ML20153E461

Insp Rept 70-0754/88-01 on 880322-30 & 0411.Violations Noted.Major Areas Inspected:Emergency Preparedness,Mgt Organization & Controls,Training & Retraining,Criticality Safety,Operations Review & Radiation Protection

ML20153E461
Person / Time
Site:	07000754
Issue date:	04/29/1988
From:	Brock B, Prendergast K, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20153E451	List: ML20153E448 ML20153E456 ML20153E461
References
70-0754-88-01, 70-754-88-1, NUDOCS 8805100018
Download: ML20153E461 (11)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-754/88-01 License No. SNM-960 Priority 0- Category V Safeguards Group V Licensee: General Electric Company Vallecitos Nuclear Center P. O. Box 460 Pleasanton, California 91304 Facility Name: Vallecitos Nuclear Center Inspection at: Pleasanton, California Inspection Conducted: March 22-30, and April 11, 1988 Inspectors: O MY B. L 8 rock, Fuel Facilities Inspector Date Signed Jk K. M. Prendergast, h NDP/Pf 6

ergency Fraparedness Da'te Slgned Approved by:

R. D. Thomas, Chief Y/

Dafte 9'igned Nuclear Materials Safety Section l Summary:

Areas Inspected: A routine unannounced safety inspection was conducted which included: management organization and controls; training and retraining; I

criticality safety; operations review; raaiation protection; emergency l preparedness; and environmental protection.

During this inspection, Inspection Procedures 83005, 88010, 88015, 88020, I

83822, 88050 and 88045 were covered.

Results: One violation was identified in one of the seven areas inspected (emergency preparedness). See Section 2.E.(3). for details.

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l DETAILS

1. Persons Contacted A. Licensee Employees:

• R. W. Darmitzei, Manager, Irradiation Processing

• J. H. Cherb, Manager, Nuclear Safety

• G. E. Cunningham, Senior Licensing Engineer.

• D. R. Smith, Manager, Nuclear Test Reactor ,

J. I. Tenorio, Manager, Remote Handling Operations C. P. Ruiz, Manager, Process and Radiation Chemistry J. E. Lewis, Specialist, Materials Characterization B. M. Murray, Radiological Engineer R. F. Begley, Supervisor, Remote-Handling E. J. Strain, Compliance Engineer ,

D. C. Bowden, Senior Engineer, Nuclear Safety i R. Quillin, Specialist, Supplemental Services G. Lundeen, Technologist  ;

F. A. Arlt, Supervisor, Maintenance and Carpentry J. Gregg, Specialist, Shops P. Hagberg, Security Administrative Assistant K. Michelini, Security Specialist i W. B. Johnson, Specialist R. Reager, Chemist i F. Matheny, Instrument Technician C. Delisle, Specialist, Facilities Protection  !

• Denotes those attending the exit-meeting B. Other Organizations:

(1) Valley Memorial Hospital E. J. Colona, Director, Engineering (2) California Division of' Forestry C. Parker, Battalion Chief, Sunol Station.

(3) Alameda County Office of Emergency Services 1

i i M. Hunt, County Emergency Coordinator

2. Functional or Program Areas Inspected A. Management Organization and Controls (88005)

(1) Organizational Structure I

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2 The licensee continues to maintain the independence of the criticality and radiation safety organization from the manufacturing of nuclear products or the processing of nuclear materials.

(2) Safety Committee The Manager Nuclear Safety compiled a detailed annual review of the site safety and compliance program activities.for 1987.

The detailed review addressed all ten functional areas in the Nuclear Safety Component as well as the two functional areas in both the Safeguards Component and the Quality Assurance Component. The information facilitated an assessment for trends. The licensee's operations in general reflected adequate control of operations. However, it was noted that some recommendations from drill critiques had not been responded to by all Area Managers particularly.where the responsibility for response was shared by all of them. This reflects on the need for additional upper management support for securing the responses. This report is scheduled to be reviewed by the Vallecitos Technological Safety Council to meet the license required review of operations.

9 (3) Internal Review and Audit The NRC inspector reviewed the records of the licensee's internal audit of operations. The records indicated the audits were completed as required. The radiation safety audit review indicated that the only problem identified was of a minor nature and was expeditiously and appropriately corrected. The inspector's review of the criticality safety audits indicated no problems had been identified.

The licensee stated there were no nonroutine events or unusual occurrences since the previous inspection.

Performance in this program area appears to be adequate. No violations were identified.

8. Training and Retraining (88010)

The licensee is assuring that the recently recertified radiation monitor receives appropriate indoctrination from his supervisor.

