ML20247D167
| ML20247D167 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 05/09/1989 |
| From: | Brock B, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20247D166 | List: |
| References | |
| 70-0754-89-02, 70-754-89-2, NUDOCS 8905250198 | |
| Download: ML20247D167 (10) | |
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,a U.-S. NUCLEAR REGULATORY COMMISSION REGION V L' t Report No. 70-754/89-02 License No. SNM-960 Priority 0 . Category V Safeguards Group V Licensee: General Electric Company Vallecitos Nuclear Center P. O. Box 460 Pleasanton, California 91304 Facility Name: Vallecitos Nuclear Center Inspection at: Pleasanton, California Inspection Conducted: April 3 through April 11, 1989 Inspectors:
B, L. Brock, Fuel Facilities Inspector. Date Signed Approved by:' <" .M:2 R. Fish, Chief
.- 8/7!N Da'te' Signed Emergency Preparedness Section Summary:
Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls;. training and retraining; criticality safety; operations review; maintenance and surveillance; radiation protection; and emergency preparedness.
During this inspection, Inspection Procedures, 88005, 88010, 88015, 88020, 88025, 83822, and 88050 were covered.
Results: No. violations were identified in the seven areas inspected.
8905250198 890509 PDR ADOCK 07000754 C PDC
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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. Nixon, Specialist Safeguards and Security B. M. Murray, Radiological Engineer R. F. Begley, Supervisor, Remote Handling E. J. Strain, Compliance Engineer A. Sandoval, Radiation Monitor F. A. Arlt, Supervisor, Maintenance and Carpentry L. Irwin, Specialist Instrument and Electrical Maintenance
- Denotes those attending the exit meeting B. Other Organizations (1) California Division of Forestry C. Parker, Battalion Chief, Sunol Station S. Barrett, Captain, Sunol Station
'(3) Alameda County Fire Department T. R. Ferriera, Fire Chief, Livermore (2) Valley Memorial Hospital V. Brown, Vice President, General Services S. Brooks, Director, Diagnostic Imaging M. Jaster, Lead Nuclear Medicine Technologist
- 2. Functional or Program Areas Inspected A. Management Organization and Controls (88005)
(1) Organizational Structure The Vallecitos Nuclear Center organizational structure is unchanged since the previous inspection. The licensee continues to maintain the independence of'the criticality and radiation safety components from the manufacturing of nuclear products or the processing of nuclear materials.
During this inspection the licensee informed the inspector that a radiation monitor was working a few hours a day as an operator to fill in for a disabled operator. The licensee
2 stressed that this monitor was expressly directed not to perform radiation monitoring work while working as an operator.
To facilitate his execution of only operator. tasks, the ,
licensee had shifted another monitor into the area to provide the radiation monitor support for the_ operation. The inspector
' interviewed the monitor performing as a temporary operator and learned he was following the instructions. This monitor was chosen as the temporary operator because he had been a Remote Handling Technician for 12 years before becoming a Radiation Monitor. This temporary arrangement is scheduled for a six week period and it appears to maintain the separation of the independent safety oversight from operations.
(2) Safety Committee The licensee's Safety Committee met during the fourth quarter.
The NRC inspector reviewed the Safety Committee minutes and noted the licensee had no new incidents warranting investigation.
(3) Internal Review and Audit The NRC' inspector's examination of the licensee's internal reviews and audits found they were conducted at the frequency required and were of adequate scope and depth.
Performance in thi., program area appears to be adequate. No violations were identified.
B. Training and Retraining (88010)
(1) Inspection report 70-754/88-03 noted the licensee's retraining program lacked specificity with regard to frequency and was silent on testing to evaluate the effectiveness of the retraining. During the current inspection, the NRC inspector found that the licensee had addressed retraining. The licensee had revised Section 3.0.6 of the applicable Vallecitos Safety Standard by including words to the effect that " personnel should receive the equivalent of IRSO (Initial Radiological Safety Orientation) every three years". This change' falls short of the mark by the use of the permissive word 'should' rather than 'will'. Additionally, the licensee's change remained silent on testing to evaluate the effectiveness of the-retraining or to determine if test results warranted waiving the examination for those persons passing the test with an acceptable score. Also, the three year period included in the revision appears unreasonably long. The licensee explained that the period was chosen to address a group of personnel that included secretaries as well as personnel working with radioactive materials. The licensee was informed that a better ,
approach would be to separate those who don't work with radioactive materials from those who do and specify appropriate retraining frequencies for each group. This was brought to the
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. attention of the NRC' reviewer of license SNM-960 for.
consideration during-the imminent relicensing review (SNM-960 expires 5/31/89).
