IR 05000018/1987001

Insp Repts 50-018/87-01,50-070/87-01,50-073/87-01 & 50-183/87-01 on 870901-03.Violations Noted.Major Areas Inspected:Evesr,Getr,Nuclear Test Reactor & VBWR Facility Operation Programs & Emergency Preparedness Program

ML20235T257
Person / Time
Site:	Vallecitos Nuclear Center, 05000000, Vallecitos
Issue date:	09/23/1987
From:	Cicotte G, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20235T245	List: IR 05000018/1987001 ML20235T243 ML20235T250
References
50-018-87-01, 50-070-87-01, 50-073-87-01, 50-18-87-1, 50-183-87-01, 50-183-87-1, 50-70-87-1, 50-73-87-1, NUDOCS 8710090312
Download: ML20235T257 (12)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos. 50-18/87-01, 50-70/87-01, 50-73/87-01, and 50-183/87-01 Docket Nos. 50-18, 50-70, 50 73, and 50-183 J

License Nos. DPR-1, TR-1, R-33 and DR-10 Licensee: General Electric Company

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P. O. Box 460'

Pleasanton, California 94566

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i Facility Name: ESADA Vallecitos Exper1sental Superheat Reactor (EVSER),

General Electric Test Reactor (GETR), Nuclear Test Reactor

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(NTR) and Vallecitos Boiling Water Reactor (VBWR)

Inspection at:

Vallecitos Nuclear Center Inspection Conducted:

September 1-3, 1987 Inspector:

M. hb[

h22 /h M. Cillis, Senior Radiation Specialist Date Signed i

Inspector:

h d bd J)22[7 W

G. R. Cicotte, Radiation Specialist Date Signed Approved By:

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4/;13/W_

G. P.(Yuhas, Chief Da'te Signed Facilitids Radiological Protection Section Summary:

Inspection on September 1-3, 1987 (Report Nos. 50-18/87-01, 50-70/87-01, 50-73/87-01, and 50-183/87-01)

Areas Inspected:

Routine unannounced inspection by two regionally based

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inspectors of EVSER, GETR, NTR and VBWR facility operation programs; including organization, audits and review, experiments, health physics program, environmental monitoring program, emergency preparedness program, reactor operator requalification program, transfer and shipment of radioactive material, a tour of the facility, open items consisting of followup items, Information Notices and Generic Letters, and a review of the annual report.

i Inspection Procedures 30703, 39745, 40745, 40750, 41745, 42745, 61745, 69745, i

82745, 83743, 86740, 90713, and 92701 were addressed.

Results: Of the fourteen areas inspected; one apparent violation was identified:

failure to fully implement and maintain the Emergency Plan (see paragraph 8).

8710090312 870924~

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DETAILS 1.

Persons Contacted

• R. W. Darmitzel, Manager, Irradiation Processing Operation

• D. R. Smith, Manager, Nuclear Test Reactor

• G. Cunningham, Senior Licensing Engineer

• E. Strain, Nuclear Safety Engineer W. B. Bowden, Supervising Engineer W. B. Johnson, Senior Reactor Operator J. L. Nixon, Security Manager J. Tenerio, Manager, Remote Handling Operations L. Erwin, I&EM Specialist R. Sandoval, Radiation Monitor

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• Denotes those individuals attending the exit interview.

2.

Reactor Operations a.

General Information The inspection included a review of licensee activities performed at the Nuclear Test Reactor (NTR), Vallecitos Boiling Water Reactor (VBWR), General Electric Test Reactor (GETR) and ESADA Vallecitos Experimental Superheat Reactor (EVSER),

VBWR, GETR and EVSER are in a permanent shutdown status.

Routine patrols and periodic entries to these facilities are made by the licensee's staff for the purpose of checking for abnormal conditions and performing checks and the radiation surveys required by the applicable Technical Specifications and/or License conditions.

Additional information related to GETR, VBWR and EVSER is discussed in paragraph 9, herein.

The review of NTR activities disclosed that reactor operations were consistent with the information provided in the licensee's annual reports for 1985 and 1986.

The inspection disclosed that the facility is extensively used as a neutron radiography facility.

The inspectors witnessed several reactor operations during the I

inspection.

No violations or deviations were identified.

b.

Organization The organizational structure for operation and administration of the j

NTR facility remains unchanged from that previously reported.

The organization was found to be consistent with Section 6.1.1 and Figure 6-1 of the Technical Specifications.

No violations or deviations were identified.

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I c.

