ML20213G238
| ML20213G238 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 05/08/1987 |
| From: | Brock B, Thomas R, Zurakowski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20213G232 | List: |
| References | |
| 70-0754-87-01, 70-754-87-1, NUDOCS 8705180200 | |
| Download: ML20213G238 (12) | |
Text
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s U. S. NUCLEAR REGULATORY COMMISSION REGION V ,
Report No. 70-754/87-01 Docket No.70-754 License No. SNM-960 Safeguards Group: 1 Licensee: General Electric Company Vallecitos Nuclear Center P. O. Box 460 Pleasanton, California 94566 Facility Name: Vallecitos Nuclear Center Inspection at: Pleasanton, California Inspection Conducted: A ril 7-10, and 21, 1987 Inspected by: . Wb 7
- 8. L. Brock, Fuel facilities Inspector Date Signed 22 %& &
P. (R. ZdraKowski, Radladon Specialist s/2k 7 Date Signed' Approved by: Mbr R. D. Thomas, Chief 8////
Date' Signed Nuclear. Materials Safety Section Summary:
Inspection on April 7-10, and 21, 1987 (Report No. 70-754/87-01)
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, environmental protection, and emergency preparedness.
During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 86740/84850, 83822, 88045 and 88050 were covered by two NRC inspectors.
Results: No violations were identified in the nine subject areas inspected.
B705180200 870511 PDR ADOCK 070 4
DETAILS
- 1. Persons Contacted A. General Electric Company
- R. W. Darmitzel, Manager, Irradiation Processing Operation
- J. H. Cherb, Manager, Nuclear Safety R. B. Adamson, Manager, Fuel Materials Technology C. P. Ruiz, Manager, Process and Radiation Chemistry
- G. E. Cunningham, Senior Licensing Engineer J. I. Tenorio, Manager, Remota Handling Operations J. Nixon, Specialist, Safeguards R. F. Bagley, Specialist, Radwaste Processing Operation F. A. Arit, Supervisor, Maintenance and Chemistry E. J. Strain, Compliance Engineer D. C. Bowden, Senior Engineer, Nuclear Safety B. M. Murray, Radiological Engineer C. Delisle, Radiation Monitor Technician J. Keith, Radiological Waste Technician E. Hagberg, Specialist Facilities Protection M. Hagerty, Industrial Nurse R. W. Warner, Scanning Electron Microscope Technologist III B. Offsite Agency S. O'Brien, Engineer, California Division of Forestry J. Estrada, Fireman, California Division of Forestry
- Denotes those attending the exit meeting.
- 2. Management Oraanization 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. Organtrational 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 manufacturer of nuclear products or processing nuclear materials.
The licensee's organizational structure appears to meet the license requirement with regard to independence of the criticality and radiation safety components from the manufacturing of nuclear products or the processing of nuclear materials.
2 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 in terms of ALARA and focus on trends for corrective action if necessary.
The VTSC met quarterly since the last inspection. The license was recently amended to clarify that the VTSC could choose not to meet in any calendar quarter so long as they notified the Manager, Irradiation Processing Operation in writing. The VTSC completed the part of open item (86-02-01) relating to the review of the Industrial Health and Safety audit frequency. Progress has been made on the other part related to the installation of higher sensitivity hand and foot counters at the Radioactive Materials Laboratory (RML). This item (86-02-01) will remain open pending completion of the installation of the more sensitive counters. The review of current and near term operations indicated the licensee's radiological safety program was marginally staffed and would be jeopardized by any staff reductions in this essential area (see Section 6.E. for details). The inspector's review of the VTSC minutes for the first quarter of 1987 (received April 21, 1987) indicated the VTSC's review of the non-reportable incidents found them adequately addressed. The VTSC did not express concern about the marginal staffing level perhaps because the potential loss of an experienced monitor did not develop until after the VTSC meeting.
The VTSC is charged with providing professional advice and counsel on radiation safety policy and staffing level adequacy. As projects at the site diminish the VTSC should be on the record for assuring that an appropriate safety staffing level will be maintained.
No violations were identified.
