ML20234F017

Safety Insp Rept 70-0754/87-04 on 871202-14.No Violations or Deviations Noted.Major Areas Inspected:Mgt Organization & Controls,Operator Training & Retraining,Criticality Safety, Radiation Protection & Emergency Preparedness

ML20234F017
Person / Time
Site:	07000754
Issue date:	12/29/1987
From:	Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20234F007	List: ML20234F004 ML20234F017
References
70-0754-87-04, 70-754-87-4, NUDOCS 8801110298
Download: ML20234F017 (10)

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U. S. NUCLEAR REGULATORY COMMISSION REGION-V Report No. 70-754/87-04 I Docket No.70-754 License No. SNM-960 I

Safeguards Group: V j Licensee: General Electric Company j Vallecitos Nuclear Center  !

P. O. Box 460 Pleasanton, California 91304 l i

Facility Name: Vallecitos Nuclear Center '

Inspection at: Pleasanton, California Inspection Conducted: December 2-14, 1987 l Inspector: / .2.f 7 B. f. Brock, Fuel Facilities Inspector Date Signed Approved by:

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f)%ff D. Thomas, Chief

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Dat4 Sighed i Nuclear Materials Safety Section )

Summary:

Inspection on December 2-14, 1987 (Report No. 70-754/87-04)

Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls; operator training and retraining; l criticality safety; operations review; radiation protection; and emergency j preparedness. I During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 83822, and 88050 were covered. ,

Results: No violations or deviations were identified in the areas inspected.

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DETAILS

1. Persons Contacted A. Licensee Employees:

• R. W. Darmitzel, Manager, Irradiation Processing

• J. H. Cherb, Manager, Nuclear Safety G. E. Cunningham, Senior Licensing Engineer J. I. Tenorio, Manager, Remote Handling Operations J. E. Lewis, Specialist, Materials Characterization R. F. Begley, Supervisor, Remote Handling E. J. Strain, Compliance Engineer D. C. Bowden, Senior Engineer, Nuclear Safety F. A. Arlt, Supervisor, Maintenance and Carpentry R. Jones, Product Manager, Sealed Sources P. A. Peterson, Engineer

. N. R. Young, Engineering Technician T. A. Felton, Manager, Industrial Safety and Hygiene H. R. Williams, Metallographer R. Reager, Chemist C. Delisle, Specialist, Facilities Protection B. M. Murray, Radiological Engineer

• Denotes those attending the exit meeting

2. Management Organization and Controls The license 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 sefety component and the radiation safety component shall exclude direct responsibility for operations involving the manufacture of nuclear products or processing nuclear materials.

The independence of the criticality and radiation safety components from the manufacturing of nuclear products or the processing of nuclear materials is maintained.

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 reviews of reportable incidents, new facilities or major changes to facilities, and for contributing professional A

. . 2 advice and counsel on criticality and radiation safety policy. The l

VTSC shall review annually the site safety and compliance program l performance to include effluent-releases and occupational exposures I in terms of ALARA and focus on trends for corrective action if necessary.

The NRC inspector's review of the non-reportable incidents found the licensee conducted appropriate-investigations and follow-up corrective action. Additionally, the inspector noted that the licensee's Vallecitos Technological Safety Council (VTSC) identified a need for increasing the frequency of Area Manager l training / retraining meetings addressing both nuclear and industrial l safety. Nuclear Safety has changed the meeting frequency from The VTSC also encouraged improvement of the annually to quarterly.

Building Emergency Teams. The result was organization of a separate fire fighting team involving fewer persons all of whom could more readily be kept properly trained. The VTSC also discussed the l incompatible storage of chemicals and the NRC's increased level of interest in this subject.

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.

A. A Radiation Monitor with significant experience retired during the inspection. A replacement monitor was transferred into the position. The new monitor had previously served as a Specialist Facilities Protection. This position required certification as a radiation monitor. Though previously certified, the new monitor will be retested and/or retrained as necessary for decertification.

Changes in the health physics staff warrant the licensee's continual attention to assure that adequate depth is maintained.

B. The licensee's Remote Handling Operation Manager holds monthly safety meetings. Records of safety meeting topics and attendance are kept and, where appropriate, tests are given. Test scores are kept on file. Procedure revisions resulting from operations experiences are reviewed at the safety meetings to assure the changes and the reasons for the changes are. understood. A recent procedure change was made because of the contamination detected on the shoes of an operator during a routine self survey at the Hillside Storage area. The licensee's appropriate corrective action included retraining and procedure modifications to preclude recurrence.

No violations were identified.

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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 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.

There were no new criticality analyses for NRC licensed operations.

8. Audits Section 5.7 of Appendix A requires that the radiation safety 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 NRC inspector reviewed the licensee's internal controls. The criticality safety audits and inspections were conducted as required and were of adequate scope and depth. The reports of the Radiological Engineer who functions as the Criticality Safety Analyst indicated there were no violations of criticality safety limits. The NRC inspector's review also noted no criticality safety limit violations.