Review and Audit The licensee's review and audit activities assigned to the Nuclear Safety Review Group (NSRG) pursuant to Section 6.2 of the Technical Specifications were examined.

The examination included discussions with the licensee's staff and a

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review of NSRG audit and surveillance records for the period of l

January 1986 to September 1987.

i The inspectors concluded that the licensee's review and audit i

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program met or exceeded the requirements of the Technical Specifications.

l No violations or deviations were identified.

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d.

Procedures Selected standard operating procedures (SOP) for the NTR facility were reviewed.

The inspectors noted that the licensee staff were in the process of reviewing and upgrading the 50P's at the time of this inspection.

The procedures appear to provide adequate instruction.

The inspection disclosed that the 50P's prescribed in Section 6.3 of the Technical Specifications were being adequately implemented.

j No violations or deviations were identified.

e.

Changes A review of maintenance records and the annual reports for 1985 and 1986 disclosed that no major changes or modifications were made at the NTR.

All maintenance activities were of a minor nature. As necessary, the licensee's staff performed a 10 CFR 50.59 evaluation.

No violations or deviations were identified.

f.

Experiments All new experiments performed since the previous inspection were reviewed and approved in accordance with Sections 4.5 and 6.2.3 of the Technical Specifications.

No violations or deviations were identified.

g.

Reactor Operator Requalification Program The implementation of the licensee's approved Reactor Operator (RO)

and Senior Reactor Operator (SRO) requalification program dated May 1979 was examined.

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' The examination included a review of the. biennial examinations administered since the' previous inspection. -Additionally,

discussions related to Information Notice 87-22, " Operator Licensing

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Requalification Examination at Nonpower Reactors"'and of the recent-changes made to 10 CFR Part 55 were held with the licensee's staff.

The examination disclosed that the licensee had received a copy of the recent changes made to 10 CFR Part 55 and'Information Notice 87-22.

The NTR Manager informed the inspectors that the information l

provided in Information Notice 87-22 will be implemented in the

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NTR's R0/SR0 requalification program.

The NTR Manager also stated l

that the current program has been revised for the purpose of incorporating the changes made to 10 CFR Part 55.

The revised program has been submitted to the NRR Project Manager for review and approval.

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The. inspectors concluded that the licensee's current requalification program met or exceeded the requirements specified in the approved plan.

No violations or deviations were identified.

h.

Annual Report The inspectors verifiea the data provided in the licensee's annual reports for 1985 and.1986.

No violations or. deviations were identified, i.

Surveillance

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Selected records. associated with the performance of surveillance activities prescribed in Section 4.0 of the Technical Specifications were reviewed.

Surveillance records reviewed included:

reactivity calculations, rod worth determinations, channel checks, channel calibrations, temperature coefficient verifications, control rod drive checks, safety rod interlock verification, thermal power verifications, and safety rod scram time checks.

The inspectors concluded that the licensee's surveillance program met or exceeded the requirements prescribed in the Technical Specifications.

No violations or deviations were identified.

3; IE-Information Notices (IN)

Licensee evaluations of IN's received between September 1985 and August 1987 were reviewed and discussed with the licensee's staff.

No violations or deviations were identified.

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4.

Generic Letter

~The information provided in Generic Letter 86-11, " Distribution of Products Irradiated in Research Reactors" was discussed with the NTR

. Manager.

The inspectors were informed that the licensee does not have any current plans to irradiate any gem stones for commercial use.

The NTR Manager stated that the NRC would be informed of any future decisions to irradiate gem stones for commercial or private use.

No violations or deviations were identified.

5.

Radiatien Protection l

a.

General Employee Training The licensee's general employee's training (GET) program for assuring compliance with 10 CFR Part 19.12, " Instructions to Workers" was examined.

The licensee's GET program is divided into two separate areas.

They are as follows:

1)

GET provided to visitors and temporary workers 2)

GET provided to permanent workers Vf sitors and temporary workers are required to view a video tape (slides) presentation of the GET.

The inspectors viewed the tape presentation during the inspection.

The presentation is approximately 20 minutes in length and.it appears to cover the material prescribed in 10 CFR Part 19.12.

The inspectors noted that some of the slides contained obsolete information.

This was brought

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to the licensee's attention at the exit interview.

The licensee's

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staff had informed the inspectors that they were aware that the tape l

presentation needed to be upgraded.

The GET provided to permanent workers is approximately four hours in length.

The examination disclosed that the licensee does not have any provisions for providing the permanent staff with refresher GET.