- 3. Operator Training and Retraining Section 7.3 of Appendix A requires that all personnel working in radioactive materials areas or in radiation areas shall receive an indoctrination lecture prior to starting work followed by additional training, including periodic retraining, commensurate with the work environment as determined by the area manager.
In one non-reportable incident the licensee's investigation noted that the incident resulted from a trained workers failure to follow the clothing requirements of the applicable Radiation Work Permit (RWP). The workers effort to undertake the task without the appropriate support is consistent with a need for reemphasizing the importance of radiation safety and the need for practices to follow procedures. This is particularly important when site operations are declining and staff reductions are taking place. The need to reemphasize the importance of
3 radiation safety was also demonstrated by a second incident in which inadequate control, insufficient shielding, and a lack of communication resulted in unexpected exposures to two employees (see Section 6.D. for details). The licensee's corrective action included review of the incidents in special meetings and the monthly safety meetings as well as preparation of appropriate procedures. The licensee's effectiveness in reemphasizing the importance of radiation safety and the provision of retraining commensurate with the work environment will be reviewed in the next inspection (87-01-01).
No violations involving NRC licensed materials were identified.
- 4. Criticality Safety Sections 5.0 and 6.0 of Appendix A to License SNM-960 require assurance of criticality safety through both administrative, technical and analytical requirements.
A. Nuclear Criticality Safety Analyses
- 1) The license previously required in Section 4.2.3 of Appendix A, that the manager of the criticality safety component have sufficient expertise in the field of criticality safety to provide the review functions of Section 5.5 of Appendix A.
This requirement of the manager of the criticality safety component was deleted by license amendment (No. 1) dated February 3, 1987. Section 5.5 was als. revised by the same amendment to require the manager of tr.o criticality safety component to assure that the results of criticality analyses are reviewed (he no longer evaluates which criticality analyses require reviews, rather he assures they all are reviewed).
- 2) The Criticality Limit Area (CLA) in Building 102J was relocated to Building 104 and designated CLA-2. The relocation was made under an appropriately reviewed and approved Change Authorization (CA). No additional criticality analysis was required because the CLA is restricted to Storage of Fissile Class I containers in an area isolated by a twelve foot required separation from CLA-1.
- 3) A criticality analysis arendment was made to permit storage of less than 15 milligrams of Californium 252 in Cell 3 without having to remove all other special nuclear ma',erial (SNM) from the cell. The cell limits and bases for them were clearly delineated. The amendment was reviewed as required by Section 5.5 of Appendix A of SNM-960.
- 4) The licensee was reminded that documentation of a review should be in sufficient detail to permit an assessment of the adequacy of the review.
- 5) The cleaned up Cell 2 is expected to be set up as a single CLA instead of two CLAs as previously existed.
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- 6) The Control Data Corporation (CDC) computer previously used for modeling and analysis is no longer available. The Standardized Computer Analyses for Licensing Evaluation (SCALE) tapes have been received and are currently being checked on the GE VAX computer in San Jose. Proposed design changes for the GE-2000 series cask is driving the effort to establish the computer l
analysis capability. Early work on the system will include cask shieldf rig calculations.
B. Audits Section 5.7 of Appendix A requires that the radiation safety component and the criticality safety component conduct inspections j respective to compliance with criticality control procedures and l verification that operations conform to the physical situations on which the calculations of criticality limits were based. Operations l routinely processing more than one safe batch of fissionable l material shall be inspected on a quarterly basis. All operations shall be inspected on an annual basis.
The NRC inspector's review found that the inspections by radiation safety and the audits by criticality safety were completed at the frequencies required. No poor criticality safety practices were observed.
No violations were identified.
- 5. Operations Review Section 2.2 of the license application states that the licensee's policy 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 materials are handled, used, or stored.
Conduct of Operations A. Radioactive Materials Laboratory (RML)
Cell I was being prepared for cleanup of its windows. The Co-60 l
inventory was being stored in casks and in the storage pool to facilitate the window cleanup. The cell will be returned to Co-60 service after completion of the servicing of its windows.
