ML082960907

GE Hitachi - Notification of Potential Technical Specification Violation for EVESR

ML082960907
Person / Time
Site:	Vallecitos File:GEH Hitachi icon.png
Issue date:	09/26/2008
From:	Don Krause GE-Hitachi Nuclear Energy Americas
To:	Whitten J NRC Region 4
References
Download: ML082960907 (18)

Text

U.S. NRC Region IV Texas Health Resources Tower 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Energy, Nuclear Donald R. Krause Monager, Regulatory Cornplionce and EHS Vallecitos Nuclear Center 6705 Vollecitos Rd Sunol, CA 94586 U5A T925 862 4360 Donold.Krause@ge.com F 925 304-7435 26 September 2008 Attention: Jack Whitten

Reference:

(1) License No. DR-10, Amendment 6, Docket No 50-183.

Enclosures:

Notification of potential Technical Specification violation for EVESR.

(1) EVESR Technical Specification, Amendment 7 Request dated 23 (2) EVESR no significant hazard analysis (letter from Latonya Mahlahla (3) EVESR no significant hazard analysis (letter from Latonya Mahlahla (4) Supplemental correspondence in Support of the Technical June 2008.

to Document Control Desk 8/11/08, LLM-2008-23).

to Document Control Desk 8/19/08, LLM-2008-24).

Specification amendment application from the Vallecitos Nuclear Center, emails dated: 3/12/08, John Buckley to David Turner; 3/17/08, John Buckley to David Turner; 5/12/08, David Turner to Staff.

(5) Timeline of events.

As reported by telephone to Bob Evans (GEH VNCs assigned NRC Inspector) office voice mail on Thursday, September 18,2008, and in phone conversation with you on 26 September 2008, Vallecitos Nuclear Center is informing you of a potential Technical Specification violation of License No. DR-10, Amendment 6. Specifically, equipment removal work was allowed to take place below the 549 ft. level on 15 September 2008 for a period of approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. All work below the 549 ft level has been halted as the immediate action. Longer-term corrective actions will be accomplished through the previously submitted Technical Specification change.

Vallecitos Nuclear Center (VCN) self-reported this potential violation after it became clear to us, through conversations with the NRC Project Manager that a difference in interpretation of Technical Specification 2(a) exists between VNC management and the NRC.

This difference in interpretation was surprising to VNC management, as we had thought we had communicated our intentions and expectations well and in sufficient Generol Electric Compony EVESRTech Spechdoc

detail to prevent confusion of our intentions. VNC Management believed, between 17 March and 18 September 2008, the NRC concurred with our decision to commence equipment removal of component parts or devices from the EVESR below the 549 level.

As a method of clarification an event timeline has been developed and is included as. Enclosures 1 - 4 are included to complete the background information.

If you have any questions or need additional information, please contact me at 925-862-4360 or David Turner at 925-862-43 Donald R.

Sincerely yours, DGnald R. Krause Mgr. Regulatory Compliance and EHS 9J uccp--

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9.26 135454 -0700 Y ii 3 le 4 4 Poge 2 of 2 to Letter from D. Krause to J. Whitten Potential EVESR Tech Spec Violation

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Nuclear Energy U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Roc kvi I le, Maryland 2085 2-2 738 Attn: Document Control Desk LaTonya Mohlahlo Vollecitos Nuclear Center 6705 Vollecitos Rd Sunol, CA 94586 USA T9258624360 Lotonyo.mohlohlo@ge.com F 910-341-2972 June 23,2008

Reference:

License DR-10, Docket 50-183

Enclosures:

EVESR Technical Specifications, Amendment 7

1) Appendix A, EVESR Technical Specifications Affected pages 1 & 3

2) Appendix A, Technical Specifications EVESR (Complete set incorporating proposed changes)

Paragraph 3.C of License No. DR-10, Amendment No. 6 authorizes GE-Hitachi to dispose of components parts or devices from the EVESR facility in accordance with the provision of 10 CFR Part 20. GEH plans to begin removal of piping, pumps, valves, control systems, walkways and some non-structural shielding as part of The Vallecitos Nuclear Center Liabilities Reduction Project as authorized. There are no plans to remove the reactor vessel or the biological shield.

To clarify the scope of these activities and specify the radiological control requirements of 10 CFR Part 20, GEH requests the following changes to the EVESR Technical Specifications:

Proposed Change 1) Delete provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areas below the 549-ft. elevation within the containment building from page 1 of Technical Specification Section A.2. GEH request condition A.2 be amended as follows:

A.2 The principal activities carried on within the plant area shall be the possession of the reactor facility, the dismantling of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory authorities.

