ML20325A195

Environmental Report 2020

ML20325A195
Person / Time
Site:	Vallecitos Nuclear Center, 05570888, 05573531, 05573532
Issue date:	11/19/2020
From:	GE Hitachi Nuclear Energy
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20325A193	List: ML20325A195 ML20325A196 ML20325A205 ML20325A206
References
Download: ML20325A195 (19)

Text

Vallecitos Nuclear Center Nuclear Test Reactor (NTR)

Docket No. 50-73 GE Nuclear Energy

TABLE OF CONTENTS

1. INTRODUCTION 2

2. FACILITY 3

3. ENVIRONMENTAL EFFECTS OF SITE PREPARATION AND FACILITY CONTRUCTION 4

4. ENVIRONMENTAL EFFECTS OF FACILITY OPERATIONS 6

5. ENVIRONMENTAL EFFECTS OF ACCIDENTS 9

6. UNAVOIDABLE EFFECTS OF FACILITY MAINTENANCE AND OPERATION 9

7. ALTERNATIVES TO MAINTENANCE AND OPERATION OF THE FACILITY 10

8. LONG-TERM EFFECTS OF FACILITY MAINTENANCE AND OPERATION 10

9. COSTS AND BENEFITS OF FACILITY AND ALTERNATIVES 10

10. CONCLUSION 11

11. REFERENCES I FIGURES 12

Environmental Report- July 2020

1. INTRODUCTION The NTR, located on the Vallecitos Nuclear Center (VNC) Site in Sunol, California, is a heterogeneous, highly enriched-uranium, graphite-moderated and reflected, light- water-cooled thermal reactor licensed to operate at power levels not in excess of 100 kW (thermal). The reactor is within a substantial controlled VNC property that limits access to the general public. It has a confinement building to restrict the release of radioactivity to the environment, diversity and redundancy of instruments and controls, and extremely low operating heat flux and temperatures. The NTR is used to support commercial neutrography, irradiations of specimens for classified government contracts, reactivity worth characterizations of reactor fuel cladding material, and training. The U. S. Atomic Energy Commission issued NTR its construction permit on October 24, 1957, and its initial operating license on October 31, 1957. Renewals to License R-33 were issued on April 20, 2001 (Amendment No. 21, ML003775776) and December 28, 1984 (Amendment No. 18).

Requirements given in the NTR license include meeting federal regulations as given in the Code of Federal Regulations (CFR) and facility specific Technical Specifications (TS). Compliance with applicable CFR and TS items is described in the Safety Analysis Report (SAR). Environmental concerns include compliance with requirements regarding airborne and liquid radioactive effluent, radioactive waste disposal, and radiation dose to members of the public from routine operations and postulated accidents. Compliance is achieved by use of design safety features and procedural controls. Design safety features include a ventilation/confinement system, shielding, the reactor building (building 105), a radiation monitoring system, and a reactor safety system. Procedural controls include a documented radiation protection program, emergency plan and implementing procedures, operating procedures, maintenance and surveillance procedures, and an environmental monitoring program and implementing procedures.

Environmental Report- July 2020

2. FACILITY The VNC Site lies within the Livermore Upland physiographic area and is largely undeveloped grasslands with hills ranging in elevation from approximately 400 to 1,200 feet above mean sea level. The VNC Site property slopes to the southwest and drains through ditches to Vallecitos Creek which discharges to Arroyo de Ia Laguna near the north end of Sunol Valley - two or three miles southwest of the VNC Site. The NTR is housed in Building 105; a single-story building with a partial basement that contains offices, laboratories, and storage areas in addition to the NTR Facility. Building 105 is situated in an approximate 135-acre parcel in the southwest quadrant of the VNC Site that is designated as the VNC Site Developed Area (Figure 1).

The NTR is within a thick-walled, reinforced concrete Reactor Cell. This Reactor Cell includes the reactor, reactor control mechanisms, coolant system, and a fuel loading tank which provides shielding and primary water system inventory. There are penetrations into the Reactor Cell to provide for passing water, electric power, and air into/out of the cell and to permit the movement of material and equipment. Normal access to the Reactor Cell is from the Control Room through two doors in the south wall: one a large, thick, shielded, concrete door and the other, a thick paraffin door covered with aluminum.