The cleanup of Cell 2 had been completed and the Scanning Electron Microscope (SEM) had been installed. The SEM was scheduled for some servicing for resolution improvement by a factory serviceman. The serviceman would remain outside the cell and a GE employee within the cell would make the adjustments following the serviceman's directions.
5 Cell 3 was in normal operation. An irradiated fuel rod recently sampled for Post Irradiation Examinaticn (PIE) had just been resealed (by welding). The welding machine (used in the cell 3 airlock) was decontaminated before packaging it for storage.
Cell 4 had been used for sampling and reassembly of the irradiated fuel rod. The small lathe used for the sampling and reassembly work will also be decontaminated and stored for future use.
Removal of a paddle (a cask containing the irradiated reassembled rod) from the R.ML dock for transport to the Nuclear Test Reactor (NTR) for non-destructive testing by neutron radiography was observed. No poor health physics practices were noted. The transfer from the dock was made with due caution. Safe practices in using the heavy machinery was evident. The Radiation Monitor received the full cooperation of the two heavy equipment operators as he went about wipe testing various parts of the cask at the exchange point.
The solid waste handling operation is planning to add a shredder in an effort to improve the waste volume reduction. The shredder is not expected to be used for shredding 55 gallon druns, rather its use will be restricted to materials from which metal has been removed. The licensee recognizes the need for and is planning modifications to the ventilation system to accommodate the shredder.
An evaluation for air sampling modifications will also be made.
B. Hillside Storage Yard The Hillside Storage Yard reflects the licensee's cleanup effort.
Various containers and parts that have been stored unused for relatively long periods have been disposed of as radioactive waste.
A few more such items are scheduled for disposal. The improvement in the organization of stored containers is readily apparent.
C. Liquid Waste Evaporation Facility (LWEF)
The radioactive liquid waste generation rate now requires the LWEF to operate only about half time. Therefore, only a few barrels of solidified sludge are generated per month.
D. Liquid Waste Treatment Systems
- 1) The sewage generated onsite does not flow offsite. The onsite sewage treatment results in separation of the solids which after sampling are periodically hauled away for appropriate disposal. The Treated liquid also sampled is used for onsite spray irrigation. Onsite storage basins are available for retention if necessary.
- 2) The industrial liquid is collected in alternate storage basins and sampled. It is released offsite to Vallecitos Creek via a weir box (for solids collection) unless sample results require
6 its disposal through the LWEF. The solids collected in the weir box are sampled to facilitate appropriate disposal.
E. Buildina 400 It was noted during the visit to Building 400 that some areas being prepared for the licensee's final survey needed to have some plywood panels removed to facilitate surveying the wall surface. The licensee agreed to remove the panels. Current plans are to survey the High Bay last, after closing off the other cleaned and surveyed areas of the building. The licensee's final survey of this building is subject to some delay because of the higher priority now given to the project involving removal of the cooling towers previously used by EVESR and VBWR. Consideration is being given to separating the wood which meets the release limits from that requiring disposal to radioactive waste in an effort to control the volume.
F. Butidina 103 Significant improvement in the housekeeping in Roos 210 warrants closing item (86-01-02). It was noted that a fire extinguisher was not on the fire extinguisher holder in the laboratory in Room 112.
Subsequent review with the Fire Marshall confirmed that the fire extinguisher was not missing but a recent evaluation resulted in the decision to relocate it just outside the laboratory door. The former holder was not removed and didn't present a fire extinguisher inspection problem because of the use of a fire extinguisher locator file to facilitate the inspections.
No poor health physics practices were noted during the operations review and no violations were identified.
- 6. Radiation Protection Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.
A. External Radiation Exposures Exposure records for all of 1986 and the first quarter of 1987 were examined by the inspector. Particular emphasis was placed on the examination of exposure records of employees involved in the nonreportable incidents discussed below. No exposure exceeded licensee administrative or regulatory limits. As expected the highest exposures were received during the very extensive cleanup of Cell No. 2. A high quarterly exposure of 2400 mrem was noted in records. Complete NRC-4 and 5 information was found to be recorded for this individual.
