ML20217D610
| ML20217D610 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 03/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217D589 | List: |
| References | |
| 70-0754-98-01, 70-754-98-1, NUDOCS 9803300103 | |
| Download: ML20217D610 (10) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV
- Docket No.: 70-754 License No.: SNM-960 Report No.: 70-754/98-01 Licensee: General Electric Company Facility: Vallecitos Nuclear Center (VNC)
- Location: Pleasanton, California Datas: February 24-26 and March 5,1998 )
i inspector: C. A. Hooker, Senior Fuel Facility inspector J. V. Everett, Health Physicist Approved By: Frank A. Wenslawski, Chief Materials Branch
Attachment:
Supplemental Inspection Information POR a
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EXECUTIVE
SUMMARY
i Vallecitos Nuclear Center NRC Inspection Report 70-754/98-01 This routine announced inspection included aspects of management and organization, operations, operational events, operator training, maintenance and surveillance testing, and followup on open items from previous inspections.
Manaoement and Oraanization
.' Key management and safety positions were consistent with Appendix A of the license.
The Vallecitos Technological Safeiy Council (VTSC) was actively involved with the site safety programs (Section 1).
Ooerational Event Review and Feedback
. The licensee's procedures adequately provided the means for identification, review, and reporting of operational events and employee safety concems. However, the matter conceming the hot cell differential pressures indicated less than satisfactory performance in timely resolution and intemal reporting of an off normal condition. NRC operational notifications were adequately reviewed for applicability at the licensee's facility, including the year 2000 effect (Section 2).
- Ooerations Review
- The licensee was adequately controlling its use of special nuclear material (SNM) and safety equipment appeared fully operational (Section 3).
Ooerator Trainina
. The licensee's training program was consistent with the requirements of Appendix A of the license and licensee procedures. Operators appeared knowledgeable and adequately qualified to perform their assigned tasks (Section 4).
Maintenance and Surveillance Testina
'. ' Preventative maintenance and surveillance activities relating to NRC-regulated activities were generally thorough and timely (Section 5).
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Report Details Summarv of Plant Status Current activities involving SNM consisted of post-irradiation examination of low-enriched uranium reactor fuel elements in the Building 102 hot cell facility. There were no current act vities involved with the use of SNM in Building 103. Other ongoing site activities involved the use of radioactive materials licensed by the state of Califomia. Some of these activities consisted of fabricating Co-60 sources, processing Xe-133 for medical use, and examination of irradiated reactor hardware.
1 Management Controls and Organization
- a. Insoection Scooe (88005)
The licensee's organization, procedures, safety review committee meetings conducted in )
1997, and criticality safety audits performed in 1997, were reviewed to verify site ;
activities were being conducted safely and consistent with requirements of the license. ,
Specific procedures reviewed included: )
- VNC Safety Standard 1.1, " Charter - Vallecitos Technological Safety Council,"
dated 8/94,
. VNC Safety Standard 2.0, " Change Authorization," dated 11/94,
. VNC Safety Standard 3.0, " Reports to Regulatory Agencies," dated 9/97,
. VNC Safety Standard 4.2, " Posting of Notice to Employees," dated 12/94,
. VNC Safety Standard 5.2, " Radiation Exposure Limits," dated 5/95, and
. NEDE Policy and Procedure 70-42," Reporting of Defects and Noncompliance Under 10 CFR Part 21," dated 1/97.
- b. Observations and Findinos Key management and safety positions for the Vallecitos organization were consistent with those listed in Addendum A of Appendix B to the SNM-960 license. The VTSC continued to perform as an independent review body of senior technical and management personnel who review reportable incidents, the nuclear safety program, new facilities and major changes to existing facilities, and provide professional advise and council on criticality and radiation safety policy.
Membership of the VTSC and quarterly VTSC meetings were consistent with Section 4.4, Appendix A of the license, and Safety Standard 1.1. Reportable events,
open items, and topics related to dosimetry performance, as low as reasonably achievable implementation, a new automated gate system, and radiological monitoring coverage were appropriately reviewed by the VTSC. ,
The inspector also noted that the site safety standards were reviewed and revised in accordance with requirements of Appendix A of the license.
- c. Qgnclusions Key management and safety positions were consistent with Appendix A of the license.
