IR 05000018/2020001

GE Hitachi Nuclear Energy - NRC Inspection Report 05000018/2020001, 05000070/2020001, and 05000183/2020001

ML20282B033
Person / Time
Site:	Vallecitos, Vallecitos Nuclear Center
Issue date:	10/20/2020
From:	Greg Warnick Division of Nuclear Materials Safety IV
To:	Feyrer M GE Hitachi Nuclear Energy
References
IR 2020001
Download: ML20282B033 (18)

Text

October 20, 2020

SUBJECT:

GE HITACHI NUCLEAR ENERGY - NRC INSPECTION REPORT 050-00018/2020-001, 050-00070/2020-001, AND 050-00183/2020-001

Dear Mr. Feyrer:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on September 8-10, 2020, 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), and Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR). The NRC inspectors discussed the results of this inspection with you and members of your staff on September 10, 2020. 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 enclosures, and your response 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 concerning this inspection report, please contact Stephanie Anderson at 817-200-1213, or the undersigned at 817-200-1249.

Sincerely, Gregory G. Digitally signed by Gregory G. Warnick Warnick Date: 2020.10.20 12:24:32 -05'00'

Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety Docket Nos.: 050-00018; 050-00070; and 050-00183 License Nos.: DPR-1; TR-1; and DR-10

Enclosure:

Inspection Report 050-00018/2020-001; 050-00070/2020-001; 050-00183/2020-001

REGION IV==

Docket Nos.: 050-00018; 050-00070; and 050-00183 License Nos.: DPR-1; TR-1; and DR-10 Report Nos.: 050-00018/2020-001; 050-00070/2020-001; and 050-00183/2020-001 Licensee: GE Hitachi Nuclear Energy Facility: Vallecitos Boiling Water Reactor (VBWR)

GE Test Reactor (GETR)

ESADA Vallecitos Experimental Superheat Reactor (EVESR)

Location: 6705 Vallecitos Road Sunol, California Inspection Dates: September 8-10, 2020 Inspectors: Stephanie G. Anderson, Senior Health Physicist Reactor Inspection Branch Division of Nuclear Materials Safety Chris D. Steely, Health Physicist Reactor Inspection Branch Division of Nuclear Materials Safety Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Office of Nuclear Materials Safety and Safeguards Anthony M. Huffert, CHP, Senior Health Physicist Reactor Decommissioning Branch Office of Nuclear Materials Safety and Safeguards N. Jeff Griffis, CHP, Senior Health Physicist Specialized Technical Training & Support Branch Office of the Chief Human Capital Officer Approved By: Gregory G. Warnick, Branch Chief Reactor Inspection Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY GE Hitachi Nuclear Energy NRC Inspection Report 050-00018/2020-001; 050-00070/2020-001; and 050-00183/2020-001 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of licensed activities being conducted at the three permanently defueled reactors at the Vallecitos Nuclear Center. 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 Review at Permanently Shutdown Reactors and Class III Research and Test Reactors

• The licensee conducted annual inspections and audits of the three shutdown reactors in accordance with regulatory, license, and procedure requirements. The licensee had implemented a fire protection program that reasonably prevented fires from occurring and was capable of rapidly extinguishing those fires that occurred. (Section 1.2)

Organization, Management and Cost Controls at Permanently Shutdown Reactors

• The licensee adequately implemented an organization that reflected the shutdown reactors license requirements and adequately managed the workload to support the shutdown reactors activities. (Section 2.2)

Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

• The licensee implemented its safety review program in accordance with its procedures and regulatory requirements. (Section 3.2)

Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors

• The licensee adequately implemented its corrective action program in accordance with regulatory requirements. (Section 4.2)

Occupational Radiation Exposure

• The licensee conducted its radiation control program in accordance with license conditions and regulatory requirements, with the exception of one violation in program areas related to occupational radiation exposure that will remain open from a previous inspection. (Section 5.2)

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

• The licensee implemented its effluent and environmental monitoring program in accordance with its Environmental Monitoring Manual and the regulatory requirements provided under 10 CFR Part 20. (Section 6.2)

Report Details Summary of Plant Status The GE Hitachi Nuclear Energy Americas, LLC (GEH or Licensee) continued to maintain the three shutdown reactors, Vallecitos Boiling Water Reactor (VBWR), General Electric Test Reactor (GETR), and Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor (EVESR) in a possession-only, safe storage (SAFSTOR)

condition, with no fuel remaining in the reactors or spent fuel pools. The condition of SAFSTOR is a decommissioning alternative in which the licensee is authorized to maintain the facility in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated to levels that permit release for unrestricted use within 60 years of permanent cessation of operations. Licensees who choose the SAFSTOR option must meet all NRC financial and safety regulations, both prior to and during the SAFSTOR period.

