ML20154G661

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Safety Insp Rept 70-0754/88-02 on 880801-05 & 25.No Violations Noted.Major Areas Inspected:Mgt Organization & Controls,Training & Retraining,Criticality Safety,Operations Reviews & Transportation of Radioactive Matls
ML20154G661
Person / Time
Site: 07000754
Issue date: 09/13/1988
From: Brock B, Prendergast K, Thomas R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154G654 List:
References
70-0754-88-02, 70-754-88-2, NUDOCS 8809210036
Download: ML20154G661 (12)


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U. S. NUCLEAR REGULATORY COMMISSION REGION V f

Report No. 70-754/88-02 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: August 1-5, and August 25, 1988 Inspectors: mod * / O B. L. Brock, Fuel Facilities Inspector Date Signed

. bh. fl e /~~ G)/1/h V K. M. Prende'rgast, Edergency Preparedness Date signed Analyst Approved by: O 6 9- e- -hs- 4-83-P%  :

R. D. Thomas,($hief Date Signed j Nuclear Materfals Safety Section Summary:

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Areas Inspected: A routine unannounced safety 1:,spection was conducted of  !

management organization and controls; training and retraining; criticality i safety, operations review; radioactive waste management; inspection of waste generator requirements; transportation of radioactive materials; radiation

During this inspection Inspection Procedures, 88005, 88010, 88015, 88020, 88025, 88035, 84850, 86740, 83822, 88050 and 88045 were covered.

l j Results: No violations were identified in the eleven areas inspected.

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8809210036 880913 PDR ADOCK 07000754 C PDC l

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DETAILS s-

1. Persons Contacted A.  : Licensee Employees:

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  • R. W.-Darmitzel, 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
8. M. Murray, Radiological Engineer R. F. Begley, Supervisor, Remote Handling E. J. Strain, Compliance Engineer W. Springsteen, Specialist l R. Gest, Specialist Facilities Protection c F. A. Arlt, Supervisor, Maintenance and Carpentry
R. Rimmer, Irradiation Technician P. Hagberg, Security Administrative Assistant W. B. Johnson, Specialist R. Krueger, Senior Engineer i L R Warner Engineer ,

J C. Delisle, Specialist, Facilities Protection S. S. Wisner, Senior Engineer N. R. Young, Technician

, D. Caviness Technician -

J. Keith, Corridor Leader j H. Williams, Meta 11ographic Technician i

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  • Denotes those attending the exit meeting .

B. Other Organizations l (1) California Division of Forestry l' '

C. Parker, Battalion Chief Sunol Station j 2. Functional or Program Areas Inspected' A. Management Organization and Controls (88005) t (1) Organizational Structure i

l The licensee continues to maintain the independence of the l

criticality and radiation safety components from the i manufacturing of nuclear products or the processing of nuclear

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(2) Safety Committee The licensee's Safety Committee activities were reviewed and were found appropriate.

(3) Internal Review and Audit .

l The NRC inspector's review of the licensee's internal reviews 4

and audits found them to be of adequate scope and depth. It was noted however, that the licensee is removing a transportation audit function (seo Section 2.G.(1)).

Performance in this program area warrants additional attention. No violations were identified.

I B. Training and Retraining (88010) 4 i (1) The radiation monitor supervisor had retired since the last

! inspection. A Specialist who is also a certified radiistion monitor had been additionally assigned some of the previous I supervisor's required oversight activities. Certification of the third monitor was also ccepleted.

r (2) Records of emergency response training were examined. The training records documented training in first aid, radiation

] monitoring, respiratory protection, fire and damage control,

and were considered adequate, j t

(3) A new procedure was also observed which contained the training ,

i requirements for the dif ferent members of the licensee's  !

emergency response teams to implement the actions required by the Radiological Contingency Plan (RCP).- EPI-3, Emergency l Response Training, Revision 0, was examined and considered to i be an improvement over the previous procedure. As a suggestion for further improvement the response to an accident involving hazardous materials should also be addressed in this procedure.

l. The licensee's performance in this program area appears to be adequate. No violations were identified, i C. Critic _ality Safety (88015) I (1) Nuclear Criticality Safety Analysis The licensee's operations have been essentially unchanged since l the last inspection, therefore, no new criticality safety I analyses were required. The loss of access to the Control Data i i Corporation (CDC) computer precludes the licensee's use of the l SCALE (Standardized Computer Analyses for Licensing Evaluation)

> tapes on the VAX system unless the effect of the different -

cross-section libraries used are thoroughly evaluated. The licensee elected not to undertake the evaluation currently I since operations were not changing.