The VTSC was actively involved with the site safety programs. 1
'2- Operational Event Review and Feedback Programs
- a. Inspechon Scope (88702 and Tl 2600/003)
The effectiveness of the licensee's programs for evaluating operational events and providing an opportunity for employee reporting of safety issues was reviewed. NRC Inspection Report 70-754/97-02, dated December 16,1997, described the review of Licensee Event Report No. 33021 involving the failure of the criticality monitoring system alarm in the Radioactive Materials Leboratory facility on October 1,1997. Procedures reviewed are described in Section 1 above. The inspectors also examined the licensee's review of NRC Information Notices (ins) and other NRC generic publications. During facility tours the inspectors evaluated an ongoing off-normal condition involving low differential pressure readings with hot cells Nos. 9 and 10.
- b. ' Observations and Findinas The licensee's program for responding to employee concems related to safety was incorporated into GE's program for dealing with 10 CFR Part 21 reporting issues (Policy and Procedure 70-42). Safety items were defined as any departure from technical requirements or a failure to comply with the Atomic Energy Act or any applicable NRC rule, regulation, order, or license condition. This corporate document directed employees to report any potential safety concem, in writing, to a Safety Evaluation Project (SEP) manager located in the corporate office. This would initiate a review process to evaluate the issue for corrective actions and reportability. If an employee was not satisfied with the closure of an issue, the person was to notify the SEP manager for further review. If the matter continued to be unresolved to the employee's satisfaction, the matter could be appealed to higher management, including the General Electnc a Nuclear Energy Vice President and General Manager. GE also maintained a corporate I help-line and an ombudsman phone line that allowed employees to report safety concems outside their management chain.
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Posted information conceming reporting 10 CFR Part 21 issues was located on the bulletin board in Building 102. Posting of the current NRC Form 3 was consistent with the requirements of 10 CFR Part 19.
VNC Safety Standard No. 3.0 outlined the licensee's onsite procedures for intemal reporting of incidents and occurrences that may be subsequently reportable to regulatory.
agencies. This procedure adequately described the reporting requirements for federal, state, and local agencies applicable to GE's activities. Appendix A of the procedure provided a list of guidance for identifying conditions or events that may require reporting to regulatory agencies, including noncompliance with standards, procedures, regulations, technical specifications, or license conditions. The procedure also required that NRC be promptly notified.
On February 24,1998, the inspectors noted that the differential pressures for hot cells Nos. 9 and 10 in the Radioactive Materials Laboratory were 0.01 and 0.022 inches of water (in. H2 O), respectively. Hot cells Nos. 9 and 10 are used to examine irradiated reactor hardware under GE's state license and are remotely located from the high-level hot cell complex where the primary NRC licensed activities are conducted. A subsequent review of the daily readings (taken at the start of the day) from area operating logs disclosed that from January 5 through February 20,1998, hot cell No. 9 averaged approximately .013 in.140 and hot cell No.10 averaged approximately 0.016 in. H,0. Table 1, Appendix A of General Electric Cornpany's (GE) state license (0017-60) and Table 8.1, Appendix A, of the NRC license (SNM-960) titled
- Equipment and Design Criteria and Guidelines," establish a differential pressure design criteria of greater than 0.02 in.140 for the hot cells. The basis provided in the tables I was to prevent any blowback of radioactive materials to the operating area.
Relative to the above matter, pognizant representatives from the operations group and the facilities maintenance staff informed the inspectors that since the replacement of a recirculating air conditioning unit oh December 14,1997, they had been experiencing the low hot cell differential pressure readings and air balancing problems on a daily basis.
For each observation of the low differential pressure readings during the moming inspections, operations notified maintenance personnel who manually adjusted the air conditioning flows to increase the differential pressures. Plans were being considered to install an automatic damper control system and an exhaust booster fan to correct the ;
problem. During subsequent discussions with licensee representatives on February 25, 1998, the inspectors leamed that regulatory compliance (RC) had not been notified of the l
. ongoing low differential pressure problem. The inspectors discussed the failure to inform RC and the length of time the problem persisted with the operations manager and the
- RC staff.
Following the above discussions, on the moming of February 26,1997, operations changed the cell 9 high-emciency particulate air exhaust filters (differential pressure at 2.0 in. H,0 and limited to 4.0 in.140) and adjusted the exhaust dampers on cells 9 and
- 10. Following this action, the differential pressures for cells 9 and 10 were 0.083 and
_=
0.042 H2 0, respectively. The differential pressure across the cell 9 exhaust filters dropped to 1.4 in. H,0. This indicated that the low differential pressure readings '
between the hot cells and operating area appeared to be more related to hot cell conditions rather than the new air conditioning unit. Although the low differential pressures did not result in any release of radioactive material to the operating area, the inspectors viewed the matter as an uncoordinated effort between maintenance and operations to effectively resolve the issue during early occurrence. Although this specific 4 natter was under the jurisdiction of the state license, the findings do not reflect a positive indication on the licensee's program of internal reporting and correcting off normal conditions in a timely manner. Since this matter was under the state of Califomia jurisdiction, this finding was communicated to the state subsequent to the inspection by the NRC Region IV Office.
