IR 05000089/1982001

IE Insp Repts 50-089/82-01 & 50-163/82-01 on 820412-14 & 16. No Noncompliance Noted.Major Areas Inspected:Radiation Control,Environ Monitoring & Emergency Planning Programs Associated W/Triga Facilities

ML20052J052
Person / Time
Site:	General Atomics
Issue date:	04/29/1982
From:	Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20052J034	List: IR 05000089/1982001 ML20052J033
References
50-089-82-01, 50-163-82-01, 50-163-82-1, 50-89-82-1, NUDOCS 8205240373
Download: ML20052J052 (11)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-89/82-01, 50-163/82-01 Docket No. 50-89, 50-163 License No. R-38, R-67 Safeguards Group Licensee: General Atomic Company P. O. Box 81608 San Diego, California 92138 Facility Name: TRIGA Facility, Mark 1 and Mark F Reactors Inspection at: General Atomics Torrey Pines Site Inspection conducted: April 12-14 and April _ 16, 1982 Inspectors: b dML

'1-25s#8 1 i

G. P.(Y[I as, Radiation Specialist Date Signed M

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Approved by:,i. A. Wenslawski, Chief, Reactor Radiation

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/ D(te Signed

/j Protection Section Approved b :

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H. E. Book, Chief, Radiological Safety Branch Date Signed

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Summary Inspection on April 12-14 and April 16,1982 (Report Nos. 50-89/82-01, 50-168/82-01)

Areas Inspected:

Routine unannounced inspection of the licensee's radiation control, environmental monitoring and emergency planning programs associated with the TRIGA facilities. The inspection involved 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> onsite by one regionally based inspector.

Results: No items of noncompliance or deviations were identified.

0205240373 820430 PDR ADOCK 05000089

PDR

9 DETAILS 1.

Persons Contacted Licensee Representatives:

• W. Whittemore, Physicist-in-Charge, 'TRIGA Facility F. Bold, Manager Compliance Control

• W. Mowry, Manager Licensing

• J. Shoptaugh, Deputy Physicist-in-Charge

• D. Pound, Criticality Safety Committee (TRIGA)

W. Stout, TRIGA Operations G. Alcorn, Health Physics Technician R. Cockle, Health Physics Technician

• J. Kieth, Health Physics Technician J. Allen, Health Physics Technician R. Bamford, lead Instrument Technician Non-Licensee Representatives:

L. Kovach, General Activation Co.

P. Maschka, IRT Corporation E. White, Environmental Consultant

• Indicates those individuals attending the exit interview on April 16,1982.

2.

Radiation Control Program a.

Organization and Staffing Since the last inspection (December 1980) the licensee has

reorganized.

Five Health Physics Technicians, one Counting

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Room Technician and, one Records and Reports Technician report to the Health Physicist. The Health Physicist (presently vacant,

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expected to be filled within the next few weeks), Security I

Control and Fire Chief report to the Manager, Compliance Control.

The Manager, Compliance Control (a Certified Health Phsicist)

i reports to the Division Director, Quality Assurance and

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Compliance who in turn reports to a Vice President of the company.

This radiation protection staff is responsible for site operatiens including radiation control at the TRIGA facility.

There have not been any new additions to the TRIGA Operations staff since the last inspectio...

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b.

Radiation Control Procedures i

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Ofthe.148sitewideHealtbhhysicsProcedures(HPD)the following that directly relate to TRIGA operations were reviewed

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by th'e'inspsctor to determine compliance with the Technical

.Spe~cifications,and 10 CFR 20 requirements.

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HPD

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. Procedure;v

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Number (

Title Date

Calibration and Testing of Continuous 4/76 Air Monitors

~ Continuous Air Monitor (CAM) Alarm Tests 10/81

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Procedure for Verification of Thermolumines-1/81

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cent and Film Dosimeters

Routine Calibration of Area Monitors 2/78

Radiological Work Permit 7/79

Environmental Monitoring Program -

12/81 Alert Levels

Radiation Safety Audit Procedures 5/80

Radioactive Material Removal Record -

5/80 Form GA-558

Procedure to Add Persons to the Permanent 6/81

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Film Badge Program

Monitoring Argon-41 in the TRIGA 10/79 MK-F Reactor Room 108 Measuring, Reporting, and Recording 4/79 Personnel N Doses from N Radiography Operations i

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123 Routine Duties for Health Physics 4/81 Technician Assigned to Bldg. 21 TRIGA facility Based on this review the inspector noted:

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CAM No. 32785 (Mark 1) and No. 32786 (Mark F) had been calibrated in June 1981 as required by HPD 2.

Remote area monitors No. 4270 had been calibrated in June 1981

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as required by HPD 14.

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HPD 43 had not been performed in January 1982 ' e the TRIGA facility.

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HPD 13 had not been performed since June 1981.