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(2) Audits i The NRC inspector reviewed the licensee's criticality safety l audits and noted they were conducted as required and were.of I adequate scope and depth. The reports indicated there were no  !

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violations of criticality safety limits identified. During the course of the facility tour the inspector noted no poor  ;

radiation safety or criticality safety practices.  !

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

adequate. No violations were identified. l l

0. Operations Review (88020) l (1) Conduct of Operations 1 (a) Radioactive Materials Laboratory (RML) f The operations in the various cells were much the same as {

during the previous inspection. No poor health physics I practices were observed during the tour of this facility. l The planned cleanup of the alpha glovebox in Cell 4 has l not been started. l The shredder installation was completed by the addition of the magnehelic gauges just after the completion of the i onsite phase of the inspection. The shredder performance was being evaluated by processing non-radioactive waste.

The licensee provided close supervision throughout the testing stage of shredder operation. On August 25,1988, the inspector learned that the licensee had prepared a revision to the original shredder procedure (after the magnehelic gauges were installed), and had included the NRC identified needed specificity in the parameters governing the changing of the pre-filters, The revised procedure will be reviewed during the next inspection, open item (88-02-01).

The installation of a wall planned to separate the cold dock from the hot dock was completed. The stainless steel flooring planned for covering the exposed concrete in the access area of the corridor where the tile has been removed is being reevaluated.

It was noted during the tour of the basement of Building 102 that the supplemental supports for the ceiling were still in place. The licensee stated that the staff's evaluation indicated that the supports were not necessary.

l The evaluation showing there is no need for the 1 supplemental supports should be addressed as part of the

! safety evaluation report since the li:ensee is using a i larger forklift to handle the large casks. The NRC reviewer for this license plans to pursue the matter with l

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the licensee and the appropriate headquarters licensing staff.

(b) Waste Evaporator Plant

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

The transfer tank radioactive residue buildup mentioned in e the previous inspection report has been addressed by the ,

licensee (see Section 2.H. open item 88-01-01,~for details).

(c) Buildina 103

- , i Research and Development activities are continuing with appropriate radiation monitor support. No poor health physics practices were noted. It was observed, however, that the Specialist was providing the support for this building in the absence of the regular monitor (who was out on jury duty).

Plutonium contaminated alpha glove boxes onsite are still being maintained. The licensee has continued to seek an avenue by which the glove boxeo could be properly packaged and shipped for disposal.

The NRC inspector noted that there appenred to be a path for fines from polishing operations to get into the 'J' trap under the sink in a metallurgical sample preparation laboratory. The inspector suggested that the licensee include 'J' traps in the surveys to establish whether the unfiltered stream carries the fines through the trap and into the two 5,000 gallon holdup tanks. The inspectors will review the licensee's findings during the next inspection, open item (88-02-02).

(d) Hillside Storage The NRC inspectors toured the area and noted its orderliness. The area continuud to reflect improved housekeeping as the old wooden shipping containers are replaced with new metal containers. No poor radiation safety practices were noted.

(e) Nuclear Test Reactor (NTR)

The licensee reduced personnel exposures by significantly l

increasing the shielding of the control room of the NTR as

! well as the ceiling of the radiographic area. The additional shielding was recently installed, consequently, there are no records at present to demonstrate the percent i reduction in dose to the workers at the NTR. However, preliminary measurements and pocket dosimetry indicate a i.

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dose reduction which is near 50 percent. Additional shielding is planned (see Section 2.H.(1)(b).

(2) Housekeeping Housekeeping improvements continue to be made in various locations around the sito. General improvement was observed but some areas warrant further attention.

