M180206, GE Hitachi Nuclear Energy - Reply to a Notice of Violation

GE Hitachi Nuclear Energy - Reply to a Notice of Violation

ML18292A751
Person / Time
Site:	Vallecitos Nuclear Center
Issue date:	10/19/2018
From:	Feyrer M GE-Hitachi Nuclear Energy Americas
To:	Document Control Desk, NRC Region 4
References
IR 2018001, M180206
Download: ML18292A751 (4)

Text

• HITACHI GE Hitachi Nuclear Energy Matt J. Feyrer Site Manaser, Vallecitos Nuclear Center 6705 Vallecitos Rd M180206 Sunol, CA 94586 USA October 19, 2018 T 92S 918 6018 Matt feyrer@lge com U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-001

Subject:

Reply to a Notice of Violation

References:

1) NRC License DPR-1, Docket 50-18

2) NRC Inspection Report No, 50-00018/2018-001 and Notice of Violation, 9/19/18

3) GEH Reply to a Notice of Violation, 10/18/18 Attached to this letter is GE Hitachi Nuclear Energy, L.L.C (GEH) response to the Notice of Violation (NOV) described in Reference 2.

This submittal replaces the previous GEH Reply to the NOV (Reference 3) to delete an inaccurate statement.

If you have any questions regarding this matter, please contact me at (925) 918-6018.

Sincerely, C!~+(~ {~

Matt Feyrer, Site Manager Vallecitos Nuclear Center

Attachment:

GEH response to violation cc: NRC Region IV Administrator R. Browder, NRC RIV MJF 18-012

M180206 U.S. NRC October 19, 2018 Page 1 of 3 Attachment The information provided below summarizes the Notice of Violation dated September 19, 2018 associated with NRC Inspection Report 50-00018/2018-001 from an NRC inspection conducted July 31- August 2, 2018.

VIOLATION NO. 2018-001-01 NRC License No. DPA-1, Amendment 21, License Condition 3.a. states, In part, that the licensee shall possess the facility in the condition described in the "Rnal Report on Deactivation of Vallecitos Boiling Water Reactor" dated February 5, 1965.

"Final Report on Deactivation of Vallecitos Boiling Water Reactor," Section V., states, in part, that the condition, security and integrity of the retired facility will be checked during the inspection, and the integrity of the reactor vessel will be verified. In addition, Section II.A.3 specifies that a manometer located outside of containment will allow monitoring of the water level of the pressure vessel and that periodic readings of the manometer will be taken.

Licensee Procedure 6.2, "Patrols and Inspections," Revision 7, implements the license requirements as stated above, and establishes the periodicity of the inspections. Specifically, Section IV.D., "Annual inspections and Radiation Surveys" states, in part, that an annual inspection, radiation and contamination surveys, and other surveillance activities, including the interior of the containment building for Vallecitos Boiling Water Reactor (VBWR) are required to be performed by the facility license, as described above. In addition, Section IV.A.,

"EVESRNBWR Weekly Patrols" states, in part, that a routine patrol will be performed each week to check the VBWR reactor vessel water level.

Contrary to the above, the licensee failed to implement Procedure 6.2, "Patrols and Inspections," Revision 7, for the activities covering VBWR, as evidenced by the following two examples:

1. On December 9, 2017, the licensee failed to follow Procedure 6.2 and inspect the condition and integrity of the retired facility and verify the integrity of the reactor vessel during the annual inspection, when water was identified in the basement of VBWR.

Specifically, during the annual inspection and radiological survey, there was no assessment of structural integrity and radiological conditions of the facility in order to assess and mitigate the associated environmental radiological risk from the water in the basement. As a result of not taking any action, approximately 2,100 gallons of water remained in the basement of VBWR until June 21,2018, when the licensee pumped the water out of the basement.

2. Since May 2018, the licensee failed to take weekly readings of the manometer, to measure the water level in the VBWR reactor vessel, as required. Specifically, during calibration of the manometer in May 2018, the device was over pressurized and broke and the manometer has not been replaced.