B. Bioassay Results Examination of all uranium and plutonium urinalyses for 1986 and those available for the 1st quarter of 1987 were examined by the inspector. There were no significant positive results.
7 C. Whole Body Count A whole body count of the person involved in the nonreportable incident discussed below disclosed a whole body deposition of 0.075 uCi Cs-137 and a Co-60 lung deposition of 0.012 uCi. These numbers indicate less than one percent of a body burden for both of the above mentioned isotopes.
D. Nonreportable Incident Review Two nonreportable incidents which occurred during the 3rd quarter 1986 and the 1st quarter 1987 respectively were reviewed in detail.
The first nonreportable incident involved an employee who entered Cell No. 2 to perform a painting job. After exiting from the cell contamination levels of 3,000 to 40,000 c/m beta gamma were detected on the hands and beard of the employee. Decontamination efforts were successful and his film badge was sent in for analysis.
Urinalysis tests and a whole body count were also performed. These analyses indicated that the employee had not received internal or external exposures in excess of administrative or regulatory limits.
Soon after the incident, the licensee formed an Investigating Committee to determine the cause of the occurrence and recommend corrective action to prevent recurrence. This committee identified six deviations from Remote Handling Operation (RHO) procedures and the RWP and made appropriate recommendations to prevent recurrence.
The second nonreportable incident involved the exposure of two Itcensee employees to c.eutron radiation from Cf-252 while performing work in the Cell No. 3 interlock area. A careful examination of the 4
conditions that existed during the exposures and subsequent calculations by the licensee resulted in a neutron dose of 750 mrem and 270 mrem respectively to the two employees. No exposure limits
- were exceeded during these occurrences.
4 As in the first nonreportable incident, a committee was formed by the licensee to investigate the incident and make recommendations to insure that the occurrence did not happen again.
One of the recommendations stated that a new procedure entitled "Cf-252 Controls" shall be written which will address the concerns expressed by the Committee. This procedure and other concerns expressed by the Committee will be reviewed during the next inspection (87-01-02).
E. Some important conclusions related to the two occurrences made by the inspector are as follows:
- 1. Good health physics controls were not fully implemented during either occurrence.
- 2. A review of dosimetry records and the licensee's performance in i this area during the past few years indicated that these incidents were isolated cases and not generic in nature.
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- 3. Olscussions with personnel and observations by the inspectors indicated that the licensee is now operating with a very minimal health physics staff.
- 4. There was some evidence that the one HP Technician at this large and busy hot cell facility could fail to implement proper ;
health physics contrc,1s simply because he can not be in two places at the same time.
- 5. For a hot cell facility of this size, a full time, fully trained back up health physicist is also needed during periods when the duty health physicist is on leave, needs help on a particular busy day, or has been given another short term assignment.
Olscussions with management at the exit interview disclosed that they agreed with the inspectors on these points.
The violations identified by the licensee (failures to follow procedures) were handled in a manner meeting the enforcement policy in 10 CFR Part 2, therefore NRC did not cite the licensee. No violations were identified by the NRC inspectors.
- 7. 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 licensee's Compliance Enginu r now reviews the responses to ,
assignments from drill critiqucs on a quarterly basis rather than on '
an annual basis. This significantly shortened review period warrants closure of item (86-02-02). It was previously noted that the licensee's practice was to expeditiously complete the assigned i tasks, however, documentation of the completion was lagging. The shorter review period however precludes an oversight remaining unrecognized for up to a year. i
- 8. Pre-Plans The inspector visited the California Olvision of Forestry (C0F),
which has the first alarm response obligation, and verified that they received the first six completed Pre-Plans. Four Pre-Plans are still in process therefore item (85-02-03) will remain open.
Building 102 Pre-Plan is to be completed next. The C0F indicated ,
the completed Prr Plans met their naeds with regard to contents. :
The licensee indicated that the Alameda County Fire Department (a !
part of the Hutual Aid response) also was provided with a copy of the wix completed Pre-Plans. Hazardous materials information includes an inventory by location that is available to the Specialists Facilities Protection. The C0F depends on the !
