ML20197A828
| ML20197A828 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 12/16/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20197A816 | List: |
| References | |
| 70-0754-97-02, 70-754-97-2, NUDOCS 9712230203 | |
| Download: ML20197A828 (14) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70 754 License No.: SNM 960 Report No.: 70 754/97-02 Lloonsee: General Electdo Company (GE)
Facility: Vallecitos Nuclear Center Location: Pleasanton, Califomla Dates: December 15 and 9,1997 Inspector: C. A. Hooker, Senior Fuel Facility inspector Approved By: Frank A. Wenslawski, Chief
- Materials Branch
Attachment:
Supplemental Inspection information 4
- 4"*!888:
C MPDR6
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EXECUTIVE
SUMMARY
Vallecitos Nuclear Center NRC Inspection Report 70 754/96-02 This inspection in ded a review of radiation safety, radioactive effluents, environmental .
protection, emergeoy preparedness, solid waste operations, and transportation of radioactivs materials. The inspection also included a review of circumstances involved with a repoltable event conceming the failure of a criticality monitoring system alarm. L t
Radiation Proth
- The licensee was adequately controlling extemal and intemal exposures (Sect!on 1.1).
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+ The licensee was adequately controlling loose radioactive materials, and contamination levels were significantly reduced (Section 1.2),
Badioactive Effluents
+ Radioactive effluents released to the environment were being maintained as low as is ,
reasonably achievable Al. ARA (Section 2).
Environmentaf Protection
- The licensee's sampling program was consistent with Section 10.2, Appendix A of the license and the environmental data indicated that plant operations did not appear to have any negative impact on the environment (Section 3).
Emeroency Preoaredness
- The licensee's emergency procedures provided adequate guidance for responding to plant emergencies and notification of offsite authorities. Emergency response personnel were adequately trained, and emergency drills appeared to adequately exercise the licensee's emergency response organization (Section 4).
Solid Waste Ooerations
- The licensee's program appeared adequate for meeting regulatory requirements (Section 5), .
Transoortation of Radioactive Material
- The licensee was effectively implementing its regulatory requirements for receiving and
- shipping special nuclear material (SNM) (Section 6).
3 Rooort Details Summary of Plant Status The use of SNM included post irradiation examination of low-enriched uranium reactor fuel elements in the Radioactive Materials Laboratory (RML)in 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 Califomia. 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. Insoection Scone (83822)
The inspector discussed extemal and intemal exposure controls with licensee personnel and toured licensee facilities to observe radiological work practices 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 31,1997.
- b. Observations and Findinas The licensee's evaluation of expected intakes for 1997 determined that workers are unlikely to recolve intakes of radioactive materials from coutine operations that would exceed 10 percent of the applicable annuallimit of Intake (All) specified in Appendix B of 10 CFR Part 20. Therefore, a committed effective dose equivalent is not included in the total effective dose equivalent.
Extemal exposures are from a ecmbination of NRC and state licensed activities. The highest exposures related to combined LNM and state licensed activities are for personnel associated with the licensee's RML hot cell remote handling operations (RHO) activities. The RHO manager's 1997 deep-dose equivalent (DDE) Al. ARA goal for the RML was 2.5 rem for a maximum individual dose. The maximum year to-date DDE was 1.895 rem. The average DDE for seven of the hot cell operators with the highest exposure was 1.24 rem.
Since current SNM activities primarily invdve examination of irradiated fuel. the licensee uses the detection of Cs-137 (byproduct ofi%diated fuel) in persu.nel WBCs as a trigger to inillate evaluations for potentialintakes of uranium Ea' 71utonium. Be use of Cs-137 was based on the licensee's isotopic characterization of net cell %r0 ntive contaminates and beta to-ayha ratios from air sampling data anJ wipe L#,
Section 8.11.1,"Whole Body Counting,' Appendix A of the license requires a minimum
4 of one WBC annually. Dependent on an individual's work assignment, RHO personnel were scheduled for WBCs 4,3, and 2 tirnes per year, These schedules were primarity related to work activities associated with byproduct materiallicensed by the State.