This is a Severity Level IV violation (Section 6.3.d.3).

M180206 U.S. NRC October 19, 2018 Page 2 of 3 Attachment GEH's Response to Violation GEH does not contest the violation and has performed a casual analysis.

1) The reason for the violation:

Apparent Cause:

AC-1: Personnel failed to follow VNC Procedure 6.2 "Patrols and Inspections-EVESRNBWRIGETR Surveillance Procedures," to perform the annual inspection of the VBWR containment, and to perform the weekly readings of the VBWR water level because corrective actions were not taken in a timely manner to support completion of procedurally directed steps.

Causal Factors:

1. CF-1: Personnel failed to follow procedure VNC-EHS Procedure HS 12.1 - VNC Pre-job Briefs, to provide an adequate pre-job brief prior to performing the infrequent annual inspection of the VBWR.

2. CF-2: Personnel failed to follow VNC Procedure VSS 5.4, Radiological Surveys, to adequately review completed surveys for the VBWR basement. Supervision did not adequately review surveys for abnormalities or specific conditions that could be indicative of degradation.

3. CF-~: Personnel did not exercise questioning attitude or personal accountability in that no one questioned or challenged the inability to complete the procedural steps which require the surveys of the VBWR and the weekly readings of the VBWR reactor vessel water level to be recorded.

4. CF-4: Personnel failed to follow procedure VSS 3.0 Notifications and Reports to Regulatory Agencies, to notify specified site contacts for: 1} the observed condition of ground water in the basement inhibiting completion of procedure steps for an annual survey, and 2) the broken VBWR manometer.

2) Corrective actions (CAs) taken to bring facility back into compliance

1. AC-1 CA 1: The basement water was sampled on April19, 2018 and the results were reported to NRC in a supplement to the GEH Annual Shutdown Reactor Report on June 20, 2018. Water in VBWR basement was removed via the sump system and transferred on June 21, 2018 to the liquid radioactive waste evaporator for processing. The VBWR Annual Survey was completed on July 17, 2018 with no abnormalities observed.

2. AC-1 CA2: A replacement VBWR reactor vessel pressure gauge was procured and sent offsite for calibration. After calibration, the gauge was installed, and the manometer was returned to service on September 12, 2018. Weekly measurements were resumed. The

M180206 U.S. NRC October 19,2018 Page 3 of 3 Attachment water level in the VBWR reactor vessel was determined to be unchanged from previous measurements.

3) Preventive Actions (PA) to prevent and safeguard against future occurrences.

1. AC-1 PA1: Revise VNC Facilities Maintenance Procedure 6.2- Surveillance Procedures to clarify roles, responsibilities and expectation with additional notification requirements for abnormalities. Due: November 30, 2018

2. AC-1 PA2: Provide response described in "GEH Response Plan for NRC Request for Additional Information," (ML18087A384) to demonstrate how the site is meeting the requirements for radiological surveying and monitoring of the subsurface and groundwater around the shutdown reactors, and to provide an engineering structural analysis of the shutdown reactor facilities. Due: March 29, 2019

3. AC-1 PA3: Identify long term actions to address aging management and critical spare components of the shutdown reactor facilities. Due February 15, 2019

4. CF-1, CF-2, CF-4 PA4: Leadership will coach staff and supervisors on the importance of procedure adherence to the following procedures. Due: November 30, 2018

a. NC-EHS Procedure HS 12.1 - VNC Pre-job Briefs

b. VSS 5.4 Radiological Surveys

c. VSS 3.0 Notifications and Reports to Regulatory Agencies

5. CF-3 PAS: Leadership will train the staff and supervisors on the traits and attributes of a Healthy Safety Nuclear Culture. Due: December 14, 2018

4) Full compliance was achieved on September 12, 2018. Longer-term preventive actions are in progress.