiously 1but that a planned class ~of advanced: training for four persons was changed to an individual study approach. Passing the examination after self study is still required lfor the demonstration of -

competence and preparation for work with radioactive materials.-

The licensee ~ also emphasized that elimination of the radioactive materials'from many'of the buildings eliminated the? source term for those buildings'and.significantly reduced the potential consequences'from -

-operating with trained Building Emergency Personnel rather than a- trained fire brigade.D ,

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