A review of records and discussions with the licensee's staff disclosed that most of the individuals assigned at the NTR and on the NTR emergency response team had not received any refresher GET since the individuals were hired.

It should be noted that some individuals were hired over twenty years ago.

The Senior Licensing Manager ttated that periodic drills and standup safety meetings are used as a training mechanism by each Manager to instruct workers of any changes in the regulatory requirements and/or procedures.

A review of the NTR standup safety meeting records was conducted during the inspection.

The inspectors concluded that standup safety meetings were being provided to workers; however, the subject material was not directly related to 10 CFR Part 19.12 instructions and the attendance could not be adequately verifie.._

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The above observations were brought to the licensee's attention at the exit interview.

The inspectors' observations were acknowledged by the Manager of Irradiation Processing Operations and Senior Licensing Manager.

The inspectors were informed that a program would be initiated to provide refresher GET at some given frequency, such as, every three or four years.

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No violations or deviations were identified.

b.

Radioactive Material Shipment and Receipt A review of radioactive material shipping and receiving records disclosed that activities associated with the receipt and

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transportation of radioactive material were consistent with 10 CFR c

l Part 20, 10 CfR Psrt 71 and 49 CFR Parts 172-178.

Transfers and/or shipments of radioactive material are made through the licensee's tj State of California radioactive material license.

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No violations or deviations were identified.

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c.

Posting The inspectors verified that the licensee's posting practices were in compliance with 10 CFR Part 19.11, " Posting of Notices to Workers".

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No violations or deviations were identified.

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d.

Personnel Monitoring Personnel exposure records for the period of September 1985 through June 1987 were reviewed.

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The review c'.isclosed that the licensee's personnel monitoring program was found to be consistent with the regulatory requirements prescribed in 10 CFR Parts 20.101, 20.104 and 20.202.

Personnel levels were as reported in the licensee's 1985 and 1986 annual reports.

No violations or deviations were identified.

e.

Solid and Liquid Wastes The licensee's staff reported that in 1986, approximately two and one-half cubic feet of solid waste was shipped to an approved burial site for disposal.

No liquid wastes were generated since the pr evious inspection.

No violations or deviations were identified.

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f.

Surveys and Effluent Releases 10 CFR Part 20.201, " Surveys," requires that licensee's perform evaluations of the radiation hazard that may be present.

Further it requires that when appropriate such evaluations include measurements of the levels of radiation.

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l A review of NTR survey records for the period of 1986 through August

1987 were reviewed and discussions related to the radiation

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monitoring program at the facility were held with the licensee's staff.

The licensee's radiation monitoring program at the NTR includes provisions for performing routine contamination surveys, effluent monitoring (e.g. liquids, gases, and particulate) and direct radiation measurements.

The review of survey data did not reveal any abnormal levels.

Radioactive materials discharged through the reactor ventilation system to the atmosphere were verified to be within the limits i

specified in Section 3.4.3.2 of the Technical Specifications.

The inspectors noted that the NTR roof was posted and controlled as a radiation and airborne radioactivity area (i.e. due to noble gas releases from the stack).

The inspectors asked the licensee's staff what the radiation levels were and to review a copy of the most recent survey.

The radiation protection technician assigned to support NTR operations and the technician's supervisor were not aware of the radiation levels and when the last survey of the area was performed.

The Nuclear Safety Engineer indicated that radiation levels (beta gamma and neutron) were approximately 80 millirem per hour (mrem /hr).

A search was made to locate the last survey taken on the NTR roof.

The only copy was dated July 24, 1969.

The survey results were consistent with the radiation levels reported by the Nuclear Safety Engineer.

A joint radiation survey of the roof was taken by the licensee and NRC inspectors to verify that conditions had not changed since the previous survey was taken.

The maximum whole body radiation level measured was 92 mrem /hr.

The above observation was brought to the licensee's attention at the exit interview.

The licensee informed the inspectors that a copy of the most recent survey would be maintained at the facility and another would be posted on the door leading to the rooftop.

The licensee added that a policy will be developed for performing a survey of the NTR roof top on a more frequent schedule.

No violations or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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g.

Environmental Monitoring The licensee's environmental monitoring program is a site-wide

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program which includes provisions for measuring radioactivity levels in air, soil, vegetation and streams.

The program also includes provisions for obtaining direct radiation measurements via an array of thermoluminescent dosimeters.

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The results of the environmental monitoring program implemented during the period of July 1985 through June 1987 were examined.

The examination disclosed that there were no effects on the environs as a result of NTR operations.