Specialist on duty to provide a warning of hazardous materials to be encountered in particular locations. The hazardous material
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inventory is updated annually. The Manager of Industrial Safety and Hygiene located in San Jose is responsible for the Hazardous Materials Program.
t C. Fire Protection l
l 1) The forty-five fire extinguisher inspection tags checked during the inspection were current. The licensee's fire extinguisher locator file continues to be used effectively.
- 2) The licensee plans to reinstitute use of the C0F in ' hands on' portable fire extinguisher training before the end of the year.
l 3) The inspector noted that although the CDF had several of its l staff (2 units, 4 people) accept the licenset's invitation to revisit the site, the two staff members on dtty during the inspector's visit at the CDF station had not yet visited the licensee's site. This anomaly was addressed in the exit meeting to facilitate corrective action. The licensee's response will be reviewed during the next inspection (87-01-03).
- 4) The licensee stated that fire hoses in Building 103 had been lengthened to facilitate extinguishing stairwell fires.
l 5) The licensee keeps a monthly record of fire protection
! equipment inspections. A red tag system is used to identify l equipment out of service. Appropriate supporting documentation I
and appropriate notification of the factory Mutual Insurance Company is given for the removal and return to service for
- those portions of the fire protection system.
D. Medical l The Itcensee and the Valley Memorial Hospital (VMH) have been in closer contact since the previous inspection. The letter committing VMH to provide medical support to the licensee was reviewed by VMH i and approved for 1986 and 1987. The licensee's Medical Director terminated and Emergency Response (medical) has been assigned to the Occupational Health Nurse. A contract doctor is now provided to the licensee's site for about four hours per week. The inspector noted that there is a need for additional interfacing between VMH and the licensee particularly in the area of tests and del 11s. There is a notable lack of information with regard to the adequacy of the
- support the two organizations will provide and can expect from each I other. Closer and more frequent interfacing such as drills would i help assess the adequacy of current plans. The inspector's question l
regarding the point at which the hospital would be notified of the possible receipt of a contaminated injured person was met with conflicting responses. This and other important questions such as the number of Radiation Monitors the licensee would provide versus the number VMH feels it needs could receive a better answer based on the experience gained from a dell 1. The licensee's progress in this area will be reviewed during the next inspection (87-01-04).
10 No violations were identified.
- 8. Environmental Protection The ifcensee 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 licenses to provide the NRC with copies of the annual report summarizing the effluent monitoring and environmental surveillance programs at the Vallecitos Nuclear Center.
The licensee's annual report summarizing the results of effluent monitoring and environmental surveillance programs was submitted as required. The report indicates that the measurements confirmed that the licensee's releases though slightly higher than last year were well within NRC release Ilmits.
No violations were identified.
- 9. Exit Meetina The results of the inspection were discussed with members of the IIcensee's staff identified in Section 1.
The topics included:
The areas inspected.
The decontamination status of Building 400.
Independence in the review of the Radiological Contingency Plan and the assessment of drills.
NRC concern about the radiation safety program staffing level.
Issuance of the license amendment resolving the items regarding the responsibility of the Manager, Nuclear Safety and the VTSC quarterly meetings.
The status of open items.
Closed: (86-01-02) llousekeeping in Room 210 of Dullding 103.
(86-02 02) Drill critique followup and timeliness of corrective actions.
Open: (85-02-03) Pro-Plans for the C0F.
(86-02-01) Followup on one of two VTSC recommendations.
11 New: (87-01-01) Review the licensee's effectiveness in reemphasizing the importance of radiation safety and providing retraining commensurate with the work environment.
(87-01-02) Review the new Cf-252 procedure and related practices.
(87-01-03) Review the licensee's efforts to assure the 1
C0F fire fighters become familiar with the site.
(87-01-04) Review the improvement in interfacing between the licensee and VMH, The licensee's comments included:
Radiation safety staffing would not be reduced in the hot cell area.
Some communication problems have developed where radio interference occurs for short periods but an alternate system can be used during emergencies.
Second party reviews of new criticality analyses will provide 1 sufficient dr. tail to permit an evaluation of the adequacy of the review, i
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