(3) Hazardous Materials Control The NRC inspectors also visited the chemical storage area with the site Fire Marshall. The inspectors again noted containers of acid stored on the same pallet as a container of base. The Fire Marshall immediately separated the containers and agreed that the retraining had not been effective. The-inspector had commented to the Fire Marshall before visiting the chemical storage area that it was often' helpful to verify that people were carrying out procedures in which they had been trained.

The Fire Marshall now agreed improved training with appropriate followup is needed.

The inspectors noted that gas bottles continue to be anchored as required in the many areas in which they were stored or, used.

The licensee's performance. in this program area appears to be adequate. No violations were identified.

E. Radioactive Waste Management (88035)

(1) The inspector reviewed the licensee's performance in the area of control of radioactive wastes (solid, liquid, and gaseous).

The inspector found that the licensee appeared to be'in compliance with regulatory requirements. The licensee conducts quality assurance audits of ten percent of the radioactive waste shipments per year following the recently updated Radioactive Products and Services Operating Procedure. A similar procedure exists specifically for handling the In-cell High Level Waste. The procedure which addresses Radwaste 4

Activity Estimation is updated appropriately to reflect the isotopic composition of the waste generated and facilitate proper completion of the shipping documents. The update is based on the radiochemical analysis of smears, and calculations of shielding attenuation and relative countrate ranges for each container type used. The licensee is in the midst of updating the tables used to characterize the wastes.

(2) The licensee does not release radioactive liquid wastes to city sewerage treatment plants or streams leaving the site. Rather, the licensee processes all low level liquid wastes in an onsite Waste Evaporation Plant. The residual sludge is solidified and packaged for shipment to a licensed radioactive waste disposal site.

6 (3) The liquid radioactive waste from the hot cells is solidified in 1.5 gallon containers, packaged in an appropriate liner, and is stored at the hillside bunker area pending shipment.

(4) The licensee's gaseous effluents are all appropriately filtered before release. The ventilation system incorporates appropriate sampling systems for the types of radionuclides being released. The measurement results are incorporated in an annual report to the NRC and the State of California. Releases have remained below NRC release limits.

(5) The inspector noted that the monitors and the flow controllers on the stack samplers were within their calibration periods.

The systems are source checked weekly and the particulate cartridges are analyzed weekly in the counting room. The source checks and instrument responses were recorded in the logbook kept in the roof top shelter where the instruments are installed.

The licensee's performance in this program area appears adequate.

No violations were identified.

1 F. Inspection of Waste Generator Requirements (84850)

(1) The licensee has in place appropriate procedures addressing low-level radwaste form, classification, stabilization, and shipment manifests. The procedures were current and had been I appropriato1y reviewed. As stated in the previous section, the l licensee keeps the procedurec current with regard to I significant changes in the principal isotopes and their relative concentrations in the waste.

l l The licensee's performance in this program area appears adequate, j No violations were identified.

G. Transportation Activities (86740) i (1) The licensee informed the inspector that upper management had decided not to continue the audit previously provided by the Nuclear Safety Assurance Manager of the Quality Assurance Department. This item was called to the attention of the NRC license reviewer who was participating in the inspection. This matter will be pursued by the NRC Ilcense reviewer on his return to headquarters.

H. Radiation Protection (83822)

(1) External Radiation Exposure (a) External radiation exposure records for the first and second quarters of 1988 were examined and the records verified compliance with 10 CFR 20. Three occasions were noted where exposures exceeded 1.25 Rems per quarter, however, the licensee's administrative procedures were in l

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accordance with 10 CFR 20.101 and were followed. Therv l' was also one example where the Ifcensee had underestimated the quarterly exposure of one individual due to a

disagreement between exposure readings obtained from l pocket dosimeters and the licensee's film and neutron dosimeters. When this problem was recognized, the "

licensee took numerous steps to mitigate the problem until i the cause for the underestimation could be determined. l These steps included continuing semi-monthly dosimeter ,

l exchange; zeroing the gamma pencils after each logging; '

increasing the multiplication factor used to account for neutron radiation; and continued studies to obtain a more accurate dosimeter reading to account for neutron radiation.