Although no individual had exceeded an annual frequency for a WBC, the inspector noted that severalindividuals had not received WBCs at the frequencies indicateo cy the licensee's schedule. The licensee attributed causes to dropped schedules during computer maintenance (April, May June, July, and September 1997) and the lack of timeliness of some personnel responding to notices for a scheduled WBC. Subsequent to the inspector's observation, the licensee's evaluation using the methodology provided in NUREG/CR-4884,
- Interpretations of Bioassay Measurements," determined that the time lapse between WBCs did not have a negstive impact on the Cs-137 trigger value for evaluating potentialintakes of uranium or plutonium using 10 percent of the applicable annual limit of intake as an investigstive level. Based on independent calculations using the same methodology, the inspector found no disagreement with the licensee's evaluation.
In response to the above issue, the licensee performed WBCs of the personnel of concem and the RHO manager initiated a backup ccheduling system for personal oversight to assure personnel received WBCs when scheduled. The review of WBC data for the past year indicated no worker had received any intake of Cs 137.
Occasionally, trace amounts of Co-60 were observed.
The review of air sampling data from fixed samplers located in general work areas and the hot cell interlocks indicated that airbome radioactivity was routinely less than 10 percent of the derived air concentration limits specified in 10 CFR Part 20, Appendix B, Table 1, Column 3 for Sr 90 and Pu 239 associated with irradiated low enriched reactor fuel. Air samplers were calit ated semiannually in accordance with the licensee's procedures, and hood flow measurements were conducted quarterly in accordance with the requirements of Table 8.1, Appendix A of the license,
- c. Conclusions Th" licensee was adequately controlling extemal and intemal exposures.
1.2 Surveys and Control of Radioactive Materials
- a. Insoection Scoce (83822)
The inspector reviewed selected routine and non-routine survey records associated with NRC licensed activities for Buildings 102,103, and 349. The operation of survey instruments, air monitors located in the hot cell operating area, worker activities, radiation waming postings, and radiological controls were observed during facility tours.
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- b. Observations and Findinas The inspector noted a significant improvement in the control of loose contamination in the normally contaminated areas of the RHO facility for routine operations during the past year. Loose contamination levels in the hot cell radiation locks were normally less than 200 dpm/ft.8 for alpha activity and less than 35,000 dpm/ft.8 for beta activity.
Previously, the alpha activity would range from less than 200 to 2000 dpm/ft.8 and the beta activity ranged from 10,000 to 50,000 dpm/ft.8. The removable contamination ,
levels from large area cmears (10 to 50 ft.:) of the hot cell access corridor, main corridor, manipulator repair room, hot shop, pool storage area, and other normally contaminated 'vork areas were typically less than 200 dpm alpha and less than 1,000 dpm beta. Previously, the licensee had typically maintained the alpha activity in these areas to less than 200 dpm for large area smears, but the beta activity ranged from 5,000 to 20,000 dpm. For Building 103, licensee survey data indicated that loose contamination levels in the laboratories were routinely less than 200 dpm/ft.8 and 500 dpm/f' 8 for alpha and beta activity, respectively. The inspector noted the performance of daily, weekly, biweekly, and monthly radiation and contamination surveys were consistent with licensee procedures.
During the inspection, activities in the RHO facility were primarily confined to within the hot cells. However, the inspector observed an entry into the No. 4 hot ceilinterlock for preparation of loading a Co 60 source shipping container. Adequate radiological control precautions were taken by the operator and the interlock air sampler automatically started when the outer interlock door began to lower. No concerns were identified by the inspector.
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. Air monitors located at the face of the hot cells were operational, currently calibrated, and the alarms were established at the appropriate set points. Radiation and high radiation areas, and radioactive materlats areas were posted and controlled as required by 10 CFR Part 20. Special status signs were present throughout each facility to wam personnel of elevated radiation levels.
Security of licensed material was adequately maintained and housekeeping was generally good in the areas toured.
- c. Conclusions The licensee was adequately controlling radioactive materials and contamination levels had been significantly reduced.
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2 Radioactive Effluents. ;
- a. lnspection Scope (88035)
The inspector reviewed selected records of liquid and gaseous effluent sampling data j from January 1 through November 30,1997, and toured the site basin liquid effluent j collection system.
- b. Observations and Findings The inspector noted that there had been no changes in the licensee's processing of radioactive liquid waste. Radioactive liquids were either solidifed or collected and transported in a r,tainless steel tank to the Building 34g waste evaporator facility for processing. Cor#contrates from the evaporation process are solidifed for waste 4
disposal. Effluelt waters from the evaporator are collected in monitoring tanks for
' analysis and ultimately disposed of by evaporation through a boiler. The evaporating system was being operated approximately 2 weeks per quarter and was shut down .
during the time of the Inspection.