On April 24, 2015 (ADAMS Accession Nos. ML15114A437 and ML15114A438), the licensee submitted a request for a partial site release of approximately 610 acres of non-impacted property on the northern section of Vallecitos Nuclear Center (VNC) site, for unrestricted use pursuant to Title 10 Code of Federal Regulation (CFR) 50.83(b). The NRC approved the partial site release of 610 acres by letter dated May 3, 2016 (ADAMS Accession No. ML16007A348). The property continues to remain under the ownership of GEH.

On December 15, 2015, the licensee submitted a request for license continuance under 10 CFR 50.51(b) for reactor licenses DR-10 and TR-1 (ADAMS Accession No. ML15349A045).

That request was approved by letter dated January 2, 2019 (ADAMS Accession No. ML18352A450). The licensee also submitted a request on July 10, 2015 (ADAMS Accession No. ML15195A088) for an alternate decommissioning schedule as described in 10 CFR 50.82(a)(3) and 50.82(b)(4)(i), using the exemption criteria of 10 CFR 50.12.

On May 16, 2017, the NRC staff issued a request to GEH for additional information on the structural integrity of the reactor buildings and how the integrity would be ensured during the extended decommissioning period, in order to assess whether the request would result in undue risk to public health and safety (ADAMS Accession No. ML17138A121). The licensee responded to this request by letter dated July 31, 2017 (ADAMS Accession No. ML17212B019).

Based on this response and a site visit conducted by NRC on September 13, 2017, the NRC determined that certain additional information must be provided by GEH to show how the licensee is ensuring the confinement of residual radioactivity associated with the shutdown reactors at the VNC and evaluating and monitoring the long term physical safety of the reactor structures. The NRC requested more detailed information by letter dated January 18, 2018 (ADAMS Accession No. ML17312B359). On March 28, 2018 (ADAMS Accession No. ML18087A384), GEH provided a response indicating that it would provide an interim status report for the hydrological and structural analyses in approximately 6 months and anticipated completing the actions within approximately 12 months, which would be March 2019. On May 31, 2018 (ADAMS Accession No. ML18151A861), GEH submitted a partial response to the request for additional information. On October 23, 2018 (ADAMS Accession No. ML18296A159), GEH provided an interim status report on the efforts to respond to the two remaining requests for additional information. On March 28, 2019 (ADAMS Accession No. ML19087A221), GEH provided the response for some of the requested additional information, and provided a schedule for submitting the remaining hydrological and structural analysis needed to support the exemption request for an alternate decommissioning schedule.

On November 15, 2019 (ADAMS Accession No. ML19319B845), GEH provided its final response on the request for additional information. By letter dated March 16, 2020 (ADAMS Accession No. ML20071G411), the NRC staff requested additional information for EVESR and GETR to make an independent assessment regarding the acceptability of the proposed exemptions. GEH responded to that request for additional information by letter dated July 15, 2020 (ADAMS Accession No. ML20197A011). Also, on July 15, 2020 (ADAMS Accession No.

ML20174A114), NRC staff requested additional information for the VBWR to make an independent assessment regarding the acceptability of the proposed exemptions. As of the time of this inspection, a complete response had not been formally submitted to the NRC.

On December 14, 2018 (ADAMS Accession No. ML18348A425), the licensee submitted a request for a partial site release of approximately 7 acres of non-impacted property along Vallecitos Road to be made available to Alameda County Transportation Commission to support road development and widening. The NRC held a public meeting in Dublin, CA on March 28, 2019, as required by 10 CFR 50.83, Release of part of a power reactor facility or site for unrestricted use, to discuss the request for the partial site release. On September 30, 2019, the NRC approved the request for the partial site release (ADAMS Accession No. ML19249C554).