The Reactor Cell is designed to confine airborne radioactivity and provides for controlled release through an exhaust stack, which is 45 feet (14 meters) above grade level and 9 feet (2.7 meters) above the highest point of Building 105. The ventilation stack has existed at the Building 105 complex since its construction in 1956. It was moved and extended in 1971, but still retains the same visual appearance as it did the late 1950s.

The VNC Site Developed Area includes several high structures on other buildings nearby, including a gas-fired boiler exhaust stack (approximately 15 feet tall) and several single and multistory buildings such as Buildings 102, 103, and 106.

Environmental Report- July 2020 Figure 2 provides an aerial overview showing Building 105 with respect to nearby buildings in the "1 00 Area" of the VNC Site Developed Area.

In addition to the Reactor Cell, the NTR Facility includes, the: Control Room, North Room, South Cell, and Set-up Room. The entirety of the NTR Facility is included within and constitutes a 10 CFR 20 Restricted Area wherein radiological controls are implemented for personnel safety.

The Control Room contains the control console and space for equipment, experiment preparation, and an operator work area. Dose rates in the Control Room are typically about 0.6 mR/h during reactor operation and may reach 2 mR/h when the aperture between the Reactor Cell and the South Cell is open during neutrography operations.

The North Room provides access to the north neutron radiography position inside the shielded, concrete monument, and the access station for the cable held retractable irradiation facility (CHRIS).

The South Cell is a concrete shielded room that provides access to the thermal column, horizontal facility, and the south neutron radiography position. Apertures are provided to both the North Room and South Cell for neutron radiography.

The Set-up Room is used for storage and setup of experiments prior to irradiation or testing.

3. ENVIRONMENTAL EFFECTS OF SITE PREPARATION AND FACILITY CONTRUCTION The NTR Facility was originally constructed in 1957. No additional major construction has occurred since. There are currently no plans for major construction that would modify the environmental envelope of the NTR Facility.

Environmental Report- July 2020 The VNC Site Developed Area, which encompasses Building 105, is an approximate 135-acre parcel of the VNC property situated in the southwest quadrant of the VNC Site between the 400 and 600-foot topographic contours.

This area contains all principal facility structures and is fenced and posted "No Trespassing." The VNC Site Developed Area includes a substantial access road from Vallecitos Road (State Route 84) with a security gate at the controlled access point. The section of the VNC Site Developed Area within the security gate is referred to as the VNC controlled access area.

In 2015, an estimated 610-acre parcel of land at the north end of the VNC Site was surveyed and released for unrestricted use pursuant to 10 CFR 50.83 as communicated to the NRC in submittals recorded under Adams accession numbers ML15114A437 and ML15114A438. This parcel has not been sold and remains part of the original VNC property. Approximately seven additional acres of VNC property along Vallecitos Road (State Route 84), were made available to Alameda County Transportation Commission (ACTC) through actions executed in 2019 and 2020 to support road development and widening. The request for this process is recorded under Adams accession number ML18348A425 and NRC approval and determination of no significant impact is under ML19249C554.

The land in both transactions underwent environmental assessments and the release of that land was determined to present no significant impact to the health and safety of the public. The unconditional release of these parcels demonstrates to a significant degree that the NTR has had no significant impact to the environment immediate to the NTR.

There are three other reactor facilities within the VNC Site Developed Area: DPR-1, Vallecitos Boiling Water Reactor (VBWR); DR-1 0, Empire State Atomic Development Agency Vallecitos Experimental Superheat Reactor (EVESR); and TR-1, GE Test Reactor (GETR). All three of these facilities are currently in SAFSTOR (SAFe STORage) under possession-only licenses. Some pre-decommissioning dismantlement has been performed in these facilities, but all

Environmental Report- July 2020 such activities were discontinued at the end of 2010. The impact of these activities is witnessed in the quantity of solid LLRW shipped (Figure 5) in 2010 and 2011. It is anticipated that decommissioning actives will be resumed in the coming years within the current decommissioning framework. All other activities at VNC, including normal maintenance and minor facility modifications continue to be conducted under 10 CFR 50.59 or according to approved license amendments.

Therefore, neither construction nor the ongoing presence of the NTR has had a significant effect on the terrain, vegetation, wildlife or nearby waters, etc. The societal, economic, and aesthetic impact of the VNC complex is no greater than that of any similar industrial complex.

4. ENVIRONMENTAL EFFECTS OF FACILITY OPERATIONS The NTR typically operates one shift, five days per week with an annual average of approximately 700 full-power hours per year (Figure 3).