No violations or deviations were identified.

6.

Facility Tour The inspectors toured the NTR facility to check the general state of cleanliness and to verify that posting and labeling practices were consistent with 10 CFR Part 20.203 and that radiation monitoring instruments were functioning properly and were in current calibration.

Independent radiation measurements were performed using an Eberline, Model R0-2 ion chamber survey instrument, S/N 2694, due for calibration on October 21, 1987.

All fixed and portable radiation monitoring instruments were in current calibration and plant cleanliness was good.

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Independent measurements confirmed that the licensee's posting and labeling practices were consistent with 10 CFR Part 20.203.

No violations or deviations were identified.

7.

Open Items (Closed) Corrective actions taken by the licensee to resolve followup items:

(50-70/85-01-01, 50-70/85-01-02, 50-73/85-02-01 and 50-73/85-02-02) were exarcined and found to be satisfactory.

These matters are closed.

8.

Emergency Preparedness a.

General Information The capabilities for responding to emergencies as specified in the licensee's approved Emergency Plan (EP) of 1982, and for demonstrating compliance with 10 CFR Part 50.54(q) and 10 CFR Part 50, Appendix E were examined.

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l The examination included a review of applicable training records, EP l

implementing procedures (EPIP), emergency response equipment, drill

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scenarios, drill critiques, and discussions with the licensee's staff.

10 CFR Part 50.54(q) states in part:

...A licensee authorized to

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possess and/or operate a research reactor or a fuel facility shall follow and maintain in effect emergency plans which meet the requirements of Appendix E of this part."

Paragraph IV.F of Appendix E to 10 CFR Part 50 requires that the emergency plan include provisions for training of personnel and exercising, by

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periodic drills, to ensure personnel are familiar with their duties.

Appendix E further states that the program should identify I

specialized initial training and periodic retraining programs.

l Paragraph IV.G of Appendix E to 10 CFR Part 50 requires the program l

to describe the provisions to be employed to ensure that the EP, emergency equipment and the EPIP's are maintained up to date.

Section 10.1 of the licensee's approved EP establishes the requirements for conducting periodic drills, training and conducting a biennial review of the plan and its implementing procedures.

Section 10.1 of the EP states in part:

"...All individuals at the site receive appropriate training.

All employees are instructed in reporting and responding to alarms.

Building Emergency Team members receive initial training and annual reviews in respiratory protection, radiological pr6tectioli, first aid, fire protection and emergency support as appropriate for their assigned responsibilities."

Section 10.1 of the EP also states in part:

"... At least every two years, drills are performed to test the system for notifications of off-site agencies."

b.

EP Implementing Procedures (EPIP)

The examination disclor.ed that the licensee has established EPIP's for responding to site-wide emergencies.

A review of the EPIP's disclosed the following:

Procedure A-5, " Emergency Control Procedure General", Section 3.3 states in part:

"The Building Emergency Teams will include personnel trained in first aid, fire fighting, and radiation monitoring as well as personnel designated as Assembly Area Leaders.

Specific responsibilities of team members are assigned in the building emergency procedures.

Drill and training sessions will be conducted to ensure that teams are in operational readiness."

Section 3.5 of procedure A-5 requires that training and drills for building and functional emergency teams will be planned, implemented and documented.

Section A.2 of Appendix A to procedure A-5 states in part:

"...An on-site fire team responds to all fire alarms.

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teams are trained in the use of plant extinguishers and fire-fighting techniques for incipient stage fires.

They will ensure that personnel evacuate the building and will request off-site assistance when needed.

During normal working hours the Building Emergency Team will make initial response and ensure building evacuation."

Procedure B-5, " Procedure for Handling Bomb Threats", Paragraph 5.3 states in part:

...Within the site Building Emergency

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Team concept, at least four individuals will be designated as search team members, two as a primary search team and two alternates or replacements if a primary team member is unavailable.

Any changes to search teams must be relayed to the Specialist-Safeguards.

The Specialist-Safeguards is responsible for providing team training as requested by Area Managers, maintaining an up-to-date roster of trained personnel to include telephone numbers (office and home)."

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Procedure C-5, " Fire Protection Procedure" states in part:

" Employee's designated as fire fighters, radiation monitors and alternate fire fighters will be trained in the use of SCBA."

Procedure E-5, " Radiation Emergency Procedure", paragraph 8.0, w

states in part:

" Preparedness of emergency teams will be maintained through the use of training sessions and drills developed and implemented as appropriate by Area Managers."