1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801) and Class III Research and Test Reactors (69002)

1.1 Inspection Scope The inspectors reviewed the licensees control and oversight of the three shutdown reactors.

1.2 Observations and Findings a. Status and tours of the shutdown reactors 1. Vallecitos Boiling Water Reactor Vallecitos Boiling Water Reactor (VBWR) is a possession-only reactor under License No. DPR-1, Amendment 21. It was a 50-megawatt (MW) power reactor that achieved full power operations in 1957, after receiving its Construction Permit No. CPPR-3 on May 14, 1956. It was shut down on December 9, 1963, for an extended period of time and subsequently was deactivated. All fuel has been removed from the facility.

The possession-only facility license DPR-1, License Condition 4 states in part, that there should be an audible control device maintained on the doors to the containment building. In addition, License Condition 5 authorizes GE Hitachi (GEH) to dispose of component parts or devices from the VBWR facility in accordance with the provisions of 10 CFR Part 20. The licensee removed extensive components from the facility between October 2007 and November 2008. All reactor systems have been removed except for the reactor vessel. The licensee monitors the water level weekly in the reactor vessel and the inspectors confirmed that it had remained essentially constant at approximately 96 inches of water, since the last NRC inspection conducted in September 2019.

The inspectors toured the facility with licensee representatives. The inspectors confirmed there was an audible control device functioning on the manual doors to the containment building that provided an alarm at the 300-area alarm panel and at the Central Alarm Station. The inspectors observed that the roll-up door was secured, which was installed in place of the equipment hatch. The inspectors entered the basement level to observe the condition and integrity of the retired facility. The inspectors observed crack formation. The cracks are being monitored by the licensee to determine growth rate. During the inspection, the inspectors did not identify any water on the floor of the basement. The sump pump was in operation at the time of the inspection, and any water that is collected in the basement of VBWR is pumped to the VBWR transfer tank, then ultimately transferred to the onsite waste evaporator plant for processing.

2. ESADA Vallecitos Experimental Superheat Reactor The ESADA Vallecitos Experimental Superheat Reactor (EVESR) is a possession-only reactor under License No. DR-10, Amendment No. 7. The EVESR was a light water moderated, steam cooled, superheat, experimental research reactor that used slightly enriched uranium dioxide as fuel. It operated at a maximum of 17 MW thermal and was initially licensed in 1963. It achieved full power operation in 1964, and was shut down on February 1, 1967, and subsequently deactivated. All fuel and other special nuclear material had been removed and shipped offsite. In addition, a significant amount of equipment used to operate the reactor, such as nuclear instrumentation, piping, pumps, and valves has been removed.

The inspectors toured the facility with licensee representatives. The inspectors confirmed there was an audible control device functioning on the airlock door to the containment building that provided an alarm at the 300 feet elevation area alarm panel and at the Central Alarm Station. The licensee had a portable dehumidifier to remove significant quantities of condensation that tended to buildup in the facility. The licensee had lighting installed and it was operating sufficiently to ensure the passageways and stairs were safely lit. The stack was no longer operational, and the licensee was using a portable ventilation system.

The radiation levels were generally less than 1 milliroentgen per hour (mR/hr) throughout the facility, except in certain areas. The inspectors measured 460 microroentgen per hour (µR/hr) on the two emergency cooling discharge valves located on the 534-ft level, using a Thermo Scientific RadEye G survey meter (Serial No. 30728, calibration due date of December 16, 2020). The licensee maintained concrete blocks over the reactor vessel and the head/shield plug storage pit. In addition, a wooden cover was installed over the empty spent fuel storage pool, with an installed railing to prevent entry since the wooden cover was not designed to support a load. The licensee maintained control of the keys to the locked cover installed over the stairwell that provided access to areas below the main 549-ft level.

3. General Electric Test Reactor The General Electric Test Reactor (GETR) is a possession-only reactor under License No. TR-1, Amendment No. 17. The reactor was a 50 MW thermal experimental test, development, and isotope production reactor that utilized highly enriched plate fuel and was initially licensed to operate in 1959. The reactor was shut down in 1977 and subsequently deactivated. All fuel and isotope production targets containing special nuclear material have been removed from the facility and shipped offsite. The reactor, systems and piping, and spent fuel pool have been drained of water. The containment polar crane was functional, and only required re-certification for it to be considered operable.

The inspectors toured the containment building and GETR auxiliary buildings immediately adjacent to the containment structure. The radiation levels inside the containment building were generally less than 1 mR/hr throughout the facility, except in certain areas. The inspectors measured 3.5 mR/hr about 1 foot away on the outside of the locked Experiment Liquid Effluent Holdup System cubicle door.