The NTR has a negligible thermal impact to the local environment. The primary coolant core outlet temperature is typically 124 degrees Fahrenheit during normal reactor operations and results in a secondary cooling system temperature delta of 20 degrees Fahrenheit across the primary to secondary cooling water heat exchanger. Secondary water temperature is usually below 95 degrees Fahrenheit and only rarely exceeds 100 degrees Fahrenheit on extremely hot ambient summer days. Upon leaving the heat exchanger, secondary cooling water flows to the facility drain, which discharges to the 50,000-gallon site retention basins. Water is held in the site's basin monitoring system for sampling to ensure it contains no radioactive material prior to its release. In this way, secondary cooling system wastewater is assimilated to ambient temperature.

Once released from the basins, this water is recycled by way of an on-site

Environmental Report- July 2020 sprinkler irrigation system (Figure 4). Periodic sampling of the sediment in the discharge swale at the southwest end of the VNC property is performed to ensure there is no buildup of trace byproduct material in the shallow soil runoff. NTR secondary cooling is not a potential radioactive liquid effluent because secondary heat exchanger is operated at a pressure about 30 psig higher than primary coolant.

There are no radioactive liquid effluents discharged from the facility.

Contaminated wastewaters created from NTR operation are processed in the site waste evaporator. Evaporator bottoms are processed, temporarily stored, and shipped as radioactive solid wastes.

Radioactive solid waste at VNC also includes contaminated items (e.g. filters, resin beads, experimental equipment) and consumable materials (e.g. paper and plastic items). Solid wastes are packaged and shipped in accordance with DOT, NRC, and State of California regulations. The use of appropriate shipping containers and an NRC-approved receiving site ensure compliance with federal regulations. Shipments of radioactive solid wastes have been relatively few over recent years, as shown in Figure 5. The only shipment made in 2017 involved retired radioactive sealed sources. Shipments in years prior to 2017 largely included materials from dismantling of the shutdown reactors. No shipments of waste were made in 2019.

Radioactive gaseous releases from the NTR are predominantly Argon-41, resulting from neutron activation of air. Gaseous effluent from the NTR is primarily by way of the stack after passing through a prefilter and a bank of HEPA filters. All gas and particulate effluents are monitored continuously for radioactivity prior to release during reactor operation and the reactor is shut down if so required to reduce emissions below release limits. Annual releases of radioactive effluents have been and will continue to be at or below established federal limits. The data for Figure 6 was taken from NTR annual reports to the

Environmental Report- July 2020 Nuclear Regulatory Commission (NRC) and represents the values measured at the top of the ventilation stack.

There are no releases of potentially harmful chemical substances associated with the NTR operation. The handling and disposal of hazardous chemicals is controlled by the VNC Environmental Health and Safety (EHS) organization. This organization provides the operations group with guidance for handling chemicals and for disposing of hazardous chemical wastes by means other than the sanitary sewer system. The NTR does not generate chemical waste that impacts the environment.

An environmental monitoring program is in place for monitoring radioactivity releases from the NTR reactor. This program is implemented by the EHS organization. Monitoring results of external radiation dose, airborne particulates, surface and ground water, milk, and vegetation are reported according to NTR and other site licensing requirements.

A Radiation Protection Program is in place at VNC that monitors the NTR reactor for external radiation dose, radiation shield integrity, radioactive contamination, and radioactive effluence. The program is implemented by the Radiation Protection organization. Areas within and surrounding the NTR Restricted Area meet regulatory limits for occupational workers and for members of the public as applicable.

Maintenance and surveillance programs are in place at VNC to maintain, repair, test, and verify that reactor systems are operational and capable of performing their intended function. The maintenance and surveillance programs ensure all reactor systems and radiation monitoring systems required by technical specifications are operational.

Environmental Report- July 2020

5. ENVIRONMENTAL EFFECTS OF ACCIDENTS Accidents ranging from the failure of an experiment to the largest credible loss-of-coolant accident and failure to scram have been analyzed and shown to result in no core damage with no fission products released. Analysis demonstrates that for any postulated accident resulting in uncovering the core, convective heat removal by natural air currents across the fuel plates is adequate to ensure fuel damage does not occur. As a result, experiments involving fissionable samples have been concluded to be bounding for the NTR rather than an accident involving elemental reactor core fuel failure. In all cases, bounding analysis demonstrates that conditions at the VNC Site Boundary would not exceed the 10 CFR Part 20 guidelines and are negligible with respect to the environment.