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 j industrial, radiation, and nuclear hazards that could occur through I 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.

A. Conduct of Operations (1) Radioactive Materials Laboratory (RML)

Cell 1 and Cell 2 operations are essentially unchanged from previous operations. Cell 3 operations now include a retained fission gas (RFG) analysis system. The RFG operation was implemented only after the required Change Authorization (CA)'

process had been fully complied with. The reviews required as part of the CA process resulted in several recommendations.

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. . -4 The recommendations were implemented before or during installation of the equipment, as appropriate. Additional changes were added-as operating experience warranted. The RFG operation uses about a third of Cell 3; therefore, the normal fuel examination work can still occur in the cell. The cleanup of the alpha glovebox in Cell 4 is still planned.

The addition of a shredder for use in waste handling has.not been started.

Modifications planned for the hot dock include providing a roof over the hot side of the dock as well as additional' low wall enclosures along the side and rear dock areas. Stainless steel decking is also under consideration because .the heavy duty forklift is especially abrasive on the current tile floor when transporting the larger casks.

(2) Waste Evaporator Plant The licensee has raised the berm around the feed tanks at.the Waste Evaporator Plant (WEP). The berm is designed to preclude the intrusion of surface runoff into the sump which feeds back to the holdup tank.

The heat exchanger at the WEP has been replaced to improve the plant's efficiency.

The licensee plans to improve the location of the self monitoring station at the WEP by moving it closer to the office door.

(3) Building 103 The status of the hazardous material inventory was discussed with the Materials Characterization Specialist who was temporarily appointed as Area Manager. The responsibility for the hazardous materials inventory is assigned to a single-person in each of the two principle groups in,the building.

The Material Safety Data Sheets (MSDS) for.the hazardous chemicals in use are available through the office of'the responsible person or-through the office of the Remote Handling Operations (RHO) Manager. The RHO Manager maintains & library of MSDSs for all hazardous materials on site.

(4) Building 400 The recent cleanup ano survey of Building 400 was independently overchecked for the NRC by the Oak Ridge Associated ' -j Universities (0RAU). The preliminary report indicated that ORAU had essentially confirmed the licensee's findings _and the cleanup of the building appeared to meet the NRC release limits. The Region V recommendation regarding release of the building for unrestricted use is pending receipt of the final ORAU report.

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. . 5 B. Hazardous Materials Control The inspector discussed the licensee's program for handling hazardous materials with the Mane.ger of Industrial Safety and Hygiene (ISH). The licensee had initially conducted a hazardous communication training course of a general nature. This course was followed by one directed towards specific groups according to their needs. Video tapes and slides were available to assist in the training program. Hazardous communications loose leaf books were provided to different operations. The contents c' the books included a section for the applicable MSDSs for that operation. The MSDSs were often in sufficient numbers to warrant keeping them in a separate loose leaf notebook. The hazardous materials inventory list is updated as different chemicals are acquired. In Building 103 the Area Manager representatives manage the hazardous materials inventory lists. The inventory lists have been reduced as materials were disposed of or substitute (less hazardous) chemicals were acquired. Office of Safety and Health Administration (OSHA) type-inspections are conducted periodically by the area managers.

The Manager, ISH explained that the Site Fire Marshal was responsible for compliance with Environmental Protection Agency (EPA) type standards regarding storm drains, sanitary sewers, and ground water. The Fire Marshall _is also the contact between the waste generator and the onsite transportation and storage unit. 'The hazardous waste disposal company is contacted for its guidance in packaging the waste for their subsequent pickup and disposal. Form NEBG-64, " Waste Identification Form," is used to ' describe the generator's waste to the disposal company and to document the proper preparation and packaging of the waste. The completed NEBG-64 must be reviewed and approved by the Fire Marshall and the International Traffic and Hazardous Material Representative before completion of the Hazardous Material Information Sheet (HMIS) from which.the Bill of Lading is prepared. The HMIS is specific to the material type' and specifies the type of DOT container required as well as the marking for the container. The properly packaged container is stored onsite in a hazardous waste storage area pending accumulation of sufficient containers to make up a shipment or the approach of the ninetieth day prior to which it is required to be shipped. This activity is addressed on the licensee's form " Hazardous Waste Disposal and Control Procedure," Vallecitos Safety Standard 7.1, Rev. 3, April 1987.

No poor health physics or criticality safety practices were noted during the operations review.

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 Exposure

6-Exposure records for the second and third quarters of'1987.were examined by the inspector. Three exposures were noted that exceeded ~

the 1.25 Rem.in the third quarter. .The exposures involved Nuclear Test Reactor (NTR) operators. Two of the three exposures had.

occurred under the special authorization'n required by 10 CFR 20.101(b) prior to incurring'the exposure. The'one exposure for which the licensee did.not complete the special authorization was identified and reported by the licensee. . This. overexposure was the subject of a special inspection covered by inspection report 50-73/87-02. During the current inspection, the inspector learned that the licensee acquired a beam catcher of borated polyethylene and is evaluating how best-to use it at the NTR to reduce operator exposures. No other exposures exceeded licensee administrative or NRC regulatory limits.