Neither HPD 71 or HPD 21 clearly address the 1979 revision

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of 10 CFR 20.102(a) regarding estimates of current quarterly dose.

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Implemenation of HPD 123 is performed on an on as required basis.

These findings were discussed with licensee representatives at the exit interview.

c.

Exposure Control On April 12, 1982 the inspector toured the.TRIGA Facility making independent measurements using NRC portable radiation survey instruments (R02 Serial No. 008985, calibration due 6-22-82, and Neutron REM meter Serial No. 006381, due for calibration 2-24-83 to evaluate compliance with the requirements expressed in 10 CFR 20. The following observations were made.

Posting, labeling and control were consistent with

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10 CFR 20.203 requirements.

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The following licensee radiation survey instruments were available for use and calibrated as required by licensee procedures.

s Type of Instrument Model Calibration Due' Date

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9/82 Beta Gamma R02 33730

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8/82 Beta Gamma R02 33737

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4/82 Neutron Snoopy 15461 Contamination Ludlum 3 19331

'7/82-Contamination Ludlum 14A 83457*-

4/82 Contamination Ludlum 14A 83840 5/82

• Inspector noted apparent damage to probe connection. '

The licensee was advised and the instrument was removed from service.

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All personnel working within the restricted area were observed to be wearing whole body personnel dosimetry as required by 10 CFR 20.202.

Work Authorization WA2544 issued June 25, 1981 for activities

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at the TRIGA was complete and posted as required by procedure.

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-4-The inspector observed the transfer of a irradiated specimen

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from storage.to a representative of the General Activation Company. The following documents were reviewed in connection with this activity:

Irradiation Request Form GA-89,

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- Serial No.,5531; Radioactive Material Removal / Record #229.

The licensee's Health Physics Technician perforced a survey of the specimen using R02 33737. The inspector performed an independent survey using R02 NRC008985. The results are summarized in Table 1.

This sample had an estimated 24 Na of 1.3 mci.

TABLE I

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Dose Rate at Dose Rate at Dose Rate Maximum Contact with l' from at 3' from Dose Rate on Shipping Container Container Container Outside Truck

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Licensee 8 mr/hr 2.5 mr/hr

.25 mr/hr.

1.9 mr/hr NRC 7 mr/hr 2.5 mr/hr

.25 mr/hr 1.8 mr/hr

The vehicle used by General Activation Co. to transport the sample was properly placarded. The inspector discussed the

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exterior physical appearance of the vehicle with the General j

Activation Co. representative.

In particular, the badly rusted tailgate was of concern.

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At about 4 PM the Mark F reactor was operated for three minutes at 1.5 mw. The inspector observed the startup, including completion of the precritical checkoff sheets.

Since the operation included use of the neutron radiography facility the inspector conducted independent measurement of the neutron scatter field surrounding the Mark F l

building. The licensee established a temporary restricted area in the parking lot ajoining the Mark F building

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l roll-up door. This roped off area was posted as a " radiation area".

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Uith the reactor at 1.5 mw the licensee measured a i

maximum neutron dose rate of 1.2 mrem /hr using the Snoopy and 0.6 mr/hr gamma with his R02 at the restricted area boundary. Using the NRC Neutron REM meter the inspector measured a dose rate of 2.8 mrem /hr with the 9" sphere, a 9"/3" ratio of 0.33 and a gamma dose rate of 0.6 mr/hr at the same point. At the control console the licensee measured a neutron dose rate of 0.5 mrem /hr and a gamma value of 0.4 mr/hr. The inspector measured a gamma dose rate of 0.5 mr/hr but was unable to measure the neutron dose rate since the reactor was shut down before a statistically acceptable neutron measurement could be made.

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-5-Based on the 9"/3" ratio the inspector estimated the average energy of the scattered neutrons to be in the range of 100-150 Kev.

Since the NRC neutron instrument had been calibrated using a moderate 252 Cf source (15 cm and 25 cm D 0)

which closely approximates the energy of the neutron fields measured, the inspector questioned the veracity of the licensee's survey results. Accordingly, the licensee agreed to conduct a comparison of instrument responses to resolve the difference in measurements.

On April 14, 1982 this comparison was conducted at IRT's low scatter neutron calibration facility.

In preparation the licensee had determined that their instrument

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(Snoopy Serial No.15461) batteries were low and replaced same.

In addition, the licensee choose to compare

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another of their instruments (Snoopy Serial No. 30305).

During the initial phase of the comparison Snoopy Serial

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No.15461 failed to respond to radiation and could not be used. Table II documents and results of-this comparison.

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TABLE II i

Source:

252 Cf, Serial No. 221Z 4.82 mg on October 22, 1972, 400.3 ug on April 14, 1982. Dose rate calulated based Savannah River Operation Publication SR0-153 dated January 1971.