LLM-2008-19 EVESR Technicol Specificotion Change to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Proposed Change 2) Delete the paragraph below condition C.3, Surveillance and Security in its entirety and replace with the following:

"Access to areas of the EVESR containment shall be controlled in a manner consistent with the requirements of 10 CFR 20.1601, Control of access to high radiation areas, as applicable."

The scope of the work associated with the liabilities reduction project will involve access to areas below 549-ft. elevation. Recent radiological surveys of the accessible areas below the 549-ft. elevation indicate that not all areas meet the High Radiation Area Controls criteria as specified in 10CFR20. Routine radiological surveys will be performed during the work and the areas will be posted and controlled consistent with the requirements of 10 CFR Part 20. includes marked up pages 1 and 2 of the proposed changes. Enclosure 2 is a complete set of Technical Specifications incorporating the proposed changes identified in.

Upon approval, GEH requests issuance of Enclosure 2 as the complete set of Technical Specifications for EVESR License DR-10.

If you have any questions or need additional information, please contact me at 925-862-4360.

Sincerely Yours, LaTonya L. Mahlahla Mgr., Regulatory Compliance & EHS cc: John Buckley Bob Evans Page 2 of 2

.,,,........ r

..... to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Appendix A, EVESR Technical Specifications Affected pages 1 & 3 I

to Letter from D. Krause to J. Whitten. Potential EVESR Tech Spec Violation APPENDIX A TECHNICAL S PECIFICATLONS 9

EVESR A.

SITE -

1. Plant Area

• The p l a n t area s h a l l c o n s i s t of a controlled access area defined by the-reactor containment building and i t s v e n t i l a t i o n system.

access s h a l l be controlled by knowledgeable plant personnel as established Personnel by w r i t t e n procedure m+c

2.

Principal A c t i v i t i e s The p r i n c i p a l activities c a r r i e d on within the p l a n t area s h a l l be the possession of the r e a c t o r f a c i l i t y, the dismantling of components other than the r e a c t o r pressure vessel and activities authorized by licenses B.

ADMINISTRATIVE AND PROCEDURAZ REQUIREMENTS I, General A c t i v i t i e s involving access t o the plant area and use oE any area o r in-place equipment s h a l l be conducted under the d i r e c t i o n of a designated f a c i l i t y supervisor with functional r e s p o n s i b i l i t y and commensurate

-9.. to Letter from D. Krause to J. Whrtten: Potential EVESR Tech Spec Viqlition I

of 10 CFR Part 20.

A general r a d i a t i o n survey shall be conducted, at.

' v" 2.

Ventilation

• A v e n t i l a t i o n p a r t i c u l a t e monitor s h a l l be operable whenever the contain-ment building is v e n t i l a t e d.

• 3..

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ment removed from radioactive materials areas s h a l l be monitored aid released i n accordance with VaLlecitos Nuclear Center s i t e *procedureB*

1 and i n compliance w i t h the standards of 10 CFR Part 20.

D.

RECORDS Appendix A p5J;:c 3

... to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Appendix A, EVESR Technical Specifications Complete set incorporated proposed changes '

to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Appendix A to License DR-10 EVESR Technical Specifications

1.

Plant Area

• The Plant area shall consist of a controlled access area defined by the reactor containment building and its ventilation system. Personnel access shall be controlled by knowledgeable plant personnel as established by written procedure.*

.I

2.

Principal Activities The principal activities carried on within the plant area shall be the possession of the reactor facility, the dismantling of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory authorities, I

6.

ADMINISTRATIVE AND PROCEDURAL REQUIREMENTS

1. General Activities involving access to the plant area and use of any area or in-place equipment shall be conducted under the direction of a designated facility supervisor with functional responsibility and commensurate authority to maintain the facility in a safe and secure condition at all times. The facility manager shall have extensive reactor knowledge and shall utilize the resources of other licensee personnel as necessary to provide an effective safety program.

2.

Review and Audit (a)

Written procedures for control of access to the plant area, use of the plant area facilities and equipment and for periodic inspection of the facility shall be established and approved by the manager to whom the facility supervisor reports.

(bl Written procedures specified in 2.(a) above shall be reviewed by technically qualified personnel responsible to a management position other than the facility supervisor (the Nuclear Safety group) in accordance with a written charter for that function.

fcl The Nuclear Safety group shall periodically audit activities conducted in the plant area to verify that effective radiological control practices are maintained.

Page 1 of 2 to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Appendix A to License DR-10 EVESR Technical Specifications C.