Regarding NRC ins, Bulletins, and Generic Letters, the inspectors verified that the licensee had received and reviewed IN Nos. 96-70,97-03, 04,20,23,24, 30,34,36,42, 47, 50, 55, 56, 57, 66, 72, 75, and NRC Bulletin 97-02 for applicability to their facility.
Regarding IN No. 96-70, " Year 2000 Effect on Computer Software," this matter is being
. reviewed under a comprehensive formalized program titled, "GE Nuclear Energy Year -
2000 Date Compliance, Definition, Standards, and Policies." Reviews had been conducted to identify noncompliant programs. The primary noncompliant programs were the personnel exposure program "RADDOS" and some older cou'. ting room software programs. The licensee's goal was to have all noncompliant programs corrected by the end of 1998.
- c. Conclusions The licensee's procedures adequately provided the means for identification, review, and reporting of operational events and employee safety concems. However, the matter conceming the hot cell diffectential pressures indicated less than satisfactory performance in timely resolution and intamal reporting of an off normal condition. NRC operational notifications were adequately reviewed for applicability at the licensee's facility, including the year 2000 effect.
3 Operational Safety Review
- a. Inspection Scope (Tl 2600/00)
The inspectors toured and discussed current operations in the Building 102 hot cell facility and the Building 103 metallurgy / chemistry laboratories. The inspectors also
' reviewed selected SNM inventories of criticality limit areas in Building 102 and Building 103.
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- b. Observations and Findinos The inspectors noted that there had been no changes in operations that required a new criticality safety analysis during the past year. Hot cell No.11 was activated in 1997 for examination (scanning electron microscope) of irradiated fuel and cladding metalography -
specimens. Use of materialin the cell was limited to 10 grams of SNM. However, only fuel cladding specimens had been examined and no SNM had been introduced into the - i hot cell. Since site activities do not involve liquid processing systems or the handling of large quantities of enriched uranium, criticality safety continues to be based on safe J
batch limits.
. The licensee's SNM inventory in Building 103 was being maintained below the suberitical area value that exempts this area from the requirement to maintain a criticality monitoring system. A major portion of the SNM inventory in Building 103 consisted of non-irradiated low enriched fuel samples and fuel pellets stored in various laboratories and the Building 103 fuel storage vault. There were no current projects involving the use of
. SNM. SNM containers in the vault were properly labeled and the door to each storage '
cubicle was latched to reduce the potential for unsafe movement of SNM in the event of an earthquake.
The licensee's inventory records in Building 102 indicated that the SNM in each of the hot cells where irradiated fuel was being examined or stored was being maintained below the safe batch quantity limit. Criticality controls were adequately incorporated in the hot cell operating procedures, and the operators were quite knowledgeable of the criticality controls for their assigned work area.
During facility tours, the inspectors noted that criticality control limits were appropriately posted where SNM was maintained or authorized. Air sampling devices, ventilation system magnahelic and hot cell photohelic gauges, and area radiation monitoring equipment appeared fully operational. Fire extinguishers and other fire safety equipment appeared operational and in good condition. Housekeeping was generally good in the areas toured.
The licensee's criticality inspections and audits were consistent with curmr.. activities and the requirements of Section 5.7," Criticality Safety inspections," Appendu A, of the license and licensee procedures.- No safety problems were identified by tha licensee's
~ inspections and audits.
- c. Conclusions The licensee was adequately controlling its use of SNM and safety equipment appeared
- fully operational.
4 Operator Training and Qualification
- a. Insoections Scoos (88010)
The inspection included interviews with operators during facility tours, a review of selected training records for the past year, and the attendance of a monthly safety / training meeting.
- b. Observations and Findings Employees working with SNM had received initial criticality training and radiological safety training and annual retraining per Sections 5.8 and 7.3 of Appendix A of the license. The licensee accomplished the annual retraining through monthly safety meetings / training sessions. During the inspection, the February monthly safety meeting / training class was attended. The meeting covered the use of personal protective clothing, a film on industrial safety, and radiological emergency response actions. Following all safety / training meetings, each individual was tested on their kncct.ge of the topic area covered in the training session A test score of 80 percent was required for a passing grade. Employees who did not meet the test score requirement were provided individual training and/or tutoring. The review of licensee training records indicated that all applicable individuals had completed the required training for 1997.