The supervisor plans to retire in August (1988) and his additional indoctrination of the new monitor should reduce the consequence of the licensee's loss of the supervisor's experience.

Records of RCP training were examined including: training in first aid, radiation monitoring, respiratory protection, and fire and damage control. Based upon this examination, required training appeared to have been accomplished. However, since the licensee does not have an implementing procedure for training, it is suggested they incorporate the current training matrix they have developed into the RCP implementing procedures. This will provide further

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guidance on the frequency and type of training required for

. emergency response.

Performance in this program area appears to be adequate. No

~ violations were identified.

C. Criticality Safety (88015)

(1) Nuclear Criticality Safety Analyses L The licensee's operations have been essentially unchanged since i

l the last inspection. As a result, new criticality safety analyses for operations involving special nuclear materials have not been required.

(2) Audits The NRC inspector's review disclosed no criticality. safety limit violations. The licensee's criticality safety inspections were conducted as required and were of adequate scope and depth. The reports of the Radiological Engineer who functions as the Criticality Safety Analyst indicated there were no violations of criticality safety limits identified during the conduct of the inspections.

(3) Criticality Calibration and Monitorina System The licensee's criticality alarm system is tested monthly.

Alarm system failures are indicated in the Central Alarm i Station (CAS) both audibly and visually. Each alarm module is equipped with a lock which can be used to bypass the klaxon 6 when a large source is scheduled to pass near the detector.

The lock design prevents removal of the key while the klaxon is deactivated. Spare alarm modules are available to replace ,

units that are scheduled for calibration or that experience a failure. Loss of AC power switches the system to battery power.

Performance in this program area cppears to be adequate. No violations were identified.

D. Operations Review (88020)

(1) Conduct of Operations (a) Radioactive Materials Laboratory (RML)

Operations in Cell 1 and Cell 2 were unchanged.

The retained fission gas operation in Cell 3 was being serviced. The planned cleanup of the glovebox in Cell 4 had not yet been undertaken. Several currently unused plutonium contaminated glove-boxes are still onsite and are being maintained. The licensee has continued to seek an avenue by which the glove boxes could be properly

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packaged and shipped for disposal. The situation of gloveboxes being subjected to long term storage needs to ,

be resolved by the licensee.

The shredder has been installed and the ventilation system has been modified to accommodate it. Ins *.allation of the magnehelic gauges is still to be accomplished. The ,

shredder is expected-to significantly reduce the volume of l low level waste. '

The licensee has completed installation of the roof over ,

the hot dock, the rollup door at the back of the hot dock, '

and the stainless steel flooring on the hot dock. The  ;

wall planned to separate the cold dock from the hot dock '

is expected to be installed soon. Stainless steel flooring is planned for instal.lat'an in the access area of )

the corridor where the tile has been removed because of the damage it sustained from operations with the hLavier forklift carrying the Peavy casks.

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(b) Waste Evaporator Plant j

The planned relocation of the self monitoring station at the Waste Evaporator Plant has not yet been implemented.

The transfer tank that brings the liquid radioactive waste to the waste evaporator apparently is accumulating a j residue that should be removed before it contributes 1 significantly to the exposure received by the tank handlers. The extent of this accumulation of rr ioactive l 1

waste residue in the transfer tank will remain L. an open l

item (88-01-01).

The NRC inspector also surveyed the perimeter fence at Building 304 where the drums of solidified waste from the l Waste Evaporation Plant are accumulated pending shipment.

No radiation levels above regulatory limits were detected.

l (c) Hillside Storage Several containers of radioactive waste prepared for shipment to a radioactive waste disposal site were as *mbled in a roped off area awaiting pickup. One side of '.te area was not roped off but was under administrative control.

A survey of the fenced perimeter by the NRC inspector found to radiation levels in excess of the regulatory limits.

(d) Decontamination and Decommissioning (D/D)

(i) Building 400 I The final report from the Oak Ridge Associated j Universities (0RAU) has been received and supports '

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the. licensee's fin' dings with regard to the adequacy i of the cleanup of the building. It appears.that the building has been cleaned to within the NRC limits for release of the building to unrestricted use. ,

Region V will make a recommendation to HQ: NMSS to amend the license to release Building 400 for unrestricted use.

Note: Attachment A, "Confirmatory Radiological Survey Building 400" is included with this report.

l (2) Housekeeping

Housekeeping improvements were needed in some areas around the site.

(a) Housekeeping at t ie stepoff pads in a laboratory in Building 103 reflected a need for closer attention by the '

laboratory users and/or the monitor. Several of the i yellow plastic shoe covers were strewn about near the '

stepoff pad even though a container for their disposal was provided nearby.