HEALTH AND SAFETY

1.

Radiation Monitorinq Radiation monitoring instruments shall be available as appropriate to prevent exposure of personnel to radiation in accordance with the standards of 10 CFR part 20. A general radiation survey shall be conducted at least annually.

2.

Ventilation

• A ventilation particulate monitor shall be operable whenever the Containment building is ventilated.*

3.

Surveillance and Security Access to areas of the EVESR containment shall be controlled in a manner consistent with the requirements of 10 CFR 20.1601, Control of access to hiqh radiation areas, as aDDlicable.

4.

Removal of Materials and Equipment As a radiation and contamination control measure, all materials and equipment removed from radioactive materials areas shall be monitored and released in accordance with Vallecitos Nuclear Center site *procedures* and in compliance with the standards of 10 CFR part 20.

D.

RECORDS Sufficient records shall be kept to establish that the facility is being maintained within the limitations of the facility license.

Page 2 of 2 to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation I t Nuclear Energy US. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Attn: Document Control Desk LaTonya Mahlahla Vallecitos Nuclear Center 6705 Vallecitas Rd Sunol, CA 94586 USA T 925 862 4092 Latonya.mahlohla@ge.com F 910-341-2972 August 11,2008

Reference:

License DR-10, Docket 50-183 Enclosure 10 CFR 5 0. 9 1 ~

No Significant Hazard Analysis for EVESR Technical Specifications, Amendment Seven

1) License Amendment Request 7, EVESR Technical Specifications (June 23, 2008)

GE-Hitachi submitted a license amendment request to the NRC for License DR-10, Docket 50-183 on June 23,2008. License Amendment Request Seven identified two proposed changes to the Technical Specifications for the ESADA Vallecitos Experimental Superheat Reactor. In accordance with 10CFR 50.91 the proposed changes described in the license amendment request (enclosure 1) were analyzed for no significant hazards consideration using the standards in 10 CFR 50.92.

Proposed change one is an administrative change submitted to clarify the scope of work associated with the removal and disposal of component parts or devices from the EVESR facility as authorized by the facility license.

Proposed change two removes unnecessary access control and locking requirements to areas below the 549-ft elevation of the EVESR containment. These controls were likely implemented when the reactor was operating to provide additional controls to high radiation areas. Since the reactor is no longer operating and the radiological conditions have changed, locking access to areas below the 549-ft elevation is not required. All areas in the containment will be controlled in accordance with 10 CFR 20.1602, Control Of Access To Hiqh Radiations Areas if applicable based on routine radiological surveys.

LLM-2008-23 EVESR Technical Specification Amendment (No significant Hazards Analysis) to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation The proposed changes to the technical specifications submitted in License Amendment 7 would not:

1. Involve a significant increase in the probability or consequences of an accident previously eva I ua ted;

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in a margin of safety GE-Hitachi has determined that there are no significant hazards associated with operating the facility in accordance with the proposed amendment.

If you have any questions or need additional information, please contact me at 925-862-4092.

Sincerely Yours, LaTonya L. Mahlahla Mgr., Regulatory Compliance & EHS cc: John Buckley Bob Evans Page 2 of 2 to Letter from D. Krause to J. Whitten Potential EVESR Tech Spec Violation

, L l l -

' - 1 Nuclear Energy U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Roc kvi I le, Maryland 2085 2-2 738 Attn: Document Control Desk LaTonya Mahlahla Vollecitos Nuclear Center 6705 Vallecitas Rd Sunol, CA 94586 USA T9258624092 Lotonyo.mahlohlo@ge.com F 910-341-2972 August 19,2008

Subject:

10 CFR 50.91(a) No Significant Hazard Analysis for EVESR Technical Specifications, Amendment Seven

References:

1) License DR-10, Docket 50-183

2) EVESR Technical Specification Amendment 7, (Letter from Latonya Mahlahla

3) No Significant Hazard Analysis (Letter from Latonya Mahlahla to Document to Document Control Desk 6/23/08, LLM-2008-19)

Control Desk 8/11/08, LLM-2008-23)

Enclosure:

Technical Basis For No Significant Hazard Analysis submitted to Document Control Desk on August 11,2008 Enclosed in the Technical Basis for the No Significant Hazard Analysis submitted for EVESR Technical Specifications, Amendment 7 (Reference 2). Enclosure 2 was inadvertently omitted from the submittal to the NRC on August 11, 2008 (Reference 3).

If you have any questions or need additional information, please contact me at 925-862-4092.