As GETR has been shut down since 1977, there are no licensed operators nor a requalification program, which is appropriate for the plant conditions. Staffing was appropriate to meet the required weekly surveillance patrols, which were being conducted in accordance with site procedures.

b. Fire Protection The licensee is required under 10 CFR 50.48(f) to maintain a fire protection program to:

(1) reasonably prevent fires from occurring; (2) rapidly detect, control, and extinguish those fires that do occur and that could result in a radiological hazard; and (3) ensure that the risk of fire-induced radiological hazards to the public, environment, and plant personnel are minimized. The three shutdown reactors are required to have a fire protection program; however, they are not required to maintain fire detection or suppression equipment at their facilities because the majority of flammable materials have been removed. The inspectors reviewed the fire protection program from an emergency preparedness perspective to verify that the program can reasonably prevent fires from occurring and rapidly extinguish those fires.

1.3 Conclusions The licensee conducted annual inspections and audits of the three shutdown reactors in accordance with regulatory, license, and procedure requirements. The licensee had implemented a fire protection program that reasonably prevented fires from occurring and was capable of rapidly extinguishing those fires that occurred.

2 Organization, Management and Cost Controls at Permanently Shutdown Reactors (36801)

2.1 Inspection Scope The inspectors evaluated the licensees organizational structure to support licensed activities and regulatory requirements.

2.2 Observations and Findings The licenses for the three shutdown reactors require in part, that activities involving access to the facility area and use of any area shall be conducted under the direction of a designated facility manager with functional responsibility and commensurate authority to maintain the facility in a safe and secure condition at all times. The inspectors reviewed the licensees organization and discussed the organizational structure with members of the licensees organization. Based on discussions and observations, the inspectors determined that the individual fulfilling the licensed responsibility as the facility manager for the defueled reactors, adequately met the license condition requirements.

The inspectors reviewed the 2019 Safety Culture Assessment Report. The inspectors noted that the assessment was detailed and inclusive of areas of improvement over the preceding year but also of areas where critical observations were made indicating needed performance improvement. It was noted by the inspectors that many of these observations and critiques were documented in the licensees corrective action program and dispositioned with the appropriate management review. The licensees Safety Conscious Work Environment program is being managed effectively with the appropriate amount of managerial oversight. In the area of assessments, the inspectors also reviewed the GEH Annual Shutdown Reactor Reports for the Year 2019, and CP-18-202-F02, Focused Self-Assessment Report dated July 29 - August 2, 2019. All assessments appear to be appropriately focused and self-critical with a management review process to ensure deficiencies are addressed.

In the area of training the inspectors focused on radiological training. The inspectors reviewed VSS 8-1, Radiological Training, Revision 11 and VSS 7.3, Radioactive Waste Handling, Revision 19. It was noted by the inspectors that all qualified radiological workers had received the appropriate training as required by licensee procedures.

The inspectors completed a review of various license and regulatory requirements while onsite. The licensee is managing the site as required by all regulatory and license requirements including the management of their decommissioning file as required by 10 CFR 50.75(g).

2.3 Conclusions The licensee adequately implemented an organization that reflected the shutdown reactors license requirements and adequately managed the workload to support the shutdown reactors activities.

3 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (37801)

3.1 Inspection Scope The inspectors reviewed the licensees control and oversight of the safety review program to ensure design changes, tests, experiments and modifications were effectively conducted, managed, and controlled during plant decommissioning.

3.2 Observations and Findings Within the past three years, the licensee has only made one modification to the existing plant systems of VBWR, EVESR, and GETR. This is due to the length of time since shutdown for VBWR, EVESR, and GETR that most, if not all, reactor systems, with the exception of the vessels, have been removed. All three reactors have been in SAFSTOR status for several decades.

In 2019 there were no 10 CFR 50.59 evaluations or modifications by the licensee for review. However, the inspectors reviewed FMP 6.3, Use and Modifications of Facilities, Revision 2 and the training program. It was noted by the inspectors that all licensee personnel who were qualified to perform 50.59 evaluations have been appropriately trained as required by licensee procedure. The licensee procedure to implement 50.59 evaluations appeared to be effective and met regulatory requirements.

3.3 Conclusions The licensee implemented its safety review program in accordance with its procedures and regulatory requirements.

