ML20210K788

Insp Rept 70-0754/86-01 on 860228-0307.No Violation Noted. Major Areas Inspected:Operator Training & Retraining, Criticality Safety,Operations Review,Transportation/Radwaste Mgt & Emergency Preparedness

ML20210K788
Person / Time
Site:	07000754
Issue date:	04/25/1986
From:	Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20210K774	List: ML20210K769 ML20210K788
References
70-0754-86-01, 70-754-86-1, NUDOCS 8604290056
Download: ML20210K788 (10)

Text

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U. S. NUCLEAR REGULATORY COMMISSION e

REGION V Report,No.'70-754/86-01

. Docket No.70-754 License'No. SNM-960

c Safeguards Group: I l

Licensee: General Electric Company i Vallecitos Nuclear Center l P. O. Box 460

.Pleasanton, California 94566 f~ Facility Name: Vallecitos Nuclear Center Inspection at: Pleasanton, California

-Inspection Conducted: February.28 - March 7, 1986

Inspected by

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B. L. Brock, Fuel Facilities Inspector Dite Signed Approved by: _[

R. D. Thomas, Chief

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Nuclear Materials Safety Section Summary:

Inspection on February 28 - March 7, 1986 (Report No. 70-754/86-01)

Areas Inspected: A routine unannounced inspection was conducted of management organization and controls, operator training and retraining, criticality safety, operations review, transportation / radioactive waste management, radiation protection, emergency preparedness, and environmental protection.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 86740/84850, 83322, 38045 and 88050 were covered by one NRC inspector.

Results: No violations were identified in the nine subject areas inspected.

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c DETAILS

1. Personu Contacted ,

• R. W. Darmitzel, Manager, Irradiation Processing Operation R. E. Butler, Manager, Nuclear Safety R. B. Adamson, Manager, Core Materials Testing and Analysis

• G. E. Cunningham, Senior Licensing Engineer J. I. Tenorio, Manager, Remote Handling Operations

':. R. Lloyd, Senior Engineer, Nuclear Safety R. Bagley, Specialist, Facilities Protection F. A. Arlt, Supervisor Maintenance and Carpentry E. J. Strain, Compliance Engineer l: D. C. Bowden, Senior Engineer, Nuclear Safety R. P. Tucker, Principal Engineer Fuel Material Testing B. Murray, Radiological Engineer C. Delisle, Radiation Monitor Technician T. B. Garcia, Radiation Monitor Technician J. Keith, Radioactive Waste Technician M. Haggerty, Industrial Nurse L

• Denotes those' attending the exit meeting.

2. Management Organization and Controls The licensee is authorized to use Special Nuclear Material (SNM) under license SNM-960 in accordance with representations and conditions contained in Appendix A, " License Conditions for the Vallecitos Nuclear Center," of the licensee's submittal dated April 20, 1984, except as modified by the conditions of this license.

A. Organizational Structure Section 4 of Appendix A of License SNM-960 requires that the functions of the criticality safety component and the radiation safety component shall exclude direct responsibility for operations involving the manufacture of nuclear products or processing nuclear materials.

The licensee's organizational structure is unchanged since the last inspection. A new Manager, Nuclear Safety has been appointed to fill the vacancy created by the retirement of the former manager.

B. Safety Committee Section 4.4 of the license conditions states that the functions of the Vallecitos Technological Safety Council (VTSC) shall include responsibility for review of reportable incidents, new facilities or major changes to facilities, and for contributing professional advice and counsel on criticality and radiation safety policy. The VTSC shall review annually the site safety and compliance program performance to include effluent releases and occupational exposures L

2 in terms of ALARA and focus on trends for corrective action if necessary.

The third quarter minutes of the VTSC were reviewed by the NRC inspector. The minutes reflected the VTSC's interest in maintaining safe operations. The committee did not. meet in the fourth quarter of 1985 because of a lack of topics to be addressed. A letter to this effect was in the file and was signed by the Manager, Nuclear Safety.

The-inspector noted there were no incident reports.for review since the September 1985 inspection. The inspector learned that the licensee had experienced a small fire in a waste package'that didn't involve any structures (see Section 8.D.). The manager responsible for the area investigated the fire, however, an incident report was not issued. The inspector suggested during the exit meeting that an incident report be. prepared. The licensee agreed to prepare the report.

No violations were identified.

3. Operator Training and Retraining

' Section 5.8 of Appendix A requirec Area Managers assure that new employees receive instruction in criticality safety, plant operating and emergency procedures prior to working with special nuclear materials.

The criticality safety training may be conducted with the radiation safety training. A written test shall be completed, evaluated and the results forwarded to the appropriate area manager.

