ML20198S907
| ML20198S907 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 01/04/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198S901 | List: |
| References | |
| 70-0754-98-02, 70-754-98-2, NUDOCS 9901120037 | |
| Download: ML20198S907 (11) | |
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P ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-754
. License No.: SNM-960 Report No.: .70-754/98-02 -
~Licensee: General Electric Company
. Facility: .Vailecitos Nuclear Center (VNC)
Location: Pleasanton, California
' Dates: November 16-19,1998 inspector: J. V. Everett, Sr. Health Physicist W. L. Britz, Fuel Cycle Inspector D. S. Simpkins, Radiation Specialist Approved By: D. Blair Spitzberg, Ph.D., Chief, Fuel Cycle / Decommissioning Branch 9 Division of Nuclear Materials Safety
Attachment:
Supplemental Inspection Information i 1
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9901120037 990104 PDR ADOCK 07000754 PDR C
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I EXECUTIVE
SUMMARY
Vallecitos Nuclear Center NRC Inspection Report 70-754/98-02 This routine announced inspection included aspects of radiation protection, maintenance and surveillance testing, radwaste management, environmental protection, emergency preparedness and followup on an open item from previous inspections.
Radiation Protection The licensee was' adequately auditing and appraising the radiological program. The licensee was adequately controlling the radiological exposure program, the portable -
instrument calibration and source check program, the exposure control program for pregnant women and the radiological protection program in the workplace (Section 1).
Maintenance and Surveillance Testina -
The licensee had established an adequate preventive maintenance program through the use of procedures and a computerized system to schedule necessary periodic maintenance activities (Section 2).
Radwaste Manaaement Review of effluent data indicated consistent negative results for the iodine-131 data. As a result, an inspection followup item was identified to review the validity of the laboratory calibration for the iodine-131 airborne release samples during a future inspection (Section 3).
The waste management program, waste storage program and waste facilities met
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regulatory requirements (Section 3).
Environmental Protection The environmental monitoring program met the requirements of license condition 10.1, effluent sampling, and license condition 10.2, environmental sampling. Environmental data indicated that plant operations did not have any negative impact on the environment (Section 4).
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
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1 licensee's emergency response organization. The licensee's emergency response equipment was maintained in a state of operational readiness (Section 5).
Transoortation l J
The Vallecitos procedures and program for shipping and receiving radioactive material I was reviewed and found acceptable. Procedural requirements were reviewed against
- selected sections of Title 49 of the Code of Federal Regulations (49 CFR). The individual responsible for implementing the radioactive shipping program was found to be )
^ j qualified to perform the required function (Section 6). j l
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Report Details Summary of Plant Status 4
Current activities involving special nuclear material (SNM) consisted of post-irradiation examination of low-enriched uranium reactor fuel elements in the Building 102 hot cell facility.
There were no current activities involved with the use of SNM in Building 103. Other ongoing site activities involved the use of radioactive materials licensed by the state of California. Some of these activities consisted of fabricating cobalt-60 sources and examination ofirradiated reactor hardware.
1 Radiation Protection (83822) 1.1 Insoection Scope The inspectors reviewed extemal and internal exposure controls with licensee personnel and toured licensee facilities to observe radiological work practices and the operation of air monitoring equipment. The inspectors also reviewed selected records of individual dosimetry reports for 1998.
1.2 Observations and Findinas The radiation protection program and procedures were reviewed for significant changes.
No significant changes were found. The 1998 audits and appraisals of the radiation protection program performed by the Vallecitos Nuclear Center (VNC) Regulatory Compliance organization, as specified in the VNC Safety Standard, were reviewed. The quarterly meeting minutes of the Vallecitos Technological Safety Council (VTSC), the Summary of 1997 Activities and the monthly radiation safety audits by the Regulatory Compliance section were reviewed. Nuclear Safety procedures developed for compliance with license condition 7.2, radiation control inspection, were reviewed.
Occupational exposure records including individual dosimetry reports and annual reports, and the program to control radiation exposure were reviewed. The review of contamination events during the year indicated there were none. The 1997 ALARA (as low as reasonably achievable) report and the ALARA goals for 1998 were reviewed. All aspects of the radiation safety program reviewed were determined to be adequate to meet the requirements of the licensee and 10 CFR Part 20.
