IR 05000018/2024002
| ML24299A239 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos |
| Issue date: | 10/29/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Zanotto K GE Hitachi Nuclear Energy |
| References | |
| Download: ML24299A239 (14) | |
Text
October 29, 2024
SUBJECT:
GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT 050-00018/2024-002, 050-00070/2024-002, 050-00183/2024-002, AND 050-00073/2024-002
Dear Kristopher Zanotto:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on October 7-9, 2024, at your Vallecitos Nuclear Center in Sunol, California. The inspection covered the following shutdown reactors under the subject licenses: Vallecitos Boiling Water Reactor (VBWR); General Electric Test Reactor (GETR); Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR); and Nuclear Test Reactor (NTR). The NRC inspectors discussed the results of this inspection with you and members of your staff on October 9, 2024. The inspection results are documented in the enclosure to this letter.
During this inspection, the NRC inspectors examined activities conducted under your licenses as they relate to public health and safety, the environment, and to confirm compliance with the Commissions rules and regulations, as well as with the conditions of your license. Within these areas, the inspection consisted of the examination of selected procedures and representative records, tour of the reactors and supporting equipment, independent radiation surveys, and interviews with personnel. Within the scope of the inspection, no violations were identified and a response to this letter is not required.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection, please contact Stephanie Anderson at 817-200-1213, or the undersigned at 817-200-1249.
Sincerely, Jeffrey E. Josey, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket Nos.
050-00018, 050-00070, 050-00183, 050-00073 License Nos. DPR-1, TR-1, DR-10, R-33 Enclosure:
Inspection Report 050-00018/2024-002, 050-00070/2024-002, 050-00183/2024-002, 050-00073/2024-002 Signed by Josey, Jeffrey on 10/29/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.
050-00018; 050-00070; 050-00183; and 050-00073 License Nos.
DPR-1; TR-1; DR-10; and R-33 Report Nos.
050-00018/2024-002; 050-00070/2024-002; 050-00183/2024-002; and 050-00073/2024-002 Licensee:
GE Hitachi Nuclear Energy Facilities:
Vallecitos Boiling Water Reactor (VBWR)
GE Test Reactor (GETR)
ESADA Vallecitos Experimental Superheat Reactor (EVESR)
Nuclear Test Reactor (NTR)
Location:
6705 Vallecitos Road Sunol, California Inspection Dates:
October 7-9, 2024 Inspectors:
Stephanie G. Anderson Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security M. Troy Johnson Nuclear Systems Scientist/Regional Operations Officer Response Coordination Branch Division of Radiological Safety and Security Accompanied By:
Tiffany N. Rushing Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By:
Jeffrey E. Josey, Branch Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security
EXECUTIVE SUMMARY GE Hitachi Nuclear Energy NRC Inspection Report 050-00018/2024-002; 050-00070/2024-002; 050-00183/2024-002; and 050-00073/2024-002 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of licensed activities being conducted at the three permanently defueled reactors and one permanently shutdown test reactor at the Vallecitos Nuclear Center (VNC). In summary, the licensee was conducting these activities in accordance with site procedures, license requirements, and applicable NRC regulations. Within the scope of the inspection, no violations were identified.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors and Class III Research and Test Reactors
The licensee conducted decommissioning activities and Class III research and test reactors activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the site. Staffing level and qualifications met minimum requirements. (Section 1.2)
Problem Identification and Resolution at Permanently Shutdown Reactors
The inspectors concluded that the licensee was adequately implementing its corrective action program in accordance with regulatory requirements. (Section 2.2)
Fire Protection Program at Permanently Shutdown Reactors
The licensee continued to effectively implement its fire protection program. The inspectors reviewed the fire hazard analysis, pre-fire plans and procedures for firefighting and determined that they were adequate. The licensee continued to effectively implement its fire system maintenance and inspection in accordance with procedures and regulatory requirements. (Section 3.2)
Occupational Radiation Exposure at Permanently Shutdown Reactors
The inspectors determined the licensee ensured adequate protection of worker health and safety from exposure to radiation or radioactive material in accordance with regulations.