4 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors (40801)

4.1 Inspection Scope The inspectors reviewed the licensees corrective action program related to the oversight of the three shutdown reactors.

4.2 Observations and Findings At the time of the inspection the licensee was implementing its corrective action program under procedure CP-16-108, Corrective Action Program, Revision 12. The procedure applies to the GE Hitachi nuclear sites and facilities at VNC. According to the procedure, any employee may initiate a condition report (CR).

The priority levels for issues identified in the corrective action program ranged from A to D, with A being a significant condition adverse to quality, safety or security, B was a condition adverse to quality, safety or security, C was similar to broke/fix or conditions that had minimal effect on the safe or reliable operation of a facility, and D was considered an improvement item.

In addition to procedure CP-16-108, the inspectors also reviewed procedures WI-16-108-01, Condition Review Process, Revision 9, WI-20-106-06, Corrective Action Program Qualifications, Revision 6, CP-15-07, Stop Work Notice, Revision 7.2, and a list of CRs related to the shutdown reactors that were issued since NRC inspection 2019-001 in March 2019, including four specific CRs related to the shutdown reactors (CRs 31073, 31951, 33068 and 33109) for adherence to the corrective action procedure, and a trend analysis of CR categories from 2009 through 2019.

4.3 Conclusions The licensee adequately implemented its corrective action program in accordance with regulatory requirements.

5 Occupational Radiation Exposure (83750)

5.1 Inspection Scope The inspectors reviewed the licensees radiation protection program related to the oversight of the three shutdown reactors.

5.2 Observations and Findings Each of the shutdown reactors have license conditions that require annual entries for routine radiation surveys and general examination of conditions throughout the buildings. The licensee performed its entries and surveillances in accordance with procedures 6.1, Access Control, Revision 9, and 6.2, Patrols and Inspections, Revision 13. The licensee submitted a summary report of these entries to the NRC on March 25, 2020. Based on the entries that were conducted and the documentation generated to support the entries, the inspectors determined that the dose rates and air sample results were consistent with historical data documented in previous annual reports. Some of the reported radiological contamination levels in the shutdown reactors were higher than what was published in previous reports, but the increased levels were due to changes in the methods that the licensee used to collect and process smear samples, and not due to actual leaks or spills of radioactive material.

In addition to the routine annual entries, the licensee had performed several other entries into the three shutdown reactors since the last inspection. These entries were made for various purposes, including performance of general housekeeping tasks, industrial safety assessments, and evaluation of areas within the reactors for current radiological conditions. For entries into the shutdown containment buildings, licensee personnel wore coveralls, booties, and gloves to minimize contamination. All entries into the shutdown containment buildings included at least one radiation protection staff who wore a lapel air sampler for the duration of the entry. The inspectors reviewed the radiation protection controls that were implemented for several entries into the shutdown reactors, including: the radiological work permits used, air sampling and contamination controls, respiratory protection equipment, and assessment of internal dose. Air sampling data was reviewed for all entries into the shutdown reactors, and bioassay data and derived air concentration-hour calculations were reviewed for specific entries into the VBWR basement and the experimental effluent holdup system room in GETR. The inspectors also reviewed the licensees procedures for airborne monitoring, air sample analysis, and internal dose assessment based on air sampling and bioassays. The inspectors discussed how these procedures were implemented for certain entries into the VBWR basement, as well as recent and ongoing revisions to these procedures.

During the inspection, the inspectors toured accessible areas within the VBWR, EVESR, and GETR containment buildings to observe radiological postings and access controls. The inspectors also performed independent radiation surveys to ensure that postings adequately reflected the radiological hazards using a Thermo Scientific RadEye G survey meter (Serial No. 30728, calibration due date of December 16, 2020). Through performance of these surveys, the inspectors determined that the postings and controls within the areas were adequate to protect worker health and safety.

During the March 2019 NRC inspection, the inspectors identified a violation (VIO 0500018/2019001-03) associated with 10 CFR 20.1501(c), which stated the licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured. Specifically, the inspectors determined that the licensee had not sampled and analyzed for hard-to-detect radionuclides (i.e., low-energy beta emitters such as carbon-14 and nickel-63) or transuranics in the shutdown reactors, even though such radionuclides could exist in the buildings due to the sites operational history. Without knowing the specific radionuclides that were present in the containment buildings, the licensee could not design a survey program that could adequately detect or quantify the radioactivity in those buildings.

