IR 05000089/1986002
| ML20214D684 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 11/05/1986 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20214D681 | List: |
| References | |
| 50-089-86-02, 50-163-86-02, GL-86-11, NUDOCS 8611240204 | |
| Download: ML20214D684 (14) | |
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(; U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No /86-02 and 50-163/86-02 Docket No and 50-163 . License No R-38 and R-67-
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License: GA Technologies, In l
.P. O. Box 81608
' ' ' San Diego, Calffornia 92138 A
' Facility Name: .TRIGA Facility, Mark 1 and Mark F
- Inspection at: GA.' Technologies Torrey Pines Site
- Inspection Conducted: October 7-10, 1986 .
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Inspectors: [ w Mg,Cillis', Senior Radiation Specialist
//- f-[6 Dhte Signed ( h k A ~
Approved by: , _
u/r/g4 G.'P. TLap, Chief Date Signed
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Facilitled Radiological Protection Section Summary:
Areas inspected: Routine unannounced inspection of the Mark 1 and Mark F
' TRIGA reactor operations, including organization, review and audit, experiments,' qualification training, environmental ~ monitoring program, radiation protection activities, transportation activities, emergency preparedness program, a tour of the facilities, discussions of relevant IE Information Notices and Generic Letters, review of Licensee Reports, and a followup of previous inspection findings. Inspection procedures 30703, 39745,.
40745, 41745, 61745, 80745, 82745, 83743, 86740, 90713, and 92701 were
- performe Results: Of the thirteen areas inspected, no violations or deviations were
. identifie gDR ADOCK 05000089 PDR
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DETAILS Persons Contacted
- R. N. Rademacher, Director, Human Resources
- K. Asmussen, Manager, Licensing and Nuclear Compliance
- L. Quintana, Supervisor Health Physics
- J.'Razvi, Associate Physicist-in-Charge,'TRIGA
- A. Baxter, Chairman, TRIGA Criticality Safeguards Committee
- A. Galli, Manager Security W. Stout, Deputy Physicist-in-Charge S. Perelman, Health Physics Technician
'* Indicates those individuals attending the exit interview on October.10,.
1986.
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In addition to the individuals identified above, the inspector held discussions with other members of the licensee's staf . Reactor Operations Organization
'The organizational structure at the Mark 1 and Mark F facility was verified to be consistent with Technical Specifications (TS),
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Section 9.1, " Organization." The organization, with the exception of personnel changes, has remained unchanged since 198 No violations or deviations were identifie Logs and Records Mark 1 and Mark F operating logs and records for the period January 1985 through September 1986 were examined. The examination included a selective review of the following types of records / logs: '
Daily, weekly, monthly, semi-annual and annual checklist *
Maintenance Logs
- Irradiation Request Forms l *
l 1984 and 1985 Annual Reports
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Reactor pool water analysis reports ( *
Calibration records for both portable and fixed radiation j monitoring equipment
j Air, contamination, and radiation survey records l
Reactor startup and shutdown checklists
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- Mark 1 and Mark F surveillance records
- Criticality Safeguards Committee review'and audit reports
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Personnel exposure reports for the period January 1985 through July 1986
General Employee Training records
- Senior Reactor Operator and Reactor Operator requalification training records
Applicable records associated with the NRC approved Radiological Contingency Plan
- Records associated with the shipment and receipt of radioactive materials
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Records related to licensee's evaluations that were conducted pursuant to 10 CFR Part 50.59, " Changes, tests, and experiments"
Mark I and Mark F emergency and operating procedures
Environmental monitoring records The examination disclosed that reactor operations, radioactive material transportation activities, reactor operator requalification
. program, review and audit activities, radiation protection program activities, and emergency preparedness activities were performed in-accordance with the applicable regulatory requirements prescribed in the TS, 10 CFR Part 19 through Part 71, and Department of Transportation regulations prescribed in 49 CFR Part 172 through-Part 178. Additional;information related to the examination of logs and records is discussed in the srbsequent sections of this inspection repor No violations ~or deviations were identifie Operator Requalification Program The operator requalification program is common to both'the Mark I and Mark F' facilities and is identical except for differences'in-control manipulations. Operators are licensed for both reactor The inspector verified by discussions with operators and examination of records that the requalification program was being implemented consistent with the NRC's approved program, dated October 25, 197 Records of operator review of ' abnormal and emergency procedures, examinations, reactivity manipulations, and supervisor evaluations for six individuals were verified to meet the program requirement The inspector noted that the training program did not provide the operators with an overview of the Radiological Contingency-Plan that was approved by the NRC in August 1984. This observation was
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discussed with-Associate Physicist-in-Charge and at the exit interview. .The Physicist-in-Charge _ stated that R0s and SR0s were provided training in the sites' Emergency Plan Implementin procedures and that,the' Physicist-in-Charge, Associate Physicist-in-Charge,.and Deputy Physicist-in-Charge all had copies of the
- Radiological Contingency Plan which they had read and understoo The Associate Physicist-in-Charge added that a discussion of the new
' Radiological Contingency Plan would be included as an' improvement item in the RO and SRO requalification program. The: Physicist's actions were acknowledged at the. exit intervie i-
- No violations or deviations were identified.