(Section 4.2)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The inspectors determined the licensee ensured that the radioactive effluent sampling and analysis requirements are satisfied, and the REMP was effectively implemented in accordance with regulations. (Section 5.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
The inspectors did not identify any significant deficiencies in the licensees radioactive waste management or transportation of radioactive materials programs and procedures. (Section 6.2)
Report Details Summary of Plant Status The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) maintains four shutdown reactors: Vallecitos Boiling Water Reactor (VBWR); General Electric Test Reactor (GETR);
Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR); and Nuclear Test Reactor (NTR). GETR and EVESR are in a possession-only, safe storage (SAFSTOR) condition, with no fuel remaining in the reactors or spent fuel pools. At the time of the inspection, VBWR was classified as an Inspection Manual Chapter 2561, Category 3 decommissioning site. In the letter dated January 26, 2024, the licensee informed the NRC that it had permanently ceased operation of the NTR on December 21, 2023 (ML24054A539). On February 28, 2024, the NRC issued amendment 26 which revised the Renewed Facility Operating License No. R-33 and the associated technical specifications to remove the authority to operate the NTR, to authorize possession-only of the reactor and fuel, to remove operational requirements not needed for the possession-only status, and to replace the requirement for NRC-licensed reactor operators with certified fuel handlers (ML24031A622).
Since the last inspection, GEH has been preparing to transfer the site to NorthStar Group, this has included a reduction in staffing and curtailment of any decommissioning related activities.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors (IP 71801) and Class III Research and Test Reactors (IP 69002)
1.1 Inspection Scope The inspectors observed site activities, reviewed materials, and interviewed site personnel:
To evaluate the status of decommissioning and verify whether the licensee was conducting decommissioning activities in accordance with regulatory and license requirements.
- To maintain awareness of work activities to assess licensee control and conduct of decommissioning.
- To determine if activities at Class III research and test reactors were conducted safely and in accordance with regulatory requirements and licensee commitments, since the last inspection.
1.2 Observations and Findings a.
Status of Decommissioning At the time of the inspection the licensee had curtailed decommissioning activities in preparation for license transfer to NorthStar Group. While normal day to day routine maintenance was being performed, no decommissioning activities were in progress.
b.
Decommissioning Operations The inspectors performed plant tours of VBWR, EVESR, GETR, and NTR including radiologically controlled areas and containments to assess field conditions and decommissioning activities. Also, the inspectors evaluated the material condition of
structures, systems, components, housekeeping, system configurations, worker level of knowledge, as well as procedure use and adherence.
The inspectors evaluated whether the licensee's organization and staffing were appropriately adjusted for changes in the status of decommissioning. The inspectors determined the licensee staffing met the minimum requirement to ensure reasonable assurance of safety and security in accordance with regulatory requirements and the license.
c.
Decommissioning and Class III Research and Test Reactors Staffing The inspectors reviewed current site staffing since the reduction in staff that occurred earlier this year. The site is maintaining minimal required staffing until the transfer has been completed.
1.3 Conclusions The licensee conducted decommissioning activities and Class III research and test reactors activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the site. Staffing level and qualifications met minimum requirements.
Problem Identification and Resolution Action at Permanently Shutdown Reactors (IP 40801)
2.1 Inspection Scope The inspectors reviewed the licensees corrective action program related to the oversight of the four shutdown reactors:
To evaluate the effectiveness of licensee controls in identifying, resolving, and correcting issues in accordance with the NRC approved Quality Assurance (QA)
Program and 10 CFR Part 50, Appendix B, Criterion XVI.
- To determine whether the audits and assessments were conducted in accordance with the requirements of the NRC-approved QA program and 10 CFR Part 50, Appendix B.
- To confirm that the licensee has established, implemented, and performed management reviews of the safety conscious work environment.
2.2 Observations and Findings a.
Corrective Action Programs At the time of the inspection, the licensee was implementing its corrective action program under procedures CP-16-108, Corrective Action Program, revision 16, and associated implementing procedures that apply to all GEH nuclear sites.
The inspectors reviewed the licensees implementation of these procedures and a recent list of corrective action condition reports (CRs) generated since the last inspection.
Limited CRs associated with activities at the shutdown reactors were written since the
last inspection. The inspectors reviewed CRs 46058 and 46713 to verify compliance with the corrective action procedure and interviewed site personnel about the actions taken in regard to the CRs. The inspectors evaluated each CR and determined corrective actions taken were in accordance with regulatory requirements.
2.3 Conclusions The inspectors concluded that the licensee was adequately implementing its corrective action program in accordance with regulatory requirements.