(2) The documentation of the weekly and monthly safety meeting records has been improved by including test results as well as attendance. The licensee stated'that the other managers will also improve their records reflecting the retraining received by their groups and will also include test results. The licensee indicated that there has been low turnover of personnel in the research and development areas. The persons doing this work have been trained in the use of the special equipment required. The licensee's view is that persons uniquely qualified for work using special equipment would not require retraining as frequently as personnel doing several different kinds of work as in a fuel fabrication plant. The licensee stated the manager of an area should be permitted to make a judgement as to whether or not retraining would be needed by those working in his area on an individual basis (apparently without the benefit of a test).
The licensee's performance in this program area appears to be adequate. However, some questions have been raised regarding retraining and have been brought to the attention of the license reviewer for consideration during the license renewal process. No violations were identified.
C. Criticality Safety (88015)
(1) Nuclear Criticality Safety Analysis a The licensee's plan to consolidate some 1rew enrichment scrap for use by the Wilmington fuel fabrication plant is experiencing a delay because the laboratory area originally scheduled for this work is being used for another project.
Solution blending will be used to generate a' homogeneous product of less than 4 percent enrichment. The ammonium diuranate precipitated from the solution with ammonium hydroxide can be representative 1y sampled for the shipping and receiving accountability measurements after drying. Changed plans at the receiving facility resulted in a significant reduction in the quantity of material scheduled for reprocessing. This wet operation will not exceed the solution criticality limit. Information Notice 89-24 was reviewed with the licensee to assure the topics it addressed were considered by the licensee for this non-routine operation.
(2) Internal Review and Audit The NRC inspector examined the licensee's internal reviews and audits and found they were conducted at the frequency required
- and were of adequate scope and depth.- The consolidation of six l criticality limit areas (CLAs) into one with the same limit previously permitted each of the six was noted. This change resulted in increased conservatism with regard to criticality
4 safety. Updating some laboratory identifications resulted in changes to.the CLA list although the areas involved remained unchanged.
(3) Criticality Calibration and Monitoring System The inspector examined the' records and noted that the criticality alarms have been source checked monthly, as required, in coordination with the Central Alarm Station (CAS)
, and the staff of the building in which the criticality alarm exists. The criticality alarms readout in the CAS which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. The system tests are conducted in conjunction with the guard in the CAS who must reset each unit in the system after completion of the test of that unit. These tests are preceded by an announcement that the imminent alarm is'a test. During a drill or when there is a spurious alarm there is no such announcement and the personnel respond-normally (immediate evacuation to predetermined areas following specific routes).
The licensee has experienced two spurious alarms'in Building 102 s' ace the previous inspection. The licensee's' personnel reccLed to the alarms as they had practiced in routine drills.
The two alarms, from the same detector, were five days apart.
After the second alarm, the licensee removed the malfunctioning unit and replaced the detector, the battery box, and the; ,
cables. No further spurious alarms have been experienced. The system now functions normally and passes the system tests.
Performance in this program area appears to be adequate. No violations were identified.
D. Operations Review (88020)
(1) Conduct of Operations (a) Radioactive Materials Laboratory (RML)
Hot cell operations are largely unchanged since the previous inspection. Cell 1 continues to be used for the primary cleaning of CO-60 capsules. Cell 2 is still used for Scanning Electron Microscopy (SEM) as well as cathodic etching of samples in preparation for exposure in the SEM.
Cell 2 is also used for secondary cleaning of Co-60 capsules. Cell 3 is used for Retained Fission Gas (RFG) analysis, however it *s on standby pending the receipt of additional work requiring its use. Cell 4, used for secondary encapsulation of the Co-60 capsules, still contains an alpha box that needs to be cleaned up and removed. The licensee has submitted cleanup and disposal cost data to the Department of Energy. After the cleanup is budgeted about 12 to 18 months will be needed to complete the project. Cell 5 continues to provide
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1 L metallographic support to the Post Irradiation Examination (PIE) work.