I Non-contact (with radioactive material systems) industrial waste water continues to be 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 Stats discharge permit. Basin 1 continues to be used for collecting treated non radioactive sanitary waste water, which is sampled and analyzed prior to being sprinkled on the licensee's property. The sampling data for each basin discharged indicated no detectable radioactivity above the action levels specified in Section 10, Appendix A of the license.
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. All discharges during the past year had been to the creek, Sanitary waste is collected in an *1mhoff" tank before undergoing sand filtration and chlorination. The Imhoff tank is not routinely sampled and sludge is pumped out annually and sent to a sanitary waste treatment system for disposal. Approximately 6,000 gallons of sludge were removed from the tank on October 21,1997, for offsite disposal. During the removal, thw siudge was sampled by the licensee and sent to a vendor for a laboratory analysis. At the time of the inspection, the licensee had not received the vendor's sample results. The results of the sample analysis will be reviewed in a subsequent inspection and is considered an inspection followup item (IFl 70-734/9702-01).
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 specified in 10 CFR Part 20, Appendix B. Table 2 Column 1. The inspector observed that the licensee had calculated the annual dose from 1996 gaseous effluent discharges in accordance with the criteria used by the Environmental Protection Agency in 40 CFR Part 61, Subpart 1. The dose was calculated using the Environmental J' Protectbn Agency's COMPLY computer code. The licensee's calculated effective dose
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equivalent from all gaseous effluents including the Building 105 test reactor for the maximally exposed individual was 0.3 millirem. This dose was well below the 10 CFR 20.1101 dose constraint of 10 mrem / year.
- c. Conclus!ons Radioactive effluents released to the environment were being maintained Al. ARA.
3 Environmental Protection
- a. Insoection Scone The inspector reviewed the licensee's Effluent Monitoring and Environmental Annual Summary Report for 1996, selected vendor sample analysis reports for 1996 and 11/97, and the licensee's environmental air sampling data for the past 6 months. The inspector also observed the status of the sampling equipment and chanDi ng of the sample filters at each of the licensee's four environmental sampling statiotts,
- b. Observations and Findings The licensee's annual effluent and environmental report was issued in accordance with Condition No. S-6 of the license and included a summary of the radioactive and nonradioactive releases from the site. The report also intluded measurements of radioactive and nonradioactive constituents from neighboring streams, wells, soils, and vegetation. The data presented in the report indicated that there had been no negative impact on the environment.
Environment (Mmples collected for radiological measurements are sent to a State of Califomla cettdieu ie.boratory for analysis. T1.a review of selected 1996 and 1997 vendor analyses supported the licensee's information provided in the environmental report.
However, the inspector noted several anomalies in units and sample values in some of the vendor's 1997 sample results which haa not been questioned by the licensee. The licensee contacted the vendor who acknowledged the errors and was to send the licensee corrected copies of the sample results. The inspector considered the matter to be an indication of less than adequate review of vendor sample results. The inspector's observation was acknowledged by cognizant licensee representatives who informed the inspector more detailed reviews would be performed in the future.
An inspection of the environmental sampling equipment at each of the four environmental sampling stations did not identify any equipment maintenance problems.
The sampling equipment was currently calibrated and appropriate sample filter handling techniques were employed by the person changing the samples. ,
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- c. Conclusions The licensee's sampling program was consistent with Section 10.2, Appendix A of the license and the environmental data indicated that plant operations did not appear to have any negative impact on the environment.
4 Emergency Preparedness Emeroency Prooram Dased 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 applicson 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 preparodness 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. .Qhservations 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, trancportation 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 offsite agencies.
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 communication with offsite support agencies. Although the exact date had not been set, the licensee had plans to participate in a joint radiological medical emergency exercise between Valley Medical Center, Pleesanton, Califomia, and the I.awrence Livermore National Laboratory, Livermore, Califomia, with!n the next 2 weeks. The exercise was suggested by the medical center to evaluate their capabilities in handling such emergencies.
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The inspector noted that the emergency cabinets contained equipnient and supplies as delineated in the licensee's procedures. Emergency cabinets were routine'y inspected and inventoried by the safety staff in accordance with established procedures.