Fire Protection Program at Permanently Shutdown Reactors (IP 64704)
3.1 Inspection Scope The inspectors observed site facilities, reviewed materials, and interviewed site personnel:
To assess whether the licensee has an effective decommissioning fire protection program that was maintained and implemented to address the potential for fires that could result in the release or spread of radioactive materials.
- To evaluate whether the licensee has appropriate procedures to prevent or minimize the release of radioactive materials resulting from fires involving contaminated plant structures, systems, and components or radioactive waste products.
- To verify the decommissioning fire protection program ensures adequate protection from the fire-induced release of radioactive material from contaminated plant areas and combustible waste products.
3.2 Observations and Findings a.
Fire Protection Program The inspectors walked down the VBWR, GETR, EVESR, and NTR and evaluated potential fire areas to verify fire hazards were being identified, examined the physical plant configuration, and evaluated if physical fire protection features were adequate from an emergency preparedness perspective. The inspectors concluded that the licensee was adequately implementing those areas.
The inspectors reviewed the fire protection program to assure the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, considering the plant conditions and activities during decommissioning in accordance with 10 CFR 50.48(f)(3). Additionally, the inspectors reviewed the licensees fire protection program for compliance with applicable requirements. The inspectors concluded that the licensee was adequately implementing their procedures and meeting regulatory and license requirements.
b.
Fire Protection Systems and Equipment The inspectors also observed the fire extinguishers and fire hose stations located throughout the facility and reviewed the fire systems maintenance program as defined by site procedure.
Fire extinguishers demonstrated to have an adequate annual maintenance tag, were not damaged, and had appropriate pressure gauge readings. The inspectors concluded that the licensee was adequately implementing the fire system maintenance and inspection program in accordance with their procedure and were meeting regulatory and license requirements.
c.
Control of Combustible Materials and Ignition Sources To minimizes the occurrence of fire, the majority of flammable materials have been removed from all four reactor locations as observed by the inspectors during walk downs.
d.
Organization The inspectors reviewed the site memorandum of understandings with the various groups who would respond to the site in the case of a fire or emergency. The site does not maintain a local fire brigade but does perform drills with local law enforcement and fire protection organizations as required. No drills were in progress to observe at the time of the inspection.
e.
Problem Identification and Resolution The inspectors reviewed various CRs associated with the fire protection program. All associated corrective actions had been taken and the inspectors verified these actions during site walkdowns.
3.3 Conclusions The licensee continued to effectively implement its fire protection program. The inspectors reviewed the fire hazard analysis, pre-fire plans and procedures for firefighting and determined that they were adequate. The licensee continued to effectively implement its fire system maintenance and inspection in accordance with procedures and regulatory requirements.
Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)
4.1 Inspection Scope To independently gather sufficient information to determine whether licensee performance meets the following objectives:
To ensure adequate protection of worker health and safety from exposure to radiation or radioactive material at permanently shutdown reactors.
- To evaluate whether the licensee adequately identified problems and implemented appropriate and timely corrective actions related to occupational radiation safety.
4.2 Observations and Findings a.
Organization, Changes, and Training
Since the last inspection, the licensees organization and personnel has undergone a further reduction in personnel with the pending transfer of the site to NorthStar Group.
The site still retains an interim contracted Radiation Safety Officer from Chesapeake Nuclear Services. No significant changes were noted in facilities, radiation instrumentation, equipment, programs, or procedures that may affect occupational radiation protection were noted.
b.
Radiological Work Planning and Observation At the time of the inspection, no radiological work was in progress. The inspectors performed tours of the radiologically controlled areas to verify appropriate radiological postings and evaluate material conditions.
c.
Dosimetry The licensee uses Landauer Incorporated for the processing of site occupational radiation exposure dosimetry. The inspectors reviewed Landauer Incorporateds National Voluntary Laboratory Accreditation Program certificate and noted the approved radiation test categories for each type of personnel dosimeter are consistent with the types and energies of radiation present and method of dosimeter use.
The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before being shipped for processing. The inspectors monitored site personal for placement and use of dosimeters for occupational exposure to radiation. No special exposures were planned for or had occurred at the time of the inspection.
d.
Airborne and Contamination Controls No work requiring respirator use was in progress at the time of the inspection. Monthly grab samples are performed of all reactor containment buildings and personnel breathing air was monitored by use of a single lapel monitor worn by an individual who entered all areas during the inspectors containment tours.