The respiratory protection program and records for respiratory qualified personnel were reviewed. The inspectors verified that emergency personnel were trained once per year on self-contained breathing apparatus. Other personnel were retrained and medically qualified every 24 months. ,
The program for controlling exposures to pregnant women was reviewed. VNC Nuclear Safety Procedures and Safety Standards specifically address the program controls for
exposures to pregnant women. No pregnant women were currently working in the radiologically controlled areas. The program was determined to be adequate.
I Portable instrument calibration controls, standard traceability and the availability of check !
sources in the field were reviewed for compliance with license conditions 8.6, instrument calibration, and 8.7, instrument check sources. Instrumentation calibration records were reviewed and indicated that instrumentation onsite was being maintained calibrated.
Check sources were noted as being available in the field for portable instruments in compliance with license condition 8.7.
Radiological areas at VNC were toured. The areas were reviewed for compliance with markings, postings, monitoring equipment, radiological controls and work practices. No I deficiencies were noted.
1.3 Conclusions The licensee was adequately auditing and appraising the radiological program. The licensee was adequately controlling the radiological exposure program, the portable instrument calibration and source check program, the respiratory protection program, the exposure control program for pregnant women and the radiological protection program in the workplace.
2 Maintenance and Surveillance (88025) 2.1 Inspection Scope
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The licensee's preventive maintenance program was reviewed to verify that required maintenance activities were being performed.
2.2 Observations and Findinas i
Preventive maintenance was performed for facilities and equipment at the site using i either a computerized tracking system or work routine procedures established in the i Nuclear Safety Procedures, series 3400 through 3700. The computerized system l produced periodic work sheets which would be assigned to site personnel by the Facility :
Manager. Worksheets were issued on a weekly, monthly, or quarterly schedule. Each j work sheet included one task. Attached to the work sheet would be a detailed work ;
instruction and/or sign off list. Upon completion of the task, the work sheet was returned i to the Facility Manager who reviewed and filed the completed sheet. The current computer software fo tracking preventive maintenance activities was not Y2K compliant.
A new software package had been purchased that was Y2K compliant and would be !
installed prior to January 2000. No other activities concerning maintenance and surveillances were susceptible to the Y2K problem.
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6-I The manual preventive maintenance program was documented in the series 3400 through 3700 Nuclear Safety Procedures. These procedures were reviewed. SNM-960 license condition 8.1.1.6 required differential pressure checks monthly on ventilation systems where special nuclear material was handled. Nuclear Safety Procedure 3440,
" Area 100 Work Routines," Revision 7 was reviewed to verify that pressure checks were included in the monthly work routines. Step D.5 of the attachment to the procedure included the requirement to log the differential pressure for the building 103 ventilation.
2.3 Conclusion The licensee had established an adequate preventive maintenance program through the use of procedures and a computerized system to schedule necessary periodic maintenance activities.
3 Radwaste Management (84850,84900,88035))
3.1 Insoection Scope The inspectors reviewed the radwaste program including: (1) the effluent monitoring program, (2) the process to ensure compliance with 10 CFR 20.2003, Disposa/ by release into sanitary sewage, (3) the waste generation records to verify proper storage or disposal, and (4) the characterization of the waste being generated. The waste storage areas were toured to verify appropriate measures, including security and postings, were in place to maintain control of the wastes.
3.2 Observations and Findinas The annual report of 1997 effluent monitoring and environmental surveillance programs at VNC was reviewed. The inspectors noted that Figures 3 and 5 were negatively biased for the iodine-131 airborne release samples for the entire year. Negative results on samples without a source term are expected on a random basis but are typically statistically offset by periodic positive results. An entire year of negative results may be indicative of a calibration problem. The licensee had not addressed and could not explain the consistent negative results for the 1997 data. The laboratory calibration for the analysis of iodine-131 airborne release samples c.a be reviewed during a subsequent inspection as inspection followup item UFl 70-754/9802-01).
The inspectors also noted that the environmental alpha, beta and gamma measurements in Figure 10 of the annual report were higher in December that in other months. The inspectors determined from the laboratory records that one sample out of four in December was counted before the normal decay time had elapsed providing a high reading from background radon progeny.