Calculated GA NRC Distance Dose Rate Snoopy'

Rem Ball 9" cm mrem /hr No. 30305 No. 006381

1376 1290 1320 100 880 860 857 150 389 400 412 i

250 134 148 157 320

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420

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i Source:

252 Cf Serial No. 218 Z 26.2 ug 10-6-72, 2.18 ug '4-14-82

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60-13.3 12.0 12.3

8.3 7.2 7.4 100 4.8 4.5 4.8 180 1.2 1.4 1.6 240

.78 0.9 1.1 330

.43 0.42 0.5

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-6-NRC 9"/3" ratio at 150 cm = 1.99 NRC R02 ganina dose rate at 150 cm = 33 mr/hr NRC neutron dose rate at 150 cm calculated using 252 Cf emission raje of 2.0 E12 inec and 10 CFR 20 flux conversion of 7.6 n/cm-sec equals 372 TFrem/hr.

mrem /hr From the data noted above it is clear that the licensee's neutron survey instrument responded adequately to an unmoderated 252 Cf neutron source and was in good agreement with the NRC neutron survey instrument. According to the energy response curve.provided by the Snoopy manufacturer (Rem Rad Monitoring Systems) in their Bulletin 7410-PB1 the instrument should be appropriate for monitoring the energy of neutrons

• scattered from the neutron radiography operations.

Based on the potential increased utilization of the TRIGAs for neutron radiography the inspector reviewed the guidance of USNRC Regulatory Guide 8.14 " Personnel Neutron Dosimeters" with the Manager, Compliance Control.

Subsequent to tie neutron radiography test the operator

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was observed carrying the film holder to the developing laboratory. Since the operator was not wearing extremity monitoring the inspector performed a survey of the hand dose rate using the NRC R02.

The dose rate to the hand was 173 mrad /hr.

In view of the short handling time in this case the requirements of 10 CFR 20.202 were not violated.

The inspector discussed the requirements of 10 CFR 20.201 in terms of 10 CFR 20.202 with the licensee representative in view of potential increase of activities such as neutron radiography.

On April 13, 1982 the inspector and licensee representatives

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toured the High Radiation / Radioactive Materials Area located behind the TRIGA facility. The licensee representative stated that this area is controlled in accordance with 10 CFR 20.203(c). The inspector observed the area was bounded by a locked chain link fence with administrative control of access keys. Within the storage area the inspector observed many loose items of radioactive material and unlabeled drums and boxes containing radioactive material.

In one case a small pile of about six nuts, a four inch flange and gasket produced a dose rate of 350 mr/hr at 12".

These materials were outside, loose and about 10' away from the fence.

In another case a 4' by 4' by 8' wood box emitted a dose rate of 100 mr/hr at a distance of 18" and was not labeled. The inspector measured a dose rate of 20 mr/hr at the fence from these source = _ _ _ _ _ -

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>The< licensee maintains the exception allowed by 10 CFR 20.203 (f)(3) regarding labeling of radioactive materials within

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this area, i

The inspector clearly stated to the licensee representatives that in his opinion good radiation safety practices, procedures and implementation of the ALARA criterion were not being utilized in maintenance of this storage area. The licensee initiated action to improve these situations. On April 14 the inspector noted work had begun and the fence dose rate had been decreased to 5 mr/hr.

i This observation was discussed at the exit interview.

d.

Radiation Control Records Review The occupational exposure records including: NRC Form 5

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equivalent, whole body count data, and radiation protection training records were reviewed to evaluate compliance with the regulatory requirements noted below for all the principle individuals assigned to the TRIGA during 1981.

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Requirement Topic 10 CFR 19.12 Instruction to workers

10 CFR 20.101 Radiation dose standa-ds l

10 CFR 20.102 Determination of prior dose 10 CFR 20.103 Internal dose standards 10 CFR 20.201 Surveys or evaluations

10 CFR 20.401 Radiation records Based on this review one anomaly was observed. On October 6, 1981 the licensee was informed by their dosimetry vendor that a TRIGA Operator had received a dose of 38.61 rem. The licensee implemented HPD 113,

" Reporting and Investigating External Radiation Exposures in Excess of Alert levels." The licensee quickly determined that the operator had dropped his thermoluminescent dosimeter into the Mark F pool on July 29, 1981. The recommendations as a result of the investigation were that the 38.61 rem dose be deleted from the individuals personnel monitoring record and an estimated dose of 0.1 rem be added for the third calander quarter of 1981.

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Contrary to this recommendation the operator's Form 5 equivalent had.not been corrected for the third and fourth

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quarter of 1981. On bringing this to the attention of the

, Manager;; Compliance Control, he acknowledged the appropriateness

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of the recommendation;and. agreed to implement the correction.