The inspectors observed locations where the licensee monitors potentially contaminated material leaving a radiologically controlled area (RCA). Specifically, workers exiting the RCA and performing contamination monitoring were observed to verify the appropriate methods used for control, survey, and release from these areas are sufficient to prevent the unintended release of radioactive materials from the site.
Inspectors verified that the licensee is ensuring the accuracy and operability of radiation monitoring instruments that are used to monitor areas, materials, and workers to ensure a radiologically safe environment by spot checking instruments actively being used during monitoring of personnel and equipment as they left the RCA.
e.
Problem Identification and Resolution The inspectors reviewed the licensees corrective action program, no problems or corrective actions were identified regarding occupational radiation exposure.
4.3 Conclusions The inspectors determined the licensee ensured adequate protection of worker health and safety from exposure to radiation or radioactive material in accordance with regulations.
Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
5.1 Inspection Scope To independently gather sufficient information to determine whether licensee performance meets the following objectives:
To ensure that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated from all established release points and releases from any unmonitored and uncontrolled discharged pathways are precluded.
- To ensure that Radiological Environmental Monitoring Programs (REMP) are effectively implemented.
5.2 Observations and Findings a.
Changes in Radwaste System Design and Operation No significant changes were made by the licensee since the last inspection.
b.
Radioactive Gaseous and Liquid Effluent Treatment The inspectors verified that the licensees annual REMP Effluent Monitoring and Surveillance Programs dated February 15, 2024, was submitted as required. No anomalous results, unexpected trends, or abnormal releases were identified.
c.
Radiological Environmental Monitoring Program The inspectors verified licensee environmental monitoring equipment is properly located, calibrated and maintained by visual inspection of select locations, additionally the inspectors interviewed personnel to ensure environmental samples are adequately collected.
The inspectors validated that vendor laboratories (Landauer Incorporated, Davi Laboratories, and GEL Laboratories) that are used to analyze REMP samples quality control program and inter-laboratory comparison programs were adequate.
d.
Problem Identification and Resolution No problems were identified or corrected regarding radioactive waste treatment or effluent and environmental monitoring since the last inspection.
5.3 Conclusions The inspectors determined the licensee ensured that the radioactive effluent sampling and analysis requirements are satisfied, and the REMP was effectively implemented in accordance with regulations.
Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
6.1 Inspection Scope The inspectors performed interviews with licensee staff and reviewed documents associated with shipment of licensed material to verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.
6.2 Observations and Findings a.
Radioactive Material Storage and Control The inspectors toured the radioactive waste storage facilities to observe the condition and marking of radioactive materials and to verify that radioactive materials were controlled, labelled, posted, and secured against unauthorized removal. Additionally, the inspectors verified that the areas met the requirements of their licensing basis.
b.
Radioactive Waste Processing The inspectors observed the waste processing system at the Waste Evaporation Plant and walked down accessible portions of the system to verify that the current system configuration and operation are in accordance with license commitments.
c.
Transportation of Radioactive Materials No transportation of radioactive materials has occurred since the last inspection.
6.3 Conclusions The inspectors did not identify any significant deficiencies in the licensees radioactive waste management or transportation of radioactive materials programs and procedures.
Exit Meeting Summary On October 9, 2024, the NRC inspectors presented the final inspection results to Kristopher Zanotto, Site Manager, and other members of the licensees staff. All proprietary information reviewed was returned to the licensee.
Attachment SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee K. Zanotto, VNC Site Manager H. Stuart, Radiation Protection Technician J. Ayala, Environmental, Health and Safety Manager T. McConnell, Regulatory Compliance and Manager Nuclear Test Reactor INSPECTION PROCEDURES IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors IP 69002 Class III Research and Test Reactors IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors IP 64704 Fire Protection Program at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors IP 84750 Radioactive Waste Treatment, Effluent and Environmental Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed None Discussed None LIST OF ACRONYMS ADAMS Agency Documents Access and Management Systems CFR Code of Federal Regulations CR Condition Report DOT U.S. Department of Transportation EVESR Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor GEH GE Hitachi Nuclear Energy Americas, LLC GETR General Electric Test Reactor NRC U.S. Nuclear Regulatory Commission NTR Nuclear Test Reactor QA Quality Assurance VBWR Vallecitos Boiling Water Reactor VNC Vallecitos Nuclear Center