B. Bioassay Results All uranium and plutonium urinalyses for the 1st and 2nd quarters of 1987 were examined by the inspector. There were no signif'icant positive results.

C. Whole Body Counts The inspector examined the results of the 2nd quarter whole body counting. One result required a recount. The result of the recount made after removal of the individual's shoes verificd that the contamination, identified as Co-60 and Cs-137, was on the shoes.

The whole body count was made because of the detection of contamination by self monitoring before leaving the Hillside Storage controlled area. The license took appropriate action to preclude recurrence (see Section 3. B. for details). The other whole body counting results were all less than two percent of a body burden.

D. Non-reportable Incident Review-A non-reportable incident that occurred since the last inspection, involved the identification of two contaminated metal' roll-about tables. The tables were found within a radiation area in a building not expected to contain contaminated equipment. The tables were contaminated with Cs-137, 300,000 dpm fixed and 100,000 dpm smearable. The licensee's investigation of this incident did not establish when and where the tables came from and who put them in their present location. This particular item was documented separately because it involved significant fixed and removable contamination and appeared to be a recent action unlike the others that appeared to have occurred some time earlier and in accordance with the earlier applicable Vallecitos Safety Standard. The l licensee has increased access control significantly in an effort to i preclude recurrence. Additionally, operations are being consolidated into fewer areas which should further reduce the possibility of recurrence. This item was identified as the result of a project undertaken by the licensee after finding a contaminated punch press in a machine shop (see inspection report 70-754/87-03).

The licensee's special project turned up other less consequential i

. . 7 problems. The report of the results of the special project is still in preparation.

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 conducted three drills since the August 1987 NRC inspection. Two of the three drills were combination drills. One was an evacuation drill to improve the evacuation time experienced in the Building'102 drill. The combination drill held October 6, 1987 at Building 102 involved criticality and fire. The drill critique resulted in seven recommendations. The responsibility for the recommendations was appropriately assigned. Three of the recommendations have been completed, the remaining four are being followed-up. The second combination drill was held October 9,~1987 at Hillside Storage and involved criticality, fire, and high radiation levels. The drill critique resulted in four recommendations. Two of the recommendations have been completed and two remain to be addressed. The third drill was held November 2, 1987 at Building 102 with the goal of reducing the evacuation time.

The evacuation time was improved to just under one minute with personnel accountability completed in about three and a half minutes. During the current inspection an unplanned evacuation was caused by a fire alarm being set off by the exhaust from the startup of a fork lift. The new fire team responded properly and the onsite fire engine also responded.

B. Pre-Plans The licensee completed the remaining four Pre-Plans; therefore, item (85-02-03) is closed. The associated open item (87-01-03) addressing the tour by the local responding fire fighting agency, the California Division of Forestry (CDF), is now closed because the licensee has adequately performed a follow up on the item since the last inspection. The CDF has revisited the site and is scheduled to tour again just after the inspection. A new Captain assigned to'the first response CDF station participated in the previous tour and voiced interest for the pending more detailed tour.

C. Fire Protection The licensee's fire extinguisher inspection program is still effective. None of the sixty extinguishers observed by the NRC inspector had been missed during the licensee's monthly inspections.

D. Medical Item (87-01-04) in the May 11, 1987 inspection "eport (70-754/87-01) addressed the need for improved interfacing, ircluding drills, between the Valley Memorial Hospital (VMH) an/ the licensee's staff.

. , 8 The licensee agreed to extend an invitation to VMH shortly after this inspection to participate in or observe one of the licensee's drills. Subsequent to this inspection, the inspector learned, by telephone, that the Manager of Nuclear Safety, the Compliance Engineer (Emergency Coordinator), and the Industrial Nurse visited VMH. They met with the VMH Chief Engineer. VMH, however, was not invited to participate in or observe a licensee drill. Therefore, item (87-01-04) remains open. The licensee's visit to VMH represents a significant improvement in communications between the licensee and VMH.

No violations were identified.

7. 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 decontamination status of Building 400.

The updating of the list of emergency telephone numbers.

The status of the open items.

Closed (87-01-03) Review the licensee's efforts to assure the CDF fire fighters become familiar with the site.

Open (87-01-04) Review of the improvement in interfacing between the licensee and the hospital.

(87-03-01) Review the results of the licensee's effort to locate and control contaminated machinery found outside of radioactive material areas.

New There were no new open items.

The inspector expressed concern that the bioassay results were running about two months after submittal of the samples. The licensee agreed to look into the matter.

, The licensee's site fire team will apparently reduce the training effort I

previously necessary to a more manageable level; however, the efficiency of the reconstituted fire team must not be less than that of the previous i I

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. . 9 team. The licensee plans to make the required submittal of the change to the Radiological Contingency Plan.

The inspector informed the licensee that current information did not appear to indicate that this facility would be subject to'a NRC team assessment.

In response to the inspector's question, the licensee indicated that no burials of radioactive wastes occurred at this site.

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