The licensee responded to the Notice of Violation (NOV) by letter dated July 23, 2019 (ADAMS Accession No. ML19205A023) and submitted various corrective actions. The corrective actions included preparing a Radiological Characterization Plan for the VBWR, EVESR, and GETR containment buildings, conducting surveys in the shutdown reactors in June 2019, and completing a survey report in November 2019. During the March 2019 NRC inspection, the inspectors collected a limited number of dry smear samples within the shutdown reactors to identify radionuclides that could be present. These samples were subsequently analyzed at an independent laboratory for a broad range of radionuclides (including hard-to-detect radionuclides and transuranics). The inspectors and licensee discussed preliminary results of the NRCs surveys and the licensees surveys during the previous inspection and this inspection. Based on these discussions and additional information requested from the inspectors on the licensees survey procedures, the licensee plans to further review its radiological survey procedures and characterization data this year. Therefore, this violation will remain open.

During the March 2019 NRC inspection, the inspectors identified a violation (VIO 0500018/2019001-04) associated with 10 CFR 20.1703(c)(1), which stated that the licensee shall implement and maintain a respiratory protection program that includes air sampling sufficient to identify the potential hazard, permit proper equipment selection, and estimate doses. The inspectors had determined that workers had entered the VBWR basement on at least one occasion to perform non-routine work that involved vacuuming and cleaning of radioactive sediments. No air samples were taken during these non-routine activities to determine whether radioactive material in the sediments had become airborne and posed an internal hazard to the workers. Because no air sampling was performed, the licensee failed to identify whether airborne radioactive material was generated during these activities, and thus failed to identify the potential hazards to the workers. In addition, the failure to identify what airborne concentrations of radioactive material may have

been generated from the activities resulted in a failure to estimate potential doses to the workers.

The licensee responded to the NOV by letter dated July 23, 2019 (ADAMS Accession No. ML19205A023). In their response, the licensee listed several completed and ongoing corrective actions, including issuance of a limited stop-work notice that stipulated all entries into the shutdown reactors were required to have lapel monitoring and coverage by Health Physics staff. Additional corrective actions were reviewed during the NRC September 2020 inspection. These additional corrective actions included collecting and analyzing bioassay samples from workers who had performed work in the VBWR basement, hiring a consultant to perform dose assessments for various VNC staff who had performed non-routine work activities in potential airborne radioactive materials areas, and systematically reviewing the radiation protection procedures that were used in support of respiratory protection, air sampling, count room analysis, and internal dose assessment. The inspectors discussed the completed and ongoing corrective actions with the licensee, and reviewed air sampling and bioassay data for all employees who had entered potential airborne areas in the shutdown reactors since 2018. Through these discussions and reviews, the inspectors determined that the licensees corrective actions were adequate, and this violation is closed.

5.3 Conclusions The licensee conducted its radiation control program in accordance with license conditions and regulatory requirements, with the exception of one violation in program areas related to occupational radiation exposure that will remain open from a previous inspection.

6 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)

6.1 Inspection Scope The inspectors reviewed the licensees effluent and environmental monitoring program for the facility.

6.2 Observations and Findings The licensee submitted its 2019 annual report for the Effluent Monitoring and Environmental Surveillance Programs as required by various site licenses and permits issued by the NRC and the State of California. The inspectors reviewed the sample collection requirements provided in the Environmental Monitoring Manual and concluded that the licensee was performing its sample collection in accordance with the manual to support the sites environmental monitoring program. The licensee collected and analyzed environmental data for air, groundwater, sediments, vegetation, and surface water basins in accordance with its procedures. The analysis results documented that no radiological material was released in quantities equal to, or greater than the regulatory limits provided in 10 CFR Part 20, Appendix B, Table II, for gaseous and liquid effluents. In addition, none of the environmental samples reported levels of radioactive material that exceeded the action levels published in the licensees Environmental Monitoring Manual. Inspectors discussed programmatic changes with the

licensee involving their effluent and environmental monitoring programs, including revisions to pertinent procedures, the increased use of their onsite count room for sample analyses, and the implementation of action levels for various samples. Several audits had been performed (by both GE staff and by external consultants) in the areas of effluent and environmental monitoring since the last inspection. Results of these audits were discussed with the licensee, along with the corrective actions and program improvements that were directly related to the audits.