The paragraph goes on to state:

"Each Area Manager of such a facility will ensure that the building emergency team is trained to respond to an emergency at that facility.

c.

Findings An examination of the licensee's practices disclosed the following:

The licensee had established a site-wide emergency plan composed of Building Emergency Team members who are assigned to respond to emergencies for a specific area or building.

On the back shifts, the on-duty Specialist-Facility Protection is assigned as the initial response coordinator for all emergencies at the Vallecitos Nuclear Station.

The Specialists-Facility Protection are GE employees who have received training for implementing and coordinating emergency response activities.

The Building Emergency Teams were composed of 20-24 members.

Team assignments included members having responsibilities of:

Area Managers, Building Emergency Coordinator, Asserr.bly Area Leader, Fireman, First Aid, Radiation Monitor. Utility Man, Electrician and Building Search Team.

With the exception of the biennial notification drill, remaining drills and exercises for 1986 and 1987, to date, were conducted at the frequencies specified in the Technical

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Specifications.

The initial biennial notification drill was

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conducted on June 29, 1987 even though the EP had been in effect since 1982.

The review disclosed that the licensee's staff had identified that the notification drills had not been performed at the frequency specified in the EP.

The review further disclosed that the licensee took immediate action by conducting a notification drill and establishing a policy for performing the drills at a greater frequency than is prescribed in the EP.

The inspectors noted that monthly notification drills were performed since July 1987.

A violation was not considered in view of the timely manner in which the licensee corrected the item.

The licensee's staff informed the inspector that the " initial training" referred to in Section 10.1 of the EP was actually General Employee's Training (see paragraph 5(a)).

A review of training records disclosed that no information was available to indicate whether the NTR Building Emergency Team members had attended the initial training.

Additionally, training records revealed that at least thirteen EP team members had not received annual reviews in radiation protection since at least 1984.

Many (greater than 50%) had not received any annual reviews in radiation protection since 1973.

The examination disclosed that none of the EP Team members listed as firemen had attended SCBA training.

Nor were there any records available to verify the team members received an annual review in fire fighting techniques.

Training records were not available for verifying that the first aid team members had been provided with or received annual reviews in first aid for the period 1984 through 1986.

Building search team members (bomb searchers) had not received any annual reviews since the initial training that was provided in 1982.

The licensee's staff could not define what the annual reviews consisted of and if they were actually conducted.

The licensee's staff informed the inspectors that GE had considered drills and exercises as a form of training and had considered the drills and exercises to satisfy the annual review training.

A review of drills and exercises conducted since 1986 disclosed that no attendance records were maintained except for a drill that was conducted on June 25, 1987.

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inspectors noted that at least five team members did not

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participate in that drill.

The inspectors noted that EP training was not documented as required by EPIP A-5, Section 3.5.

The above observations were brought to the licensee's attention I

at the exit interview.

The inspectors informed the licensee

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that failure to fully implement the training and notification drills was an apparent violation (50-73/87-01).

The licensee acknowledged the inspectors' observations.

The inspectors were informed that the licensee was in the process of revising the site-wide emergency plan to require a single fully qualified and well trained emergency response team in lieu of the current plan to have an EP team assigned to respond to each building.

The licensee expects that this change will result in an overall improvement for maintaining a well qualified emergency response team and for demonstrating compliance with 10 CFR Part 50.54(q).

9.

GETR, EVSER and VBWR Surveillance The inspectors verified that the licensee's staff was performing the surveillance and surveys at GETR, EVSER and VBWR as specified by the respective license conditions and Technical Specification (see paragraph 2(a), herein).

Survey data recorded since the previous inspection were reviewed.

The reported data was consistent with what had been reported in previous licensee and NRC inspection reports.

Currently; entries to GETR and VBWR are made annually and entries into EVSER are conducted semi-annually.

The Senior Licensing Manager disclosed that a request had been submitted to NRR to conduct the entry inspection at EVSER on an annual frequency.

The inspector concluded that the licensee's surveillance at GETR, VBWR and EVSER were consistent with the license conditions and Technical Specifications.

The inspector asked the licensee's staff to notify the Region V office whenever the next planned entry into GETR, VBWR and/or EVSER was scheduled to be accomplished.

No violations or deviations were identified.

10.

Exit Interview The inspectors met with the licensee's representatives (denoted in paragraph 1) at the conclusion of the inspection on September 3, 1987.

The inspectors summarized the scope and findings of the inspection.

The apparent violation discussed in paragraph 8 was brought to the licensee's attention.

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