No impact to the environment would result from failure of the primary cooling water heat exchanger tubes because the primary side of the heat exchanger is approximately 30 psig lower in pressure than the secondary side. This would result in a secondary-to-primary leak in the event of a tube leak and primary cooling water would be contained within the NTR Facility, collected, and processed in the site's waste evaporator.

6. UNAVOIDABLE EFFECTS OF FACILITY MAINTENANCE AND OPERATION The unavoidable effects of continued operation of the NTR involve the materials used in construction that cannot be recovered and the fissionable material used in the reactor. No adverse impact to the immediate environment is expected from either.

Environmental Report- July 2020

7. ALTERNATIVES TO MAINTENANCE AND OPERATION OF THE FACILITY There are no suitable alternatives to the capabilities and rewards provided by a nuclear research reactor described in the Introduction other than equivalent capabilities at other research reactors. However, the NTR remains unique in its configuration design in accommodating materials into the horizontal facility and so remains the preferred facility for certain DOD needs. The capabilities provided via the reactor facility include the neutron radiography of aerospace components, and the use of facilities or neutron beams in support of research.

8. LONG-TERM EFFECTS OF FACILITY MAINTENANCE AND OPERATION The long-term consequences of the continued operation of the NTR are beneficial due to its ongoing contributions to industrial quality control, scientific knowledge, and research. Considering the relatively small capital investment necessary for NTR maintenance and its negligible impact on the environment resulting from the small gaseous and particulate discharges, the irreversible and irretrievable commitments associated with the facility over its life have been minimal and would continue to be so during continued operation.

9. COSTS AND BENEFITS OF FACILITY AND ALTERNATIVES The original cost of the NTR, excluding the remainder of the VNC Site, was less than one million dollars. Therefore, replacing NTR with a like facility adjusting only for inflation, would exceed nine million 2019 dollars. The benefits of maintaining NTR operational include, but are not limited to: neutron radiography, research and improvements, neutron activation analysis, basic research support,

Environmental Report- July 2020 and commercial irradiation services. There exists no alternative device that can reasonably provide this range of activities.

10. CONCLUSION The social, aesthetic, noise, and plant biodiversity impacts from the continued operation of the NTR are expected to be inconsequential and consistent with prior operation at the remote semi-isolated site location.

There will be no significant environmental impact associated with the relicensing of the NTR and, hence, no additional environmental impact statement over and above this document is required.

Environmental Report- July 2020

11. REFERENCES I FIGURES REFERENCES

1) General Electric Nuclear Test Reactor Safety Analysis Report

2) General Electric Company Docket No. 50-73, The Nuclear Test Reactor Amendment No. 23 to the Facility Operating License

3) Technical Specifications for the Nuclear Test Reactor Facility License R-33

4) GEH Annual Nuclear Test Reactor (NTR) Operating Reports

5) GEH Vallecitos Nuclear Center Environmental Monitoring Manual

6) GEH Vallecitos Nuclear Center Effluent Monitoring and Environmental Surveillance Programs Annual Reports FIGURES Figure 1 - Map View of VNC Site Developed Area Figure 2 -Areal View of Building 105, Housing the NTR, and Surrounding Buildings Figure 3- NTR Reactor Annual Operating Hours Figure 4- VNC Sprinkler Irrigation Figure 5- Solid Waste Shipments Figure 6- NTR Effluent Stack Releases

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Environmental Report- July 2020 Figure 2- Aerial View of Building 105, Housing the NTR, and Surrounding Buildings

Environmental Report- July 2020 NTR Reactor Operating Hours 1200 1000 800 600 400 200 0

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 D Rx Startups* D Hrs Critical D EFPH

• Number of startups with Rx operating at or above critical Figure 3- NTR Reactor Annual Operating Hours

HITACHI Environmental Report- July 2020

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Environmental Report- July 2020 LLRW Shipments 14000 12000 10000 8000 6000 4000 2000 0

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Figure 5- Solid LLRW Shipments

HITACHI Environmental Report- July 2020 Ar-41 4.00E+02 3.50E+02 3.00E+02 2.50E+02 2.00E+02 i!

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Figure 6 - NTR Effluent Stack Releases