Radiation survey instrumerits examined were currently calibrated and operational.
Self contained breathing apparatuses were neatly maintained and all air tanks viere full.
During facility tours the inspector observed the placement of fire extinguishers appeared appropriate. Emergency exits and pathways were well marked and easily identifiable.
- c. Conclur.lons The licensee's emergency procedures provided adequate guidance for responding to plant emergencies and notification of offsite authorities. Emergency response personnel were adequately trained, and emergency drills appeared to adequately exercise the licensee's emergency response organization. The licensee's emergency response equipment was maintained in a state of operational readiness.
5 Waste Generator Requirements and Waste Storage
- a. Insoection Scoce (84850 and 84900)
The inspector discussed solid waste operations with cognizant licensee personnel and reviewed selected licensee procedures,
- b. Observations and Findings 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. The licensee had adequate storage space for waste.
The RHO manager continues to be the primary person responsiole for radioactive waste processing and transportation activities at the facility. All of the radiuactive solid wastes generated onsite are transferred to RHO facilities 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 manifest" end 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.
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.l 6 Transportation of Radioactive Materials
- a. Insoection Scone (86Y40) ~
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. Observatiom and Findinas The licensee had made only one shipment of SNM during the past year. The shipment i
consisted of 10 irradiated low enriched fuel rod segments shipped to the Argonne National Laboratory on October 28,1997. The shipment was made in a ModelT 2 NRC 4
approved shipping contair.er (USA /5607/B[F]). The licensee's shipping records indicated that the shipment was made in accordance with the safeguards requirements of 10 CFR 73.21 for transporting irradiated reactor fuel. The packaging, inspections, and transport index were consistent with the requirements of the NRC Certificate of Compliance for the package.
The licensee had received one domestic irradiated fuel shipment and one retum shipment of irradiated fuel from a foreign country during the past year. Each of the shipments was transported under the safeguards requirements of 10 CFR 73.21.
Based on the examination of licensee receipt and shipping records, the inspector noted that: (1) the licensee performed receipt surveys pursuant to 10 CFR 20.1906, (2) transfers of SNM were conducted in accordance with the requirements delineated in 10 CFR 70.42, and (3) the regulatory requirements of 10 CFR Parts 71, and 49 CFR Parts 171 throuGh 189 for transporting radioactive materials were met. Personnel associated with the handling and packaging of shipping containers were provided annual training applicable to their assigned tasks.
The licensee's annual quality assurance audits of certified shipping containers have been normally conducted in the last quarter of the year. The last audit was conducted in December 1996 and the 1997 audit was planned to be conducted by the end of the year. The inspector noted that th6 typical formal audit report issued by the lead auditor (currently the manager of regulatory compliance) had not been completed for the 1996 audit. However, the audit checklist sufficiently documented the audit results. The inspector noted that the audit covered the requirements of Subpart H to 10 CFR 71.
The audit identified nn findings that required corrective actions. Regard:ng the lack of a formal report, the regulatory compliance manager stated that a draft report had been returned to one of the auditors for editorial corrections and inadvertently overlooked for completion.
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- c. Conclusions The licensee was adequately implementing its regulatory requirements for receiving and shipping SNM.
7 Followup on Operational Event (90712 and 2600/003)
(Closed) Licensee Event Reoort No. 33021: Failure of the criticality monitoring system (CMS) alarm in the RML facility. During the performance of a mMo source check of the CMS at approximately 2 p.m. on October 1,1997, the alarri mm m did not actuate when the AmBe neutron check source was applied to the detectou M9 licensee identified that a mechanical trip needle on the readout meter (0 to 10 uA) had stuck and failed to actuate the alarm (3.1 uA). The normal reading during the response check was 4.5 uA. The CMS in the RML facility consisted of a single lithium iodide neutron detector with a battery-powered photo multiplier tube that provided current to a remote readout and alarm system. Loss of current to the meter provided a trouble alarm, but in this case there was no loss of current to the meter. An alarm condition actuates a local klaxon horn and an alarm panelin the security building. At the time of the failure and during subsequent troubleshooting all movement of SNM was discontir'ued. At 12:44 p.m. on October 2,1997, the licensca reported the matter in accordance with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting requirements of 10 CFR 70.50(b)(2)(i). The meter was replaced and the system properly responded during the source check. The licensee's evaluation for any potential undetected criticality events since the previous monthly source checks was described in the initial report and a subsequent followup 30 day report submitted on October 30,1997. The inspector verified the corrective actions described in the licensee's followup report, which included the installation of a new CMS. Actions taken at the discovery of the event and subsequent corrective actions appeared adequate and appropriate.