The inspectors walked down the areas exterior to the VBWR, EVESR, and GETR. This was done to ensure that measures are being taken to monitor for potential groundwater contamination/migration from the shutdown reactors and to ensure that measures are taken to minimize contamination of the environment until future decommissioning.

GEH submitted their 2019 Annual Shutdown Reactor Report to the NRC on March 25, 2020 (ADAMS Accession No. ML20091H582). By letter dated June 3, 2020 (ADAMS Accession No. ML20132A091), NRC sent a request for additional information regarding the groundwater sampling and analysis. GEH responded by letter dated July 1, 2020 (ADAMS Accession No. ML20183A221). One outcome of this response was that GEH had existing non-monitored sumps and wells evaluated for feasibility and suitability as groundwater monitoring wells. Based on that evaluation, GEH is planning to modify the groundwater extraction well southeast of EVESR to accommodate sample collection, and the Environmental Monitoring Manual has been revised to include the location into VNCs groundwater monitoring regime. Sampling will commence upon completion of the necessary well modifications, anticipated by the end of year 2020. The final evaluation/implementation will be done through the reuse or modification of the shutdown reactor facilities process using procedure 6.3, Use and Modification of Facilities, Revision 2.

GEH has also evaluated existing potential background monitoring well locations and identified a suitable well to be utilized as a control location within the radiological groundwater monitoring program. The VNC Environmental Monitoring Manual has been revised to include an existing monitoring well to be utilized as the control well. The licensee also discussed current evaluations underway to potentially install a sump exterior to the VBWR as a way to control water infiltration into the basement of that building.

At GETR the inspectors walked down the exterior areas and evaluated CRs related to the groundwater monitoring at GETR. This was done to ensure that measures are being taken to monitor for potential groundwater contamination/migration from GETR and to ensure that measures are taken to minimize contamination of the environment until future decommissioning of that facility.

An evaluation is ongoing for the Tank Farm adjacent to GETR, which is considered a potential source for subsurface soil and groundwater contamination. The need for additional groundwater monitoring, i.e., a replacement for well B-2, is included as an element of this evaluation. Condition Report-31951 evaluated eliminating monitoring well B-2 from the routine groundwater sampling program due to the issues with obtaining reliable representative samples from it, and replacing it with well MW-8, which was installed last year specifically to monitor the groundwater at GETR. The evaluation identified that at least four quarters of monitoring data from B-2 would be necessary

before the evaluation could be completed for abandoning the well. However, before those quarterly sampling events could be completed, part of the sampling device became lodged in the well making sampling attempts unsuccessful. The status of well B-2 was therefore indeterminate. The NRC will review its status in review of the next Annual Shutdown Reactor Report and/or site inspection.

6.3 Conclusions The licensee implemented its effluent and environmental monitoring program in accordance with its Environmental Monitoring Manual and the regulatory requirements provided under 10 CFR Part 20.

7 Exit Meeting Summary On September 10, 2020, the NRC inspectors presented the final inspection results to the Site Manager and other members of the licensees staff. The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary information. No proprietary information was identified.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee M. Feyrer, Site Manager J. Smyly, Environmental, Health and Safety Manager D. Heckman, Regulatory Affairs and Licensing Lead K. Zanotto, Lead Manufacturing Projects J. Ayala, Radiation Protection Supervisor INSPECTION PROCEDURES IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 69002 Class III Research and Test Reactors IP 36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 40801 Self-Assessments, Auditing, and Corrective Action at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 05000018/2019001-04 VIO Failure to implement and maintain a respiratory protection program, for activities associated with air sampling of the containment buildings in compliance with 10 CFR 20.1703(c)(1).

Discussed 05000018/2019001-03 VIO Failure to ensure that instruments and equipment used for radiation measurements in the containment buildings are calibrated for the radiation measured in compliance with 10 CFR 20.1501(c).

Attachment

LIST OF ACRONYMS ADAMS Agency Documents Access and Management Systems CFR Code of Federal Regulations CR Condition Report EVESR Empire State Atomic Development Associates Incorporated Vallecitos Experimental Superheat Reactor GEH GE Hitachi Nuclear Energy Americas, LLC GETR General Electric Test Reactor mR/hr milliroentgen per hour MW Megawatt NRC U.S. Nuclear Regulatory Commission NOV Notice of Violation

µR/hr microroentgen per hour VBWR Vallecitos Boiling Water Reactor VIO Violation VNC Vallecitos Nuclear Center 2