Operators / technicians received specialized training specific to their assigned work areas.
From observations during facility tours and discussions with operating personnel, it appeared that operators / technicians were adequately knowledgeable of the criticality safety, radiation safety, and SNM inventory controls as applicable to their assigned task.
- c. Conclusions
' The licensee's training program was consistent with the requirements of Appendix A of the license and licensee procedures. Operators appeared knowledgeable and adequately qualified to perform their assigned tasks.
5 Maintenance and Surveillance Testing a .- Inspection Scope (88025)
The inspectors toured the licensee's faci!ities to observe the status of safety equipment and reviewed the records for the past year of: (1) monthly fire protection system
- inspections and alarm tests, (2) daily Building 102 operations safety checks, (3) semiannual electrical interlock tests of the Building 2 hot cell doors, (4) annual calibration of hot cell differential pressure photohelic gauges, and (5) the criticality monitoring system.
.g.
- b. Observations and Findinas The inspectors found that' calibration and surveil lance tests were performed in accordance with the requirements delineated in Appendix A of the license and/or licensee procedures. No safety concems were identified as a result of the review.
NRC Inspection Report 70-754/97-01 described the licensee's replacement of the criticality monitoring system. The review of the licensee's monthly system functional checks since installation of the new system indicated that the system was capa'o le of performing its intended safety function.
- c. Conclusions Preventative maintenance and surveillance activities relative to NRC activities were generally thorough and timely, and identified problems were adequately corrected.
5 Sewage Sludge it sue (92701)
(Ocen) Insoection Followuo item (70-754/9702-01: Review of licensee's sample analysis of sludge from the sanitary waste "Imhoff" tank. On October 21,1997, the licensee had taken a sample of 6,000 gallons of sludge removed from the tank for offsite disposal and had not received the vendor's laboratory analysis as of the time of the inspection (NRC Inspection Report 70-754/97-02). The inspectors noted that the subsequent vendor analysis indicated a gross alpha activity of 22.8 pCilg and a gross beta activity of 24.6 pCilg. A subsequent sample of the sludge remaining in the tank was taken on December 21,1997, and indicated a gross alpha activity of 27.6 pCi/g and a gross beta activity of 33.2 pCilg. Although the sample data indicates the presence of radioactive material, without an isotopic analysis, the licensee could not explain the source of radioactivity (i.e., naturLIly occurring or radionuclides associated with NRC or state licensed activities). This matter was further discussed by telephone on March 5,1998, with members of the RC staff. The licensee representative acknowledged the importance of performing an isotopic analysis and agreed to expedite the process and provide the Region IV office with the sample results. This matter remains open.
Subsequent to the inspection, Region IV staff informed the state of Califomia about this j matter. <
6 Exit Meeting Summary I I
The inspectors presented the inspection results to members of the licensee management ;
at the conclusion of the onsite inspection on February 26,1997. Followup discussions relative to the sludge samples from the *lmhofF tank were held on March 5,1998. The licerisee acknowledged the findings presented. !
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. Although propnetary information was reviewed during this inspection, such information is l not knowingly described in this report.
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ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee F. Arit, Manager, Facilities Maintenance C. Basset, Manager, Regulatory Compliance C. Hill, Supervisor, Remote Handling Operations M. Rogers, Specialist, Radiation Monitoring B. Murray, Senior Licensing Engineer G. Stimmell, Manager, Vallecitos and Morris Operations J. Tenorio, Manager, Remote Handling Operations INSPECTION PROCEDURES USED IP 88002: Operational Event Review and Feedback Programs at Fuel Cycle Facilities IP 88005: Management Organization and Controls IP 88010: Operator Training / Retraining Tl 2600/003: Operational Safety Review l lP 88028: Maintenance / Surveillance Testing IP g2701: Inspection Followup ITEMS LEFT OPENED AND DISCUSSED Left Opened 70-754/9702-01 IFl Review sample results of Imhoff tank sludge LIST OF ACRONYMS USED GE General Electric Company IN information Notice - 1 in. H2O inches of water RC Regulatory Compliance SEP Safety Evaluation Project SNM. special nuclear material
-VNC Vallecitos Nuclear Center
'VTSC Vallecitos Technological Safety Council e.
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