ML20215N845

Insp Rept 70-0754/86-02 on 860908-18.No Violations Noted. Major Areas Inspected:Mgt Organization & Controls,Operator Training & Retraining,Criticality Safety,Operations Review & Transportation/Radwaste Mgt

ML20215N845
Person / Time
Site:	07000754
Issue date:	10/30/1986
From:	Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20215N839	List: ML20215N838 ML20215N845
References
70-0754-86-02, 70-754-86-2, NUDOCS 8611070335
Download: ML20215N845 (9)

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U. S. NUCLEAR REGULATORY COMMISSION l

REGION V l

, Report No. 70-754/86-02 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: September 8-18, 1986 Inspected by: -

8. L. Brock, Fuel Facilities Inspector

/d d M Date Signed Approved by: ,

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R. D. Thomas, Chief Ef/ Date Signed Nuclear Materials Sarety Section Summary:

Inspection on September 8-18, 1986 (Report No. 70-754/86-02)

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, 83822, 88045 and 88050 were covered by one NRC inspector.

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

8611070335 861031 PDR ADOCK 07000754 C PDR

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.}J' DETAILS f

1. Persons' Contacted

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• R. W. Darmitzel, Manager, Irradiation P.rocessing Operation.

, *J. H. Cherb', Manager, Nuclear Safety C.~ P; Ruiz,' Manager, Process.and Radiation Chemistry

• G. E. Cunningham,. Senior: Licensing Engineer:

J. I. Tenorio, Manager,' Remote Handling Operations J. Nixon, Specialist, Safeguards.

R. F. Bagley, Specialist,-Facilities Protection F. A. Arlt, _ Supervisor, Maintenance and Carpentry E. J. Strain, Compliance Engineer

-D. C. Bowden, Senior Engineer, Nuclear Safety

.R. Remmer, Radiation Technician <

B. M.' Murray, Radiological Engineer C. Delisle, Radiation Monitor Technician C. A. Bayles, Security Officer D. G.:Hallquist, Specialist, Facilities Protection E. J. Colonna, Chief Engine'er, Valley Memorial Hospital Gi Pisano, Battalion' Chief, California Division of Forestry C. Stanley, Captain, California Division of Forestry

• Denotes those attending the exit meeting.

- 2. - Management Organization and Controls The licensee is authorized to use Special Nuclear Material-(SNM) under

~licenselSNM-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 essentially unchanged since the last inspection. Another new Manager, Nuclear Safety has been appointed effective. September 1, 1986. Additionally, the

. Radiological Engineer is now responsible for the criticality safety component functions.

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B. Saf'ety Committee

-Section 4.4 of the license conditions states that the functions of the'Vallecitos Technological Safety Council (VTSC) shall include- i responsibility for review of reportable incidents, new facilities or

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2 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 inspector reviewed the minutes of the VTSC for the first quarter 1986 and noted that the VTSC review of the 1985 activities of the Nuclear Safety function resulted in two recommendations. The licensee's followup on the' recommendations will be reviewed during the next inspection (86-02-01).

The inspector reviewed licensee incident reports and found the incidents were appropriately documented, investigated, corrected and action was taken to preclude recurrence. The reports were appropriately distributed.

The inspector also reviewed the licensee's report of the waste package. fire of items contaminated with by product material. The licensee's report prepared December 27, 1985 (not an incident report) was distributed to the Manager Nuclear Safety and the Site Fire Marshall. This closes item 86-01-06.

No violations were identified.

3. Operator Training and Retraining Section 5.8 of Appendix A requires 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 licensee adequately followed up on providing retraining to SCBA users. Appropriate steps precluding recurrence of the failure to provide the required SCBA retraining were taken. This closed item 86-01-01.

The former Senior Engineer, Nuclear Safety provided special training in criticality safety to the Radiological Engineer and the Senior Licensing-Engineer (see Section 4).

No violations 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

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Section 5.5 of Appendix 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 double contingency policy are identified and reviewed.

1) The new Manager, Nuclear Safety stated that all criticality.

analyses will be reviewed by qualified reviewers to assure the double contingency policy is fulfilled. A related unresolved item currently being discussed with Licensing involves the qualifications for the position of the manager of the criticality safety component (Section 4.2.3 of Appendix A to license SNM-960). The licensee subsequently. committed to submitting an application for a license amendment clarifying this section of the appendix to the license. The resolution of this item will be included in the next inspection report.

2) The functions of the vacated position of Senior Engineer, Nuclear' Safety have been assigned to the Radiological Engineer.

Criticality ~ Specialist' training had been given to the Radiological Engineer from November 1984 through May 1986. The Senior Licensing Engineer who served four years as the Criticality Specialist (1967-1971) joined some of the half hour daily classes given from September 1985 through May 1986.