(3)' Hazardous Materials Control The NRC inspector reviewed the storage of flammable liquids ,

with regard to the existence of berms beneath the storage tanks. The question of t'ne existance of the berms was raised ,

by the Battalion Chief of the Sunol Station of the California Division of Forestry (CDF). It appeared that the flammable liquid storage tanks were adequately bermed. The tanks not bermed were horizontal 55 gallon drums of combustible i lubricants. These drums were mounted on stands to facilitate dispensing their contents. One of the drums needed a catch pan for drippings. ,

i The NRC inspector also visited the chemical storage area with the site Fire Marshall. The inspector noted containers of acid stored on the same pallet as a container of base. The Fire Marshall immediate'. separated the containers and connented that training had been provided to avoid such storage l conditions. This incident indicates a need for licensee management followup to ascure that storage procedures are being followed. The licensee's performance will be reviewed in a subsequent inspection (88-01-02). The Fire Marshall agreed to 1 ask the Specialist, Materials Characterization who functions also as the Hazardous Materials Custodian for Building 103, to examine the chemical storage area for incompatible chemical storage.

The inspector also noted that gas bottles were observed to be anchored as required in the many areas in which they were stored or used.

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'. 6 Performance in this program area appears to be adequate. No violations were identified.

E. Emergency Preparedness (88050)

(1) Offsite Support Agencies t

. Discussions with offsite support agencies verified the licensee has established an interface with and has formal agreements with appropriate state, local and federal agencies, regarding emergency response. Numerous agreements with offsite support agencies, along with documentation of their current validity were observed. In addition,.the Alameda County Office of Emergency Services, which is the responsible agency for protecting the public in the area around the site, was also contacted as part of this inspection. Discussions with the County Emergency Coordinator indicated the county was aware of their agreement with VNC. However, they did not have a copy of the RCP. As a method of improving the coordination of any response to an emergency, it is recommended the county be included in the distribution of the RCP. '

(2) Emeraency Plans The RCP was examined along with recent changes to the approved plan. The examination concluded the changes had been approved by management and did not appear to decrease the. effectiveness of the RCP. In addition, the licensee's Emergency Call List was also examined and noted to be current with recent changes to

, the emergency organization.

(3) Facilities and Equipment I

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This inspection included a visitation of all site facilities, an examination of inventory and maintenance records, and an inspection of the emergency lockers in Buildings 1028 and the i GETR, the licensee's mobile equipment platform (fire truck),

I and the standby emergency diesel generator .

l (a) The examination of the emergency lockers and records of their inventories indicated the inventories were timely and well documented. 'The emergency instrumentation was observed to be operable and in calibration. Records of i emergency diesel maintenance also appeared timely and the I diesel started readily when operated. The site fire engine l appeared well maintained and started readily when tested.

However, as a recommendation to insure its maintenance and 1 availability during an emergenc3, it is suggested that the i maintenance and the technical inspections of the vehicle be proceduralited to insure they are completed. In addition, since a fire engine is no better than the operating crew, it is suggested that the responsibilities of the individuals who operate the engine, pumps and hoses

, be examined to insure appropriate training is i

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, 7 accomplished. Emergency respirators were also examined during this portion of the inspection and the following problems were identified:

(1) The RCP requires respirator maintenance to be accomplished in accordance with the Nuclear Safety Manual Volume I, Respiratory Protection. Respiratory protection is also addressed in the Site Emergency Procedures, Volume III. The inspection showed that the SCBA cylinders, located in Building 1028, were not fully charged and that two of_the cylinders only contained 1500 and 1750 lbs, of compressed air. The two tanks were also not tagged to indicate they were operable and had been recently inspected. In addition, it was also noted that the two tanks had not been hydrostatically pressure tested as required by the Respiratory Protection Manual. Records examined showed the tanks had not been tested since 1980, well outside of the 5 year time frame. Since the failure to adequately maintain the tanks could result in injury to personnel, the licensee should examine this area to assure respiratory standards are maintained. The failure to hydrostatically test emergency use SCBA cylinders was identified as a violation and will be followed as open item (88-01-03).

(ii) Nuclear Safety Procedure, Number 8400, Revision 3 '

Emergency Locker Inspection and Maintenance, had not l been maintained current with changes in the location '

of emergency equipment. Neutron monitoring equipment referred to as being available in the 102 change room and 104 shipping and receiving area was no longer stored at those locations. The licensee should review their emergency procedures to see they are maintained with changes in their emergency equipment.

l (b) Seventy-five fire extinguishers were examined by the NRC inspector and were noted to have been inspected monthly by the licensee, as required.