The~ advanced radiological safety course was given as a self study course to a radiation worker. The worker completed the course and achieved a passing score on the written test. This closes item (85-02-01).

Since the disbanding of the formal fire brigade self-contained breathing apparatus'(SCBA) units have been placed in various buildings. The licensee subsequently identified four Building Emergency Team members needing training in SCBA. This potential violation was identified and expeditiously corrected by the licensee. The adequacy of the corrective action and the steps taken to preclude recurrence will be reviewed during the next inspection (86-01-01).

Fire extinguisher training was provided for all employees since the last inspection. Instruction included a classroom training movie, a lecture by the Site Fire Marshall, and practice in extinguishing a fire using a portable fire extinguisher. The California Division of Forestry (CDF) assisted with crowd control and backup during the fire fighting practice.

No violations were identified.

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l42 ccriticality' Safety- '

U- t ' . Sections- 5.0 and 6' 0.of Appendix A to License ' SNM-960 require assurance

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of criticality safety;through both administrative, t_echnical ~and analytical requirements.

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NucleaY Critical'ity ' Safety' Analyses '. - 1

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T' ~ Sectioli 5.5' of Appen' dix A requires that the manager of'the.

criticality. safety component shall' assure that the analyses in which

!. , an error in an analysis could lead to conditions that do not" fulfill the'doubleicontingency

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policy are identified and reviewed.

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,' NS new critdality safety analyses.of site operations were made

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renewal of DOT' Certificates of Compliance where fuel element. loads a .

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B. " Audit's5 " ~

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Section 5.7,of' Appendix' A requires that the radiation ' safety

., component and the criticality safety component conduct inspections

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. respective to' compliance with criticality control procedures. :Also, l.

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verification that operations conform to the. physical situations on which the calculations of criticality limits were based. Operations

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routinely processing more than one safe batch of fissionable-material shall be inspected on a quarterly basis. All operations H .- shall be inspected 'on an annual basis. '

.The' inspector. reviewed the licensee's internal ~ audits. The audits had been conducted as' required.

C. Facility Changes and Modifications No facility changes affecting criticality safety analyses-had been

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s No violations were identified.

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5. -Operations Review f

Section 2.2 of the license application states that the licensee's policy g

is to protect the employees, the public, and the environs from potential industrial,. radiation, and. nuclear hazards that could occur through activities conducted.in each component's facilities. Responsibility-for implementing this basic policy has been delegated through line managers

.to-the; manager and supervisor of each activity in which radioactive s materials.are-handled, used, or stored.

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4 Conduct of Operations A. Radioactive Materials Laboratory (RML)

The NRC inspector visited the site in January to observe the licensee's health physics practices during the RML Cell 2 floor

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cleanup. The licensee's planning and careful execution was evident and no poor health physics practices were observed. The cleanup

' operation was scheduled to startup again in mid-March for a final week of incell work after acquisition of a portable machine for use in clesning the cell walls. The licensee is using techniques that generate significantly less radioactive waste than the sand blasting used in previous years. The Cell 2 windows will be replaced in sequence with refurbished windows after the cleanup reduces the intell dose rate to the 5-10 mr/hr range. The post irradiation examination (PIE) work previously done in Cell 2 was transferred to Cell 3 to permit the Cell 2 cleanup and window replacement.

While touring the RML pool storage area the NRC inspector observed that a radioactive part was stored temporarily under a lead blanket on the pool deck in the locked, fenced, and posted high radiation area. The inspector requested a check of the dose rate on the other side of the wall behind the radioactive part. The dose rate measured was 5 mr/hr. The door controlling access to that area, the main entrance to the Chemical and Metallurgical Engineering Laboratory (CMEL), had been properly posted but the sign was no longer in place. The licensee indicated the sign removal had not been authorized and he immediately replaced it. The source of the radiation was by product material.

B. The inspector visited Building 400 and noted it had undergone a significant cleanup. Portions of the concrete floor had been removed for access to and removal of contaminated soil. Other portions of the concrete had been scabbled to remove surface contamination. The licensee was setting up' grids in preparation for making the final survey. The licensee plans to request an NRC overcheck.

C. The inspector observed that several of the laboratories in Building 103 have been cleaned and repainted. However, Room 210 appeared to need additional housekeeping (86-01-02).

No violations were identified.

6. Transportation / Radioactive Waste Management

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The licensee's program for packaging and transporting radioactive waste must be conducted in accordance with the requirements of 10 CFR Part 20.311 and Part 71.. Also, 10 CFR PartL61 requires that all radioactive waste prepared for disposal be classified in accordance with paragraph 61.55 and meet the waste characteristics requirements in paragraph 61.56.