Additionally the Radiological Engineer attended the Nuclear Criticality Safety course given by the University of New Mexico in May 1985. The inspector emphasized that the license required in Appendix A Section 4.2.2 that "should the criticality safety component lack the one year of experience, all analyses for the interim period until the experience is achieved shall be verified by two of the individuals described in 5.5 or by the physics advice function in 5.4 of this Appendix". The licensee stated that this requirement would be met.

B. Audits Section 5.7 of Appendix A requires that the radiation safety component and the criticality safety component conduct inspections.

respective to' compliance with criticality control procedures and

' verification that operations conform to the physical situations on which the calculations of criticality limits were based. Operations routinely processing more than one safe batch of fissionable

. material shall be inspected on a quarterly basis. All operations shall be inspected'on an annual _ basis.

The inspector reviewed the licensee's internal audits. The required u criticality safety audits had been conducted by the Radiological Engineer whose functions now include criticality safety.

No violations'were identified.

5. Operations Review

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-Sectionf2.2o'f,thh..licenseapplicationstatesthatthelicensee'spolicy

-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. .Respons.ibility 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.

JConduct'of Operations

'A. Radioactive Materials Laboratory (RML)

The licensee' finished cleaning the Cell 2 floor and walls. ~ No.

overexposure occurred during the carefully orchestrated project.~

'The 'resulting in-cell dose rate of 200.ar/hr was not as low as i expected. ' The back wall of the cell was- then covered to about an' 8 ft. height with 2. inch thick. steel plate _ shielding to further reduce the in-cell dose rate. 'The_ affect of the shielding lowered the in-cell dose rate to an acceptable level of 50 mr/hr. During the

inspection the cell windows were being removed for cleaning. The windows will be reinstalled after they've been cleaned.

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B. Building 400

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The inspectors visited Building 400'and noted evidence'of the i licensee',s:recent. surveys. It-was also noted that one area outside

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the building where a below grade tank had been removed had been back f

filled with gravel and reinforcing. rods were in place. . The' inspectors pointed out that since the hole had_ contained a tank.that

' stored ~ radioactive 1i. quid waste-the NRC would need to survey the~

4 hole and take soil samples as part of the independent overcheck of

the licensee's survey = report. The licensee agreed.not to pour the concrete' slab until the NRC sampling was completed. The licensee requested that Region V consider doing the overcheck of_ Building 4'00

- in two' phases. Phase I would include the tank shelter outside along 1

, the south wall'of' Building 400. Phase II would include the other parts of auilding~400 where radioactive material had been used.

i' Completing Phase I would permit filling the hole and pouring

i. concrete to prevent rainwater from running-into'the highbay of the l Building through a hole made to: remove the drain line that led from-the highbay to the underground storage-tank. The licensee's survey report was received after the inspection. The NRC independent

- overcheck of the hole and tank storage. area (Phase I) will-be done during the week of October 26,.1986.

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. C .- Building 103 i

The inspector visited Room 210 of Building 103 and noted it was still in need of housekeeping. The Manager of Process and Radiation Chemistry explained that a system temporarily undergoing test in the g room delayed effective housekeeping. The test was scheduled for t completion the week following the-inspection and the' room would th'en ,

4 receive the needed housekeeping. A work order had been placed for j significant refurbishing of the room, including some repainting,.but f

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starting this much larger project is' more than a few weeks away.

The housekeeping status remains an open item (86-01-02).

No violations were identified.

6. Transportation / Radioactive Waste Management-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 Part 61 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 inspectors toured the Hillside Storage Facility (HSF). The storage facilities within the HSF were described for the visiting Region V Nuclear Materials Safety and Safeguards Branch Chief. The Bunker storage at HSF includes about 42. containers of >100 nCi/g transuranic (TRU) waste About five percent of the waste consists of solidified burnup dissolution samples and metallographic cell cutting and polishing wastes; the remaining 95 percent consists of the sampled irradiated test fuel rods. Cleanup of Cell 4 will produce more TRU waste (some of this TRU waste is stored in containers in the Cell). The capacity of the HSF Bunker is adequate for the storage of this TRU waste (the waste is generated.in small quantities). The licensee expects it will be several years before shipment of this TRU waste containing >100 nCi/g will be authorized.

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The inspectors observed that the licensee used good health physics practices while removing drums from their storage locations and loading them in a: shielded container for shipment to an authorized waste burial site.

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 review of the licensee's exposure records identified the highest whole body exposure for the first quarter of 1986 as 2400 mrem. The exposure was for work in the Cell 2 cleanup project.

The employee's NRC-4 and NRC-5 forms were current.

The licensee is reviewing the visitor film badge results. Visitor film badges are reading about 40 mrem where previously they read 0 '

mrem. The licensee's review of visitor on-site activities support the conclusion that appropriate exposure record adjustments need to be requested. The NRC inspector pointed out that inclusion of some control badges in the licensee's film badge. program could provide definitive support for such requests.

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B. Bioassay Results s '

The previously unavailable uranium urinalysis data for the fourth quarter of 1985 and the first quarter of 1986 were examined by the inspector along with the data for the second and third quarters of 1986. The examination indicated there were no significant

, ex, p,osures.