Three requests for exposure records pursuant to 10 CFR 19.13

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were reviewed. The requests dated: 8-11-81, 5-12-81 and 2-11-80 were responded to an 8-17-81, 6-8-81 and 2-11-80, all within the 30 days permitted.

Five employee terminations were reviewed to determine compliance

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with 10 CFR 20.408/.409. The terminations occurred on:

2-6-81, 2-6-81, 2-20-81, 3-21-81 and 11-6-81 and the reports were submit'ted on 3-9-81, 3-9-81, 3-9-81, 4-22-81 and 11-18-81 as required.

The TRIGA " Health Physics Laboratory Notebooks" for

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1981 were reviewed. These books contain survey and other relevant data associated with the TRIGA.

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The minutes of the quarterly meeting of the Criticality Safeguards Committee were reviewed as noted.

Date Document Identification 3-5-81 DCP:81:15 6-2-81 DCP:81:32 9-4-81 DCP:81-46 12-2-81 DCP:81 :57 3-8-82 DCP:82:04 These meetings met the requirement of Section 8.0 of the Technical Specification.

The following Radiological Work Permits (RWP) were reviewed.

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RWP 3-5-82, "Make and Attach Grille to Mark F Shroud" RWP 3-30-82, " Install Test, Mark 1, Mark F" RWP 2-9-82, " Observe Neutron Radiography" RWP 1-22-82, " Neutron Radiography of Transducers" RWP 2-2-81, " Install Microwave Alarms"

No items of noncompliance were identified as a result of the inspection of the radiation control area.

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3.

Emergency Planning The licensee has a formally developed emergency plan and emergency

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procedures. This plan and procedures were last formally reviewed

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by the licensee in April 1979 and have been described in previous inspection reports.

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The matter of an upgraded emergency plan is an active issue. At this time the licensee is developing comments on Proposed Revision 1 to USNRC Regulatory Guide 2.6, " Emergency Planning for Research and

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Test Reactors".

Records indicate that two evacuation drills (7-14-81, 1-27-82) have been performed since the last inspection.

i Training records indicate that radiation safety training was provided to Fire Technicians in May and October 1981.

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The inspector inventoried the " Health Physics Emergency Vehicle" l

and found it contained the equipment designated by the inventory i

sheets.

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From discussions with the Physicist-in-Charge and Manager, Compliance Control it was readily apparent that they.were

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familiar with the plan and their responsibilities.

No items of noncompliance were identified.

4.

Environmental Monitoring l

The 1981 Annual Reports dated February 25,-1982 and identified as

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GA67-3055 and 3056 indicated that 0.105 Ci of 41 Ar were released from.

the TRIGA facility.

Review of the Semiannual Reports submitted on.

August 26, 1981, GA696-3000 and February 22, 1982.

GA696-3053 indicated 0.28 Ci were released during'1981.

Procedure HPD98 describes a

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technique to accumulate release data.

From-discussions with-the

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licensee's Environmental Consultant the inspector: learned-that due_ to the extremely low utilization of the TRIGA a release factor was used to calculate the 41 Ar since the actual releases were below the minimum j

sensitivity of the stack monitor.

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I From a review of 1981,1980 and 1979 data consistency of methodology was not evident. At the time of this finding the fianager, Compliance'

Control and Environmental Consultant were not available to resolve the issue.

In any event, the actual releases are a extremely small fraction of the permitted values.

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-10-This matter will be reviewed in a subsequent inspection (50-163/

82 01-01, 50-89/82-01-01).

Radioactive liquids and solid waste are not released directly from the TRIGA. The releases are made under a different license and y

are inspected accordingly.

Review of environmental records did not indicate any releases from the TRIGA which approached the " alert" values specified in

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HPD40 for 1981.

No items of noncompliance were identified.

5.

Licensee Response to IE Bulletins, Circulars and Notices Since the last inspection the licensee has received and reviewed the following IE Information Notices: 80-32 Rev. 1, 81-13, 81-15, 81-18, 81-26, and 81-34 which are related to radiation protection.

No IE Bulletins or Circulars involving radiation protection were transmitted to the licensee in 1981.

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Exit Interview

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The inspector met with the licensee representatives ~ henoted in -

Paragraph 1) at the conclusion of the inspection on April'16,1982.

The inspector sununarized the' scope and f'ndings of the-inspection.

Several specific points were discussed.

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Minor inconsistency in. reporting 41 Ar release data ne'eds to be resolved.

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Packaging labeling and control of radioactive material in the TRIGA storage yard were' not consistent with good radiation safety practices and procedures.

The licensee responded by stating that the matter was under review and several actions had already been-initiated.

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Some HPD procedures such as HPD 13 and 43 are not being implemented.

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Two HPD procedures, HPD21 and HPD71 are no longer consistent with 10 CFR 20.102.

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Occupational Exposure History, NRC. Form 5 or equiviliant must be maintained as accurate as is possible.

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