(b) Some shielding modifications had been implemer'ted at the NTR. Of particular note, the 2" borated polyethylene sheet was installed in the south cell ceiling, and an i additional brick shielding wall (48"H x 36"L x 8"W) had [

been added in the vicinity of the south cell door to  ;

provide additional shielding to the operators. The '

licensee was evaluating an audible digital self-reading i dosimeter and has purchased ten additional pocket dosimeters. The inspectors were also informed that a '

boral plate was added to the north cell and a magenta tape boundary was added to the hallway floor near the entrance to the control room to delineate the radiation area ,

boundary. When the new south cell door replaces the  !

current door it is expected to eliminate the need for the  !

floor marking in the hallway. Further exposure redtqtions <

are expected to result from pouring additional concrete [

along the south outside wall (along the back porch) and [

reducing by about 4 feet the distance operators will enter  ;

the south cell. The licensee has seen a reduction in the i exposures, however, at the same time there has been an )

increase in the throughput at the reactor. It is l anticipated that the cumulative affect of all of the l changes will be an even further reduction in exposures (t although throughput may continue to climb. The licensee I plans to evaluate the affect of the changes on exposures. f (2) Non-reportable Incident Review L

(a) During the course of working in the Radioactive Materials L Laboratory (RML) corridor an employee bumped his head  !

l whlie working near the crane book and block in the pool I l area. The surgeons cap he was wearing was knocked off and }

l landed on the floor. The employee retrieved the surgeons  !

cap and placed it on his head before exiting the area. [

His self survey at the area exit detected the l contamination and he reported it imediately to Nuclear t l Safety. The contamination, approximately 300,000 c/m. was l restricted to one spot in the employee's hair and was [

readily remaed by washing. The employee was given a l l I l i

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whole body count and the results indicated there was no deposition. The licensee set up an investigation committee, investigated the incident, identified the probable causes, and made recommendations to. strengthen the identified weaknesses. Responsibility for each recommendation was assigned to' a specific manager where appropriate.

The licensee's performance in this program area appears to be improving but warrants additional attention. No violations were identified.

I. Emoraency Preparedness (88050) ,

(1) Tests and Drills Records of a criticality drill conducted June 16, 1988 and four

, fire drills conducted bttuaan July 13-15, 1988 were examined.

The records documented that critigt.es were held af ter each drill and that itema iden,tified which require improvement or

. correction are receiving managesent attention. The records also documented licensee actions to upgrade the scope of emergency preparedness drills and so invite participation of the Valley Memorial Hospital (VMH) and the California Division of Forestry (C0F) in the licensee's drill program.

The emergency response call list was also examined and observed to be current and up to date. Personnel on the list were noted to have received all required training prior to being put on the list for emergency response.

(2) Facilities and Equipesnt The inspection of the licensee's facilities included a walk through all site facilities, an examination of maintenance and inventory records, an inspection of the emergency equipment located on the mobile equipment platform (MEP), and the vergency lockers 1ccated in Building 102-8. The following observations were noted:

(a? The emergency equipment located in the emergency lockers and the NEP, as well as other areas of the plant, were noted to be operable and records documented timely inventories and maintenance.

(b) The MEP, site fire engine, was operable but scheduled f-repair.

(c) The portable air samplers located in Building 102-8 were noted to have last been calibrated in 1979. If the samplers are intended for use during an emergency, their calibration frequency needs to be addressed in the Nuclear Safety Procedures.

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" _(d) The forty-three radiation measurement instruments observed  ;

by the NRC inspector were all within their calibration dates.

(3) Fire Protection 1 The eighty-nine fire extinguishers observed by the NRC inspector had been inspected monthly by the licensee as required.

The ir.spectors visited the-California Division of Forestry (CDF), Sur.o1 Station, which has first alarm response obligation. The Battalion Chief indiccted the CDF planned to.

participate with the licensee in a drill short1,' af ter the enti of the high fire season. The concerns expresset, during our previous visit with the CDF have been adequately addressed according,to the Battalion Chief.- The Chief did, however, express concern about the licensee's use of their MEP where it may impede the. effective use of the CDF aquipment arriving in response to an alarm.' The Chie' prefer, ad that the licensee

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licensee and the CDF in the coming months in an effort to coordinate their onsite fire suppression efforts.

(4) Medical .