3-The inspector's examination of the plutonium urinalysis data

.m 4 indicated no positive results.

g The review of the previously unavailable bioassay data closes item x s. 86-01-03.

Novjolationswereidentified.

s 8.- Emergency Preparedness s Section 4;9 of the license application addresses the plans for a prompt

, . response to various types of emergencies.

, , i Y A. Tests and Drills

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The inspector reviewed the critiques of the drills held during the previous inspection. The critiques were all held shortly after the drills and were thorough. This closes item 86-01-04. Most items were expeditiously corrected, however documentation reflecting the followup corrective action sometimes lagged. The Compliance Engineer annually reviews the responses to the recommendations and sends a memo to the line managers supervision identifying late i responses which most often are a failure to provide the documentation of corrective actions already taken. It appears however;that where corrective action had not in fact been completed

, 3 it may'not be identified for almost a year. Followup of

^ recommendations should be on a shorter interval. This will be reviewed during the next inspection (86-02-02).

1 IL Pre-Plans The licensee has made significant progress'towards. completing the Emergency Response Pre-Plans for the California Division of Forestry (CDF). The licensee plans to provide the CDF with the Pre-Plans.

already completed. The remaining Pre-Plans will be provided to the CDF as they are finished. This item (85-02-03) remains open pending

, completion of all of the Pre-Plans.

C. Fire Protection s

1) The licensee has instituted use of'a fire extinguisher checklist to preclude oversights in checking fire extinguishers. The inspector found fire extinguisher inspections were current. Item 86-01-05 is therefore closed.

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( 2) The' inspector interviewed two CDF officers, a 8attalion Chief-l and a Captain, independently. The need for completion of the l Emergency Response Pre-Plans was expressed by both CDF L 3 officers. As mentioned earlier (Section 8.B.) significant

}. , progress has been made towards completing the Pre-Plans.

Additionally, the licensee plans to provide the CDF the six Pre-Plans that have been completed. The others will be provided as they are finished.

D. Medical The inspector. visited the Valley Memorial Hospital (VMH) and interviewed the Chief Engineer who is the liaison for VMH disaster planning. It appeared that increased communication between the licensee and VMH is needed. Although the licensee indicated the Vallecitos Nuclear Center (VNC) Medical Director was the principal' contact with the VMH, the inspector provided the VMH Chief Engineett with'the'. telephone number of a contact at the licensee's site. -

Additionally, the VNC Emergency Response Coordinator was provided' ,

with the telephone number of the VMH Chief Engineer.

3 The licensee did.have a chance recently to view a video tape of a VMH disaster drill. The Chief Engineer VMH expressea interest in including the licensee periodically in a drill.

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 indicated releases less than regulatory limits. Twelve NRC environmental samples reported in Table 1 of inspection report 70-734/86-01 included one sample, NRC-8, for which the gross' alpha resulted reported, 60110 pCi/g, was not consistent with the other results. Remeasurement of this sample was requested. Two different size aliquots of this sample were subsequently measured and yielded identical results of 1013 pCi/g. These results, recently received, were significantly'different from the first result of 60110 pCi/g and were consistent with the average of the gross alpha results reported for the other eleven samples (712 pCi/g).- These latter measurements of sample NRC-8 are less than NRC release limits and are in agreement with the licensee's value of <13 pCi/g reported from their analysis of their portion of the same sample. Prior to receipt of the

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NRC sample remeasurements, the inspector took three additional samples in and around the same area. The samples were each mixed separately and split with the licensee. The licensee's gross alpha measurements were

<10 pCi/g,~11111 pCi/g, and 12112 pCi/g. This closes item 86-01-07.

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No violations were identified.

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

The topics included:

the areas inspected the cleanup status of cell 2 the decontan,ination status of Building 400 the status f the partially filled pit at the back of Building 400 and its needed NRC overcheck criticality safety analysis review requirements under the current staff the status of open items closed: 86-01-01 SCBA training review 86-01-03 Review.of 4th quarter 1985 and 1st quarter 1986 bioassay results 86-01-04 Review' fire drill critiques of four alarms that occurred during the previous inspection 86-01-05 Fire extinguisher inspection followup i 86-01-06 Review the waste package fire report 86-01-07 Resample NRC-8 because of the gross alpha result I

open: 85-02-03 Pre-Plans for the CDF 86-01-02 Housekeeping in Room 210 of Building 103 new: 86-02-01 Review the licensee's followup of the two VTSC recommendations 86-02-02 Review documentation of drill critique followup and timeliness of corrective actions The licensee's comments included:

Only the number of survey instruments needed will be kept in service. I An evaluation of the current calibration frequency will be made to see if a change is warranted.

A1.1 criticality analyses will receive reviews required under the current staff conditions.

An unresolved item involves clarification of the requirements for the position of the manager of the criticality safety component. The licensee committed to applying for a clarifying license amendment.

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