The NRC inspector toured Hillside Storage, the radioactive waste storage area, and noted the licensee is converting to the use of metal containers

5 rather" than wooden boxes for Type A waste shipments. The inspector reviewed the licensee's procedures for packaging waste from the Remote Handling Operation (RH0). Packaging of the waste in expanded metal baskets had been observed during an earlier inspection. The licensee-imposes a 1000 R/hr unshielded -limit at the expanded metal- basket surface

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to assure meeting DOT's limit of 10 mr/hr at the cask surface. Grouting around the basket after its placement in an extended 17 H drum contributes significantly to this dose reduction. Curves have been generated to facilitate conversion of dose rate measurements on grouted containers to the radionuclide inventory. The curves used yielded a conservative result in an initial trial. The licensee anticipates the-

. curves.have the potential of reducing personnel exposures through reduced handling of grouted containers. The inspector reviewed the licensee's curve generation method and found it to be based on the use of ISOSHLD, a discrete source code for distributing sources through a volume, and RIBD a_ code accounting for the fission product inventory.

No violations were identified.

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

A. External Radiation Exposures The inspector's examination of the licensee's exposure records for the fourth quarter of 1986 disclosed that the highest whole body exposure for work within Cell 2 was 2350 mrem. The employee's NRC 4 and NRC 5 forms were current as were the forms for others for whom L ' authorization had been given for doses in excess of the quarterly limits in 10 CFR Part 20.101. Film badges for persons on a quarterly badge exchange frequency were processed immediately if they participated in a special project such as the Cell 2 cleanup.

Rush telephone reports were requested in such circumstances.

Dosimeters are used during these projects to facilitate controlling the total dose within the authorized limits.

B. Bioassay Results The licensee's urinalyses results for the fourth quarter of 1985 and the first quarter of 1986 were not available for review by the inspector because of difficulties within the contract laboratory's operations. The licensee learned the contract laboratory is back in normal operation and therefore expects to receive the analyses results shortly. The results will be reviewed during the next

-inspection (86-01-03).

C. Airborne Contamination During Cell 2 Cleanup The licensee used portable air samplers for assessing incell airborne contamination during the incell work. The highest incell airborne concentration did not exceed the Maximum Permissible Concentration (MPC) for a worker wearing the supplied air hoods.

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.- - 6 These ai'r hoods were used routinely during all incell work.

.Similarly, the access corridor airborne concentrations were also less than MPC for. workers wearing the full face mask required in the area. The inspector reviewed a sample of the medical records for

.the status of the respiratory protection physicals and found the

. physicals were current for users of respiratory protection equipment. The inspector's review of the airborna rencentrations in

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.the. operating gallery during the Cell 2 cleanup indicated airborne

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concentrations remained less than MPC.

No violations were identified.

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

A .- Tests and Drills The inspector observed three fire drills during the inspection. A fourth alarm was not a drill but was caused by a switch designed to signal the activation of one or more sprinkler heads on a sprinkler system. The switch was adjusted but the licensee is considering replacing it. The drills were well executed and the scenario for one . included the failure of an injured employee to leave a building.

The personnel accounting system identified the absence and identity of'the individual. The entry team located the injured person and requested the assistance of the onsite nurse. The nurse, being interviewed by the inspector at the time of the drill, promptly excused herself, picked up two kits and responded to the site of the emergency. Critiques were held after the drills. The findings and recommendations will be reviewed during the next inspection (86-01-04).

B. Pre-Plans The licensee is still preparing the Pre-Plans for the California Division of Forestry (CDF). The Pre-Plan format provided by the CDF results in a very detailed useful document. This item (85-02-03) will remain open until the Pre-Plans have been completed.

C. Training Fire extinguisher training was conducted in October of 1985.

Audiovisual and lecture presentations were followed by practice in extinguishing a pan fire and a cabinet fire with portable fire extinguishers. The CDF provided assistance during the fire extinguishing phase of the training. An examination was given after the training. During the site tour the inspector observed that three fire extinguishers in the RML Hot Shop were in need of their February 1986 monthly inspection. Only three days had passed.since the end of the month of February. No other fire extinguisher inspection oversights were observed. The fire extinguishers were subsequently inspected by the licensee. They will be checked again i

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. 7 during the next inspection (86-01-05). After the fire brigade was disbanded SCBA units had been added to building emergency kits. The licensee identified that'the SCBA training of four emergency team members was not current. Th'ose persons needing SCBA training have been scheduled for the training.