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. 1 These two examples indicate a lack of rigor in reviewing effluent data. The inspectors inquired whether or not the analytical lab participated in an interlaboratory comparison program. It was determined that the licensee did not participate in such a program.
The inspectors reviewed the licensee's control of liquid radwaste disposal by the sanitary system. The licensee's policy is not to dispose of liquid radwaste into the sanitary system. The VNC Safety Standard on radioactive effluent controls did not permit the use I of site industrial or sanitary drains for liquid radwaste disposal.
The inspectors reviewed waste generation and handling records including shipping !
papers for fuel rods and manifests for storage. The inspectors reviewed the waste processing areas, the waste storage facilities, including vans for low level waste, and the hillside bunker storage for waste fuel pellets. The methods to determine the isotopic characterization and amount of waste by smears, predetermined ratios, dose rate calibrations and specific calculations were reviewed. The records, characterization j methods and waste storage provisions were adequate. '
1 3.3 Conclusions Review of effluent data indicated consistent negative results for the iodine-131 data. As a result, an inspection followup item was identified to review the validity of the laboratory calibration for the iodine-131 airborne release samples during a future inspection.
The waste management program, waste storage program and waste facilities met regulatory requirements.
4 Environmental Protection (88045) 4.1 Inspection Scope The licensee's Effluent Monitoring and Environmental Annual Summary Report for 1997, selected vendor sample analysis reports for 1997 and 1998, and the licensee's environmental sampling data for the past nine months were reviewed. Also observed was the status of the sampling equipment at each of the licensee's four environmental sampling stations.
4.2 Observations anGindinas The licensee's annual effluent and environmental report was issued in accordance with safety condition No. S-6 of the license and included a summary of the radioactive and nonradioactive releases from the site. The report also included 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. All radioactive releases were well below 10 CFR Part 20 limits.
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Environmental samples collected for radiological measurements were sent to a State of California certified laboratory for analysis. The review of selected 1997 and 1998 vendor analyses supported the licensee's information provided in the environmental report.
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 calibrated and appropriate sample filter handling techniques were employed by the person changing the samples.
4.3 Conclusions The environmental monitoring program met the requirements of license condition 10.1, effluent sampling, and license condition 10.2, environmental sampling. Environmental data indicated that plant operations did not have any negative impact on the 4 environment.
5 Emergency Preparedness (88050) 5.1 Inspection Scope 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," Appendiv A of the licensee's renewal application dated December 1,1992, the licensee included a commitment to maintain procedures for responding to emergencies.
4 The licensee's emergency preparedness program, applicable emergency response
- procedures, emergency response training records and drills were reviewed. Selected d
emergency response equipment lockers and the mobile equipment platform were inspected.
5.2 Observations 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, transportation of radioactive materials, major power outages, chemical or oil spills and hazardous materials / waste emergencies. The licensee's procedures adequately outlined the emergency response organizatica, responsibilities of emergency response personnel, classification of events and notification of offsite agencies.
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. Annual drills and critiques were conducted as required by the licensee's procedures.
Review of records for onsite drills and critiques indicated that personnel were familiar with their assigned responsibilities and drill deficiencies were identified and corrected.
The licensee conducted their quarterly communications tests with offsite support agencies. A joint radiological medical emergency exercise between Valley Medical 1
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Center, Pleasanton, California, and the Lawrence Livermore National Laboratory, Livermore, California, was conducted in 1998. The exercise was used to evaluate the hospital's capabilities in handling such emergencies.
Emergency cabinets located throughout the site contained equipment and supplies as delineated in the licensee's procedures. These cabinets were routinely inspected and inventoried by the safety staffin accordance with established procedures. Radiation survey instruments were currently calibrated and operational. Self-contained breathing apparatuses were maintained and all air tanks were full. Emergency notification lists were current and reviewed in accordance with procedures.
5.3 Conclusions
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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.
6 Transportation (86740) 6.1 Inspection Scope The radwaste shipping and receiving program was reviewed to verify compliance with selected sections of 49 CFR. Qualifications of individuals involved with shipping radioactive material was verified.