1 (4) Tests and Drills Records of tests and drills were examined and they were performed as required by the RCP. Written critiques were also available to show that management was apprised of items j requiring improvement and that corrective actions were taken.

! However, there are numerous areas that did not appear to have been exercised. No drill records were observed to demonstrate i the following: accident classification; emergency notification to offsite agencies; decontamination; first aid treatment of a l contaminated worker; and participation in a fire drill by offsite fire agencies. It is recommended that drills exercising the above areas be given preference when

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• [ I '.' ~8 establishing the scope and objectives foe future drills (88-01-04).

(5) M3 dical The licensee visit to Valley Memorial Hospital /VMH) just after the last NRC inspection represents a significant improvement-in communications between the licensee and VMH. However, at that time the licensee did not arrange for VMH to participate in one of the licensee's drills. Item (87-01-04) was therefore left open. The NRC inspectors visited the VMH during this inspection and found they were still interested in participating in an exercise with the licensee.

Performance in this program area needs further improvement. One violation was identified in Section E.(3)(a).

F. Radiation Protection (83822)

(1) Radiation Surveys (a) Radiation surveys were performed by the inspectors at numerous locations around the site. The survey instruments used included a Keithley survey meter, model number 361000, calibrated 3/10/88, and an Eberline E-520 survey meter, and GM probe, calibrated 1/6/88. Specific facilities where surveys were performed included: the Cobalt Irradiation Facility, Hillside Storage and its perimeter fence, the Waste Evaporator, the perimeter fence near the cooling towers, and Buildings 102 and 104. The surveys demonstrated radiation levels were within NRC regulatory limits and posting appeared appropriate.

(2) Non-reportable Incident Review The licensee stated.that there were no no esutine events or unusual occurrences since the previous inspection.

Performance in this program area appears to be adequate. No violations were identified.

G. Environmental Protection (88045)

(1) The licensee continues to follow their. environmental sampling program. Operations in the Radioactive Materials Laboratory continue to be the principal source of airborne radionuclides from NRC licensed operations. It was noted that the licensen's airborne releases continued a downward trend. The airb'rne releases during 1987 averaged only about 50 percent of those for 1983 which were found to be less than NRC release limits in the 'iafety Evaluation Report that was undertaken as part of the license renewal process. Releases for 1987 also averaged less than NRC 10 CFR Part 20 limits for releases to unrestricted areas.

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:: t ,* . 9 (2) The vegetation samples for 1987 yielded results. indicating l gross beta gamma values at about the same (20 pCi/g) level as the 1983 values. K-40 was also reported at.the 20.pCi/g level, 3

up'a, factor of four from the 1983 results (excluding.the ona 4 1983 K-40-result which was low by a factor of fifteen from the results since 1982). . Gross alpha values _were up about 60 percent to the 0.05 pCi/g level, a

(3) Radioactive liquid wastes are not released from the licensee's site. These wastes are sent to-the Waste Evaporation Plant

'where they are evaporated. The resultant. sludge is solidified and packaged in plastic-lined DOT Specification 17-H 55 gallon urums. The drums are stored until sufficient numbers' warrant shipment-to a-licensed radioactive waste disposal site, i

The licensee's performance in this program area appears to be 4

adequate. No violations were identified.

H. Exit Meetina (30703)

The results of the inspection were discussed with the members of the licensee's staff identified-in Section 1.

i The topics included: -

The areas-inspected.  ;

1 Planned disposal of the Cooling Towers. l I

The radiation monitor staff changes.

, Maintenance and minimization of long term storage of plutonium j contaminated gloveboxes.

Closer monitoring of waste handling from the Electron Discharge Machine.

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Labeling inaccuracy on the Cf-252 cask.

Concerns expressed by the CDF Battalion Chief.

Modifications to the RML (roof, rollup door and.SS flooring)

Surveys at the NTR.

i SCBA maintenance (hydrostatic ~testin'g) and storage locations, j Neutron instrument location vs designated storage tocations.

1 Drills and Exercises (frequency and scope of needed improvements).

Formal training procedure needed for the RCP.

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l The status of'the open items was reviewed. 2 One item (87-01 03) was 1 closed (C0F firefighter site familiarization) and two remained open. '

Of the two items remaining open, one (87-01-04) related to licensee l

'and hospital interfacing, and the other (87-03-01) related to a l survey for contaminated machinery (the survey was completed and the '

report is being finished). Five new open items were identified. .)

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