Sincerely Yours, LaTonya L. Mahlahla Mgr., Regulatory Compliance & EHS cc: John Buckley LLM-2008-24Technical Basis for No Significont Hazard Analysis to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Technical Basis For No Significant Hazard Analysis for EVESR Technical Specifications, Amendment 7 Summary of Chanqes for EVESR Technical Specifications, Amendment 7 Affected Section: Technical Specifications Section A.2, Principle Activities currently states:

The principal activities carried on within the plant area shall be the possession of the reactor facility, the dismantling of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory authorities provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areas below the 549-ft. elevation within the containment building.

Proposed Change 1) Delete provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areas below the 549-ft. elevation within the containment building from page 1 of Technical Specification Section A.2. GEH request condition A.2 be amended as follows:

A.2 The principal activities carried on within the plant area shall be the possession of the reactor facility, the dismantling of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory authorities.

Affected Section: Techncial Specifications Section B. 3 Surveillance and Security currently states:

Access to areas below the 549-ft level shall remain covered by concrete blocks over the reactor vessel and the head and shield plug storage pit, by a wood cover over the empty spent fuel storage pit and by locked covers on the personnel and equipment hatchways.

Keys to locks on the hatches and on the crane power switch shall be available only to the facility supervisor of his designated alternate.

Proposed Change 2) Delete the paragraph below condition C.3, Surveillance and Security in its entirety and replace with the following:

B.3 Access to areas of the EVESR containment shall be controlled in a manner consistent with the requirements of10 CFR 20.1601, Control of access to high radiation areas, as applicable.

10CFR50.91ia) No Siqnificant Hazard Analysis

1) Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Page 1 of2 to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Technical Basis For No Significant Hazard Analysis for EVESR Technical Specifications, Amendment 7 Proposed change one is an administrative change submitted to clarify the area where dismantling activities will occur as authorized by the facility license. The majority of the component removal activities will occur in areas below the 5493. elevation. Proposed change two removes the specific shielding and covering requirements for the reactor vessel, shield plug storage pit and the empty spent fuel storage pit and modifies the access control requirements to be consistent with 10CFR20. The EVESR reactor was shutdown in 1967 and has remained in a Possess Only status. All fuel bundles were removed from the facility and the radiation and contamination levels have been reduced by the removal of radioactive material and natural decay. No aspect of the proposed changes will involve a Significant increase in the probability or consequences of an accident previously evaluated.

21 Does the change create the possibility of a new or different kind of accident from any accident evaluated?

Response: No.

Proposed change one is an administrative, therefore there it cannot create a new or different kind of accident. Removal of the specific shielding and covering requirements for the reactor vessel, shield plug storage pit and the empty spent fuel storage pit and modification of the access control requirements as described in proposed change two will not impact the function or integrity of the reactor pressure vessel, which is the primary safety system required to be maintained by the license. The proposed changes do not create the possibility of a new or different kind of accident from any accident evaluated.

3) Does the change involve a significant reduction in a margin of safety?

Response: No.

Removal of the specific shielding, covering and access control requirements will not result in a reduction of the margin of the safety for the EVESR facility. These controls were implemented to provide shielding and access controls to High Radiation Areas. Since the reactor is no longer operating and the radiological conditions have been significantly reduced, the specific controls specified in the current technical specifications are not required. All areas in the EVESR containment will be controlled in accordance with 10 CFR

20. High Radiation areas will be controlled in a manner consistent with the requirements of 10CFR20.1601. The proposed changes do not affect the margins of safety.

Page 2 of2

Vallecitos EVESR Reactor Page 1 of 2 to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Turner, David W. (GE Infra, Energy)

From:

Sent:

Monday, May 12,2008 09:03 To:

cc:

Subject:

FW: Vallecitos EVESR Reactor Turner, David W. (GE Infra, Energy)

Bassett, Chuck W. (GE Infra, Energy); Lillge, Robert E (GE Infra, Energy, US); Astrauckas, Greg (GE Infra, Energy, Non-GE)

Mahlahla, Latonya (GE Infra, Energy)

Let's look at modifying the tech specs. to allow protection of the high rad areas IAW 10CFR20 instead of the proscribed methods currently in the TS.

David From: John Buckley [1]

Sent: Monday, March 17, 2008 10:44 AM To: Turner, David W. (GE Infra, Energy)

Subject:

RE: Vallecitos EVESR Reactor Per our conversation, I have reviewed the GE EVESR license and TS and agree that you may proceed to remove and dispose of component parts or devices from the EVESR facility in accordance with the Vallecitos Nuclear Center site procedures and provisions of 10 CFR Part

20.