The licensee viewed the video tape of the Lawrence Livermore r National Laboratory (LLNL), exercise that Valley Memorial Hospital (VMH) had participated in. The licensee indicated that viewing the tape had proven helpful. The licensee plans to include offsite agencies in a licensee drill following the high season of wild lend fires.

The ilcensee's performance in this program area needs improvement.

No violations were identified.

l J. Environmental Protection (88045)  ;

(1) The licensee continues to follow the environmental sampling l program. A review of the gross beta / gamma data from one of the vegetation sampling locations, V-2, appeared not to folicw a reasonable trend. The numbers reported for 1986 and 1907, 2.7

! pCi/g and 2.07 pCi/g, were significantly less than the average i of the results for the previous three years (21.4 115 pCi/g).

l Additionally, the available but not yet reported 1988 result

! (23.5 18.2 pCi/g) agreed well with the earlier data (all from the same sampling location). The inspector's .aview of the 198? and 1987 data found they should have been 12.7 pCi/g and i

20.7 pCi/g, respectively. The correct results clarified that t the 1986 and 1987 measurements were in reasonable agreement l with the average vegetation measurements including all sampling locations obtained from 1983 through 1988 (20 113 pCi/g). The errors were essentially number transcriptions. The licensee  ;

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10 agreed that more independent review was needed to assure the results prepared in generating the annual report were accurate.

The licensee's performance in this program area appears to be adequate. No violations were identified.

K. Action on Previous Inspection Items 87-01-04 This item was closed based on the invitation extended to the Valley Memorial Hospital to participate in an emergency drill with the licensee.

87-03-01 The NRC inspector reviewed the licensee's report of the identification and control of contaminated machinery. The licensee's response and effective corrective action appears satisfactory. This item is therefore closed.

88-01-01 The NRC inspector reviewed the status of the licensee's evaluation of the buildup of radioactive residue in the portable tank. The tank, transported by a forklift, is used to transfer radioactive liquid wastes to the WEP.

The licensee tracks the residue buildup, controls access to the tank, evaluates when cleanout should occur, and determine which method to use to minimize exposures. This item is therefore closed.

88-01-02 The licensee's performance in correcting the storage of incompatible chemicals was not sufficiently effective to preclude recurrence in the same storage building where the problem had originally been identified. This item i therefore remains open and will te reviewed again during the next inspection.

88-01 03 This item had been cited as a violation for the j licensee's failure to hydrostatically test self contained breathing apparatus (SCBA) cylinders. An examination of l the licensee's response dated March 1, 1988 and a physical

! examination of the SCBA cylinders located on the mobile equipment platform (MEP) and in the emergency lockers in l Building 102-8 verified that all cylinders had been hydrostatically tested. The tanks had been hydrostatically tested in April 1988 and had received their monthly operability checks. Records of monthly checks were examined from April to July 1988 and they appeared ' equate. This item is considered closed.

88-01-04 The NRC inspector examined the licensee's documentation reflecting improvements in the emergency response drill and exercise program. The improvements included accident classification, notification, decontamination, first aid, l

and offsite agency participation. This item is closed.

l L. Exit Meeting (30703) l l

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, Y9 n g The results of the' inspection were' discussed with the members of.the.. "

,lic'ensee!s. staff identified in Section 1.

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The' topics included: *

.Thelareasinspected. -

The radiation monitor. staff. changes.

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'., Status of open items: ,

i closed items .5 ,

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,f oopen items 3 (1,old. 2 new)'

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l Concerns ' expressed by the CDF Battalion Chief.'

Modifications to the RML. hot dock.. _

, Improvements in control 'of dos's e by,various changes completed and' planned at the NTR.

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.Orills and. Exercises (frequency ard scope improvements are

. ' planned and offsite agencies have been invited).

She~ .er procedure change It appeared that the shredder .I

- procedure should .includ: e specificity with regard to the conditions under which t'.. tre-filters on the ventilation

, system woul,d be chan ?'?. the licensee agreed this would be accomplished soon af'cr installation of the magnehelic gauges.

' Independent annual audits. The lice.nsee indicated that the independent annual audits of the transportation system were to l be discontinued though the QA audits'of ten percent of the radwaste shipments would continue. .The inspectors indicated this change was not viewed favorably and would be reviewed with l NRC licensing. *

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