Inspection Report 70-754/97-01, dated April 16,1997, described the licensee's plans to replace the above licensee designed CMS with a new upgraded gamma detection CMS.
The licensee maintains a CMS at the RML and the Hillside Stora.f facility. The licensee had previously removed a CMS located in Building 103, following a reduction of the SNM inventory at this location. The above lithium lodide neutron detection CMS had been in service prior to the newer CMS requirements of 10 CFR 70.24 (a)(1) for persons licensed after December 6,1974. Safety Condition S-7 of the license also provided conditions that exempts the licensee from certain CMS alarm requirements of 10 CFR 70.24 (a)(2) for persons licensed prior to the newer requirements. Since the time of the reported alarm failure, the licensee had completed its installation of a new commercially manufactured gamma c etection CMS at the RML and the Hillside Storage facility.
The inspector performed a walkdown of the new system and reviewed the initiating Change Authorization (CA 96-07), records of lastrument calibrations and acceptance tests, and established procedures for performing monthly source checks of the new
system. The new Eberline CMS (RMS 11 RU) included three analog readouts and three
_ compensated gamma detectors (DA16CCS) with a built in check source. The criticality coincidence alarm er a a two out of three logic for activation of the criticality evacuation alarm. The system is designed to provide a trouble alarm with a system malfunctio..
and is equipped with en un-interruptible power supply designed to transfer loads in the event of a utility line failure. Based on the review of the new CMS, the inspector concluded that the new system met the requirements of 10 CFR 70.24 (a)(1) and the guidance provided in ANSl/ANS-8.3-1986.
Relative to the new system, the license had plans for amending its license to remove the exemption and update the description of the CMS in Appendix B, Demonstration Volume of the license.
8 Exit Interview The inspector presented the inspection results to members of the licensee management at the conclusion of the inspection on December 5,1937. Followup discussions relative to the inspection wers held on December 9,1997. The licensee acknowledged the findings presented.
Altnough proprietary information was reviewed during this inspection, such information is not laowingly described in this report.
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ATTACHMENT !
- SUPPLEMENTAL INSPECTION INFORMATION -!
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- PARTIAL LIST OF PERSONS CONTACTED J LI:mnsee i F. A. Artt, Manager, Fac,uties Maintenance o
C. W. Basset, Manager, Regulatory Compliance .
- E. W. . Hagberg, Facilities Protection Specialist :
. B. M. Murray, Senior Licensing Engineer ;
' A. MJ Rogers, Radiation Monitoring Specialist G. L. Stimmell, Manager, Vallecitos and Morris Operations J. l. Tenorio, Manager, Remote Handling Operations -
NHQ .
?J. -V. Everett. Health Physics inspector, Region IV M. T. Masnik, Project Manager, Non-Power Reactors and Decommissioning Project Directorate /NRR =
D. B. Spitzberg, Chief, Nuclear Materials inspection and Decommissioning Branch, Region IV INSPECTION PROCEDURES USED
'IP 83822: Radiation Protection IP 88035: Radioactive Waste Management IP 88045: Environmental Protection IP 88050: Emergency Preparedness IP 84900: Low-levelWaste Storage IP 84850: Inspection of Waste Generator Requirements IP 86740: Inspection of Transportation Activities
- IP 90712: In-Office Review of Written Reports of Non routine Events at Power Reactor Faullities Tl 2600/03: Operational Safety Review ITEMS OPENED, CLOSED AND DISCUSSED .
Ooened
-70 754/9702-01 IFl Review sample results of Imhoff tank sludge -
Closed 70-754/33021 LER - Failure of the CMS alarm in the RML
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- q LIST OF ACRONYMS USED .
~ALARA as low as is reasonably achievable CMS = criticality monitoring system-deep-dose equivalent- j DDE RHO- Remote Handling Operations -
RML Radioactive Materials Laboratory i SNM+ ; special nuclear material '
WBC whole body count 4
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