If you would, please give me a heads up before you start work. Thanks.

>>> "Turner, David W. (GE Infra, Energy)" cdavidw.turner@ge.com> 03/12/2008 5:05:58 PM >>>

Excellent, I look forward to hearing from you next week.

David From: John Buckley [2]

Sent: Wednesday, March 12, 2008 1:06 PM To: Turner, David W. (GE Infra, Energy)

Subject:

Re: Vallecitos EVESR Reactor Thanks for the heads up. I will take a look at the license and get back with you next week.

Hope things are going well. Have a good weekend.

>> > "Turner, David W. (GE Infra, Energy)" <davidw.turner@ge.com> 03/11/2008 12:Ol PM

John, You and I discussed interference removal in the VBWR containment building last August. That project has been going very well. We intend to finish up on our current scope of work late this spring. Based on that success, we 9/26/2008

Vallecitos EVESR Reactor Page 2 of 2 to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation are intending to continue with our liabilities reduction projects. Specifically, we plan to do EVESR (DR-10, Docket 50-1 83) interference removal similar to what we are finishing on the VBWR.

Here are the key points in the EVESR license that GE-H feels are most relevant to the project.

In Docket 50-183, License No. DR-10, Amendment No. 6:

3.C. "GE-Hitochi sholl not dispose of the facility or the property occupied by the facility without prior approval of the Commission, except that GE-Hitachi may dispose of component parts or devices from the EVESR facility in accordance with the provisions of 10 CFR Port 20" In addition, in Appendix A, Technical Specifications:

A. Site

2. Principal Activities "The principal activities carried on within the plant ore0 shall be the possession of the reactor facility, the dismantlinq of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory agencies, provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areos below the 549-ft. elevation within the containment building."

C.4. requires "Access to areas below 549-ft. level sholl remain covered by concrete blocks over the reactor vessel and the head and shield plug storage pit, by o wood cover over the empty spent fuel storage pool, ond by locked covers on the personnel and equipment access hatchways."

Sin e license paragraph 3.C is fairly inclusive, we do not see any licensing impediments to removing the bulk o the components from the interior of the reactor containment building. Our plans include piping, pumps, valves, control systems, some walkways and non-structural shielding.

I could be more clear by describing what we are leaving. We are not planning to remove the reactor vessel or the biological shield surrounding it.

Thank you for taking a look at this and commenting on our understanding of the license. We intend to start by early June and complete the current scope of activities in late 2008.

David W. Turner GE-Hitachi Nuclear Energy Manager, Vallecitos Nuclear Center T

925.862.4344 C

925.200.5060 F

91 0.341.2577 E

davidw.turner@ge.com www.qe-enerqv.corn/nuclear 6705 Vallecitos Rd Sunol CA 94586 GE-Hitachi Nuclear Energy 9/26/200 8 EVESR Timeline to Letter from D. Krause to J. Whitten: Potential EVESR Tech Spec Violation Date Early 2008 March l l t h, 2008 March 17th, 2008 May 12th, 2008 June, 2008 June 23rd, 2008 August llth, 2008 August 19th, 2008 Sept. 15th, 2008 Sept 16th, 2008 Sept 18th, 2008 Action GEH VNC reviewed license for EVESR. GEH believed that license condition 2.(a) Principle activities allowed the removal of equipment in the entire containment. Le., the restriction on activities below the 549 foot level was limited to and acfivifies authorized by licenses issued by appropriafe regulafory authorities Wrote to NRC PM John Buckley about our understanding and asked for his read of the license Mr. Buckley agreed with our stated analysis GEH discusses removing reference to the 549-foot level from the TS.

GEH and contractor saw the restrictions in the TS as cumbersome for removing components below that level.

Discussed moving the boundaries to control access to a larger (whole containment building) envelope.

Started preparations for equipment removal such as electrical preps., depressurization checks, Submitted license amendment request #7.

Moving the boundaries of control would allow easier equipment removal from the lower levels of the reactor containment Added to the request #7. it was seen as an administrative change.

We believed we were already authorized by the current TS to remove that equipment Submitted 50.59 review Started Equipment Remova I NRC requested change to Technical v. administrative GEH stops work below and tells NRC HQ that we have already removed some piping.

GEH realizes that the NRC does not believe any equipment removal below the 549-foot level is authorized GEH Vollecitos Nucleor Center C:\\Docurnents and Settings\\NE30810\\Locol Settings\\Ternporory Internet Files\\OLK34\\TS chonge tirneline o.doc Poge 1 of 1