D. Fire Protection Two persons.used a fire hose from a nearby hose house to extinguish a fire in a waste package being loaded with items contaminated with by product material. No structures were involved in the fire. The licensee had investigated the fire but had not prepared a written report. The licensee agreed to prepare a report. The report will be reviewed during the next inspection (86-01-06).

No violations were identified.

9. Environmental Protection The licensee has been authorized, pursuant to 10 CFR 20.106(b), to release radioactive materials in accordance with Section 8.11, " Airborne Effluent Control," of Appendix A of the application. Additionally, license condition 14 requires the licensee to provide the NRC copies of its annual report summarizing the effluent monitoring and environmental surveillance programs at the Vallecitos Nuclear Center.

-The licensee's semiannual effluent monitoring reports were examined by the inspector. The releases were within regulatory limits. Twelve NRC environmental samples collected both onsite and offsite were measured at.

the Department of Energy's Radiological and Environmental Sciences Laboratory (RESL) at the Idaho Nuclear Engineering Laboratory (INEL).

The measurement-results are included in Table 1. The results indicate stream bed and soil contamination levels below NRC limits for release to unrestricted use except for the gross alpha result from one onsite sample, NRC-8. The licensee's analysis of their portion of the sample gave a result.less than NRC release limits. Additional samples will be taken by NRC at and around the area from which NRC-8 was taken t

(86-01-07).

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No violations were identified.

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

Thetopicsinclyded:

the~ areas ~ inspected the licensee's ' identification of the need for respiratory protection

! training for four building emergency response personnel status of open items 4

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closed: 85-02-01 Advanced radiation safety course 85-02-02 Fire fighting training open: 85-02-03 Pre-Plans for the CDF (progress was evident)

.new: 86-01-01 SCBA training review

. 86-01-02 Housekeeping in Room 210 of Building.103 86-01-C3 Review 4th-quarter 1985 and 1st quarter 1986 bioassayeresults 86-01-04 Review critiques of three drills and one alarm occurring during this inspection 86-01-05 Fire extinguisher inspection followup 86-01-06 Review the report on the waste package fire

• 86-01-07 Resample NRC-8 because of the gross alpha result Cell 2 cleanup observations and record review Fire drills and critiques Documenting the results of the investigation of fires A*

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_ Measurement basis for the determination of waste packages radionuclide inventories Improved storage and control of Pu sources Status of preparation of Building 400 for a final survey and an independent NRC overcheck The licensee comments included:

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Fire extinguishers would be checked as required by the procedures.

The licensee noted that the sprinkler system and fire insurance precluded the need to fight other than incipient fires.

The need for approval for radiation safety _ posting removal will be reemphasized.

The fire investigation will be documented.

Areas at risk have been significantly reduced by consolidation of activities in buildings with sprinklers.

• This item was not discussed during the exit meeting but is listed here for convenience.

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-TABLE I EESL Analysis of NRC Environmental Samples Taken.

. On or Near the General Electric Vallecitos Nuclear Center

~(pCi/g'(dry)'i 1 sigma)

(Sample. Gross Gross No. Location Alpha. Beta Pu

'238 239,240

, Pu U*_ Cs-137

-Franco Pond 7i2 22i8 0.005210.0014 0.002210.0010 9.2 2.5610.06 NRC-1

- NRC Vallecitos 712 1116 0.0016i0.0010 0.003810.0012 1.3. 0.0810.01

,- Creek

.NRC-3 Rodeo Grounds 913 .1715 0.000610.0009 0.001610.0009- 5.2 0.0510.01 Creek

'NRC-4 ' Dry Stream 712' 1615 0.002110.0010 0.002310.0011 1.90.0810.03 Bed NRC-5 Weir Box 312 1314 0.000210.0008 -0.000610.0010 1.2 1.0110.03 Culvert.

NRC-6 La'e s Lee 512 1516 0.001210.0009 0.000910.0009 1.4 0.2210.03 NRC-7 E. of Bldg. '612 2216 0.006610.0015 0.003610.0003. 2.7 3'.0110.06

'102F-NRC-8 E.~of Bldg. 60110 2517 0.0006 0.0008 0.005410.0013 5.-l' O.6410.03 <

102G

-NRC-9 =40' S. of 512 1315 .0.001410.0009 0.00910.002 1.2 0.2610.02 iMet. Sta.

- NRC-10 1100' NNW of .912 2315 0.002910.0012 0.004410.0013 0 0.51io.03

'Sta. 3 NRC-11 -40' W of' - 912 . 1215 -0.000710.0009 0.003810.0012 0.8 0.17i0.01 L " '

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' NRC-12 20' W of. 813 1515 0.0002i0.0010 0.005710.0015 2.1 0.2110.01 Sta.14 Calculated.from the reported gamma spectra.

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