The shredder procedure was revised to clarify the intent to preclude the shredding of materials contaminated with special nuclear material (SNM). -The use of the acronym TRU (transuranic) in the procedure was now'followed by.
"and uranium bearing materials" to assure that' materials contaminated with uranium would also be precluded from being shredded. This revision adequately addresses the ,
inspectors concern. The shredder is now in routine use.
Shredded material which when packaged yields a surface dose rate equal to or less than 180 mr/hr is shipped by van at about 60 drums per van. Packaged' shredded material yielding a surface dose rate of greater than 180 mr/hr'are .
shipped in a Hittman shielded container at about sixLdrums- l per shipment.
The licensee is still. undecided as to which, if any, floor covering will be put over the bare concrete floor in the access area of the corridor. It would appear that some type of covering would be easier to decontaminate thanL the floor as it now exists., Currently the floor is bare except for the residual glue left behind when the floor tiles were taken up. It appears that a spill in the area would require removal of a portion of the exposed concrete surface.
The licensee is refurbishing a room to be an ultra-sonic decontamination room. Three air samplers have recently been installed and provisions are being made for the installation of a hood.
The planned change of the oil in the hydraulic system that operates the cell doors has been delayed.
Consideration is being given to improving the liquid cleanup filtration system used for the liquids from hot cell cleaning operations.
(b) Waste Evaporator Plant (WEP)
The licensee completed the installation of an enclosure around the solidification process area. This step should minimize the spread of contamination during the mixing step of the solidification process.
Water used only for once through cooling of equipment is stored in a 50,000 gallon rubber bladder. Samples of the water are analyzed. The analytical results have routinely been less than NRC release limits and the water has therefore been released to Lake Lee, the onsite lake. If the analytical results should exceed the licensee's
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' limits, the water would be processed through the WEP.
'(c) Building 103-The licensee still has plutonium contaminated alpha glove boxes onsite that are being maintained.
(d) Hillside Storage The small wooden building that stored items being saved for future use was dismantled after it was determined that there was little possibility that the planned use of the items would actually occur.
Drums and boxes containing materials identified as waste were stored in a building pending arrangements for shipment. Similar containers of materials which'may eventually be identified as waste are considered as "in process" and are stored outdoors. When the "in process" materials are identified as wasta they may need sorting and repackaging before they are queued up in the aforementioned building in preparation for shipment.
Some pieces of equipment are stored in the building for protection from the weather. Most of the containers subject to weathering by outdoor storage are covered with plastic designed for protection against the effects of weathering.
The inspector noted the licensee made available space in the Hillside' storage. bunker for the storage of waste containers accumulated from about nine years of operation.
These containers have greater than 100 nanocuries per gram (nCi/g) TRU. Additional storage capacity is expected to i be'provided through cleanup of additional Hillside storage space.
(2) _ Housekeeping Housekeeping around the site continues to show improvement.
(33 Hazardous Materials Control The NRC inspector, accompanied by the site Fire Marshall, inspected the chemical storage area. The inspector noted that there was no incompatible storage of chemicals.
The inspector's review of the storage of pressurized gas bottles found the gas bottles were properly secured.
The licensee's performance in this program area appears to be adequate. No violations were identified.
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7 -l E. Maintenance and Surveillance Testing (88025)
(1) Maintenance The licensee's records of the ventilation fan lubrication ,
were not clear and therefore warrant improvement. It appears that the licensee's plan of putting the fan service schedule on a computer will result in improved records.
(2) Calibrations The licensee's system of haVing radiation monitors deliver survey instruments for calibration is effective in precluding calibration oversight. All instruments observed during the ;
inspection were within their calibration period. l The licensee's performance in this program area appears adequate.
It was noted that little. progress has been made in getting the ventilation system on the computer maintenance schedule.
F. Radiation Protection (83822)
During the previous inspection (70-754/88-03) it was suggested that additional attention be given to the lccation of some High Radiation Area signs. The posting problems were found to have been corrected when reviewed during this inspection. All special status signs were noted to be in excellent condition during this inspection (the faded and torn signs noted during the previous inspection had been replaced).
The licensee's performance in this program area appears adequate.
No violations were identified.