6.2 Observations and Findinos The Vallecitos procedures for handling, shipping, and receiving radioactive material were reviewed including VNC Safety Standard 7.3 " Radioactive Waste Handling," Revision 12, VNC Safety Standard 7.6 " Radioactive Material Shipment and Receipt", Revision 8, dated February 1997, and Irradiation Processing Operation Standard Operating Procedure Chapter Ill, " Shipping and Receiving Radioactive Material," Revision 8, dated October 1998. The procedures were reviewed against selected sections of 49 CFR including requirements for class 7 radioactive material, surface contaminated objects, low specific activity, route controlled quantities, exempt quantities, special form and type A and B prckaging. The procedures included directions on proper labeling, marking, classifying packaging and determining quantity type and form. The procedures were found to be current with 49 CFR. The Remote Handling Operations Shipping and Receiving organization was responsible for processing shipments and for receipt of incoming radioactive material. The Remote Handling Operations Shipping and Receiving organization was also responsible for reviewing all procedu.a t. sed by the various site organizations for the packaging of radioactive material. The Manager, Remote Handling Operations was responsible for approving radwaste shipping papers.
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l LThe current Manager, Remote Handling Operations had 20 years experience with 1 radioactive waste shipments.-
. Vallecitos had provisions for shipping radwaste to Bamwell for burial. No shipments had l . been made in the past 18 months; Vallecitos also used a vendor service for volume j i
reduction, repackaging and disposal. No shipments had been made to the vendor in the l
- past 12 months. I i
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The Vallecitos procedures and program for shipping and receiving radioactive material was reviewed and found acceptable. Procedural requirements were reviewed against
, selected sections of 49 CFR. The individual responsible for implementing the radioactive
- - shipping program was found to be qualified to perform the required function.
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- 7 Follow-up of Open items (92701)
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. (Closed) Inspection Followuo item (70-754/9702-01): The licensee's response of April l l 29,1998,
Subject:
Reply to Open item 70-754/9702-01, " Review Sample Results of j /mhoff Tank Sludge"pavided the details of the sampling and analysis process and F stated that the measured alpha and beta radioactivity in the Imhoff tank sludge was ~ .
_ l 4 determined to be due to na!urally occurring radionuclides, The licensee concluded that the radioactivity did not originate from any licensed activities at GE VNC. The report also discusses vendor laboratory typographical errors in the reporting of the units pCi/l rather i than pCi/gm and the misidentification of a sample. The inspectors found the licensee's 4
response to be adequate. This item is closed.
.8 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management
. at the conclusion of the onsite inspection on November 19,1998. A telephone followup
. exit briefing was conducted on December 22,1998 to discuss the negative bias issue concerning the icdine-131 environmental data included in this report. The licensee did not identify as proprietary any information provided to or reviewed by the inspectors.
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ATTACHMENT . - l PARTIAL LIST OF PERSONS CONTACTED Licensee
' R. Adamson, Manager, Materials Technology F. Arlt, Manager, Facilities Maintenance' .
D Aufdenkamp,-Specialist, VNC Shipping C. Basset, Manager, Regulatory Compliance M. Rogers, Specialist, Radiation Monitoring T. Mahmood, Materiats Technology .
B. Murray, Senior Licensing Engineer j
. G. Stimmell, Manager, Vallecitos and Morris Operations J. Tenorio, Manager, Remote Handling Operations
. INSPECTION PROCEDURES USED IP 83822: Radiation Protection IP 88035: Radioactive Waste Management !
IP 88045: Environmental Protection iP 88050: Emergency Preparedness IP 84900: Low-level Waste Storace IP 84850: Waste Generator Requirements IP 86740: Transportation IP 88025: Maintenance / Surveillance Testing
. IP 92701: Inspection Fo;1owup ITEMS CLOSED 1
Opened 70-754/9802-01 IFl Laboratory calibration for the analysis of iodine-131 airborne release samples Closed 70-754/9702-01 IFl Review sample results of Imhoff tank sludge LIST OF ACRONYMS USED ALARA as low as reasonably t.chievable CFR Code of Federal Regulations GE General Electric Company PDR- Public Document Room pCi/g picoCuries per gram pCi/l picoCuries per liter SNM special nuclear material VNC- Vallecitos Nuclear Center VTSC- Vallecitos Technological Safety Council