G. Emergency Preparedness (88050)
(1) Offsite Support Agencies The inspector visited the California Division of Forestry (CDF) and the Valley Memorial Hospital (VMH). Discussions'at the CDF were held principally with the Battalion Chief, but fortuitously one session included the Fire Chief of the Alameda County Fire Department (ACFD).
The CDF Battalion Chief indicated, and the ACFD Fire Chief agreed, that the Mutual Aid responders should be included in site orientation and drills if possible. A question was raised with regard to the availability of personnel dosimetry for the Mutual Aid responders. The licensee held the view that there I would be adequate dosimetry available even during an event that I warrants a Mutual Aid response. The licensee's position is I based on the premise that it is unlikely that any event would require very many Mutual Aid responders to enter an area where i they would be subject to exposure to radiation. It appears that the parties involved can resolve this concern by i
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F communicating with each other. The inspector encouraged the licensee to meet with the parties and include personnel u
dosimetry as a topic to be addressed at the meeting. The licensee agreed to give consideration to such a meeting.
L The inspector's visit to VMH'resulted in establishing contact with the Director of the Disaster Committee, the Director of Diagnostic Imaging and the Lead Nuclear Medicine Technologist.
The previous VMH contact, the Director of Engineering, is no longer a part of the emergency response at VMH. The licensee and VMH cooperated in a drill on December 14, 1988. The' i scenario involved transporting a simulated contaminated injured person to VMH for decontamination and simulated medical ,
L- treatment. The first critique was held at VMH.immediately. '
after the drill. This critique was attended by VMH, VNC, and a consultant retained by VMH, A second critique was held the same day with the VNC manager of nuclear safety. The critiques identified that VMH had adequately prepared to receive the patient. . Surveying the patient had an extra element of realism as a result of planting three Coleman lantern mantles in the clothes of the " injured contaminated" patient. Further, an 8 microcurie (uCi) check source was included in the bandage on the wound to simulate a' contaminated wound. Of particular note was the conclusion drawn during the critique that VNC should send two Radiation Monitors rather than one to facilitate better control on ingress and egress at the VMH morgue which serves as the treatment area for contaminated injured patients.
It was also concit.ded that an air sampler should be. included in the Building 1028 emergency cabinet so it can be taken along on emergencies in the' event of a need to measure airborne contamination.
(2) Tests and Drills The licensee conducted a fire drill on December 21, 1988. The scenario involved the discovery of a fire in the radioactive materials area of Building 104. An employee fell and injured himself while running to report the fice. Another employee called in the alert. The site Fire Marshall requested additional help as soon as he arrived on the scene. .The California Division of Forestry (CDF) responded with two engines. The CDF was able to use its new monitor which can be l used from high on the fire engine or at ground level.
The drill was followed by a critique. Five items were identified and assigned for corrective action. Four of the items have been corrected, the remaining item requires another p drill before it can be corrected.
Notification of the NRC was incorporated in the Site Emergency Procedures rather than the Radiological Contingency Plan (RCP).
This notification of the NRC may be an item for closer review during relicensing if INMS wants the NRC notification to be a l i part of the RCP.
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(3) Fire Protection Dubing the tour'of the facilities, the inspector checked fifty six fire extinguishers and found their tags indicated they had all received the required monthly inspections.
> The SCBA units on the licensee's onsite fire engines were checked for serviceable air pressure. The thirteen tanks were all equal to or greater than 2000 psi.
(4) M_edical The licensee's medical support for the site has been revised from the previous arrangement. The doctor.is present at VNC only a half day per week and the nurse is present at VNC only three days per week. The nurse participated in the drill that included the VMH, The licensee's performance in this program area reflects significant improvement in cooperation with offsite agencies and now appears to be adequate. No violations were identified.
H. Exit Meeting (30703)
At the conclusion of the inspection the results were discussed with the members of the licensee's staff identified in Section 1. The following topics were addressed.
o The areas inspected.
o The temporary radiation monitor staff change.
o The need to consider separating radiation workers from secret ries with specific retraining frequencies established for each group without the permissive "should" in the retraining commitment.
o The need to improve the communication with the Mutual Aid responders specifically with regard to personnel dosimetry, o The need to discuss with VMH how the radioactive waste (solid and liquid) will be handled after VMH treats a patient from VNC.
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