7 Experiments
.The inspector reviewed the documentation of the Criticality Safeguard Committee's (CSC) review and approval of' experiments -
initiated since the previous inspectio The CSC's reviews and approvals were accomplished in-accordance with established procedures and the approval process appeared to be consistent with requirements prescribed in the Mark 1 and Mark F T .No violations or deviations were identifie Licensee Event Reports Licensee reports dated November 14, 1985, and June.5, 1986, were i
discussed with the Associate Physicist-in-Charge.
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The November 14, 1985, report identified an occurrence wherein.the Mark F reactor was operated for a period of about one week with one of the power level scram settings having a set point 9% abo've the TS~
. limit. This. event was identified on the Region V open item list as open item numbers 85-11-L1 and 85-11-Y The discussions and record review disclosed that the Ereactor power ,
levels were maintained below Mark F's 1.5 megawatt limit. The scra *
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setting was based on an erroneous entry into.a lo'gbook made during'a
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power level calibration performed on September 27,1985. ' The error j was a result of an inadvertent juxtaposition of numbers that were i cntered into the logbook. The adequacy of the corrective 1 action l described in the licensee's report was verified during the inspection. Since the licensee identified, reported and corrected-
. the problem, no Notice of Violation is proposed for this matter, pursuant to 10 CFR 2, Appendix C.
The Tune 5, 1986, letter identified Region V open item number 86-05-RI, which reported that the in-core, number 4 thermionics
, device was discovered to have a slightly higher secondary pressure than the alarm point setting. This device provides a light alarm at I the Mark F reactor console. The corrective actions with respect to this occurrence were verified to be complete by the inspector. The corrective actions appeared to be satisfactor _
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s Items 85-11-L1,.85-11-Y1, and 86-05-R1 are close ' . Procedures The inspector examined operating procedures that were established
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for'the: Mark 1Jand Mark F TRIGA reactors pursuant to the applicable TS.
' The inspector noted that procedures were available at the facility and were being maintained by the reactor operating staff. The inspector also noted that the procedures are periodically reviewed for adequacy by the operating staff and the Criticality Safety Committee (CSC). New procedures and/or changes to. existing procedures since.the previous inspection were reviewed and, approved
' by the operating staff and CSC in accordance with the applicable TS and the. licensee's administrative procedures. , ,
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No violations or deviations were identifie Review and Audits Discussions with'the CSC Chairman and a review,of CSC records .
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disclosed that the CSC review and audit. functions for.the period of 1985 through July 1986 were consistentLwith the requirements prescribed in the Mark 1 and Mark F-TS. - ' '" _ ,
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The inspector concluded that the review and audits provided a i
detailed overview of reactor operations. 'The inspector noted that the review and audits did not provide a' verification that th ~
i radiation protection program at the TRIGA facilities or-the" Radiological Contingency Plan were being maintained.
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The. inspector discussed the above observations with .the Chairman of the CSC and at the exit interview.'
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e The inspector was informed that the depth of CSC audits woul be.
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expanded to provide a more in depth overview of the radiation, protection program and the Radiological Contingency Plan.
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No-violations or deviations were identified.
F Annual Reports The inspector reviewed the licensee's 1984 and 1985 annual reports
- for-the Mark 1 and Mark F that- were submitted to Region V in February 1985 and 1986 pursuant to the T The 'information provided in the reports was discussed with the TRIGA
- . facility operating staff and the site's Health Physics staff.
i-The inspector verified that the information provided in the annual reports was consistent with data recorded in the documents listed in
- . paragraph 2 of this inspection report.
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No violations or deviations were identifie . Radiation Protection Liquid and Solid W'astes All liquid and solid waste: generated from the Mark 1 and Mark F facilities is transferred to GA's SNM-696 Licensed Waste Processing Facility for ultimate disposal by a licensed disposal vendo Radioactive Material Shipments and Receipt
. A review of radioactive material shipping and receiving records
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indicated that activities-related to this subject were consistent with 10 CFR Part 20.205, 10 CFR Part 71 and Department of-
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Transportation regulations prescribed in 49 CFR Parts 173-17 Transfers-and/or shipments of radioactive materials are made through GA's State of California radioactive material. licens No violations or deviations were identifie Posting The inspector verified that the licensee's posting practices were consistent with 10 CFR Part 19.11, " Posting of Notices to Workers."
No violations or deviations were identifie Personnel Monitoring
The-licensee's program for assuring compliance with 10 CFR Part 20.202 was examined and was found to be consistent with the s regulatory requirements prescribed in 10 CFR Part 20.101 and 10 CFR Part 20.10 No violations or deviations were identified.
i- Facility Tour
, Several tours of the Mark 1 and Mark F facility were made during .the inspection period of October 7-10, 1986. The licensee's Emergency Support Center and the emergency equipment identified in the licensee's
- NRC. approved Radiological Contingency Plan were inspected during the
- tou Confirmatory measurements were performed on October 7 and 8 by_ the inspector using an Eberline Model R0-2 ion chamber, Serial No. 2691, that was due for calibration on October 9,1986. Radiation measurements obtained by the inspector were in agreement with those measurements documented on licensee survey record '
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Work practices observed during the tour were consistent with the recommendacions of 10 CFR Part 20.1(c) for maintaining personnel
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exposures "as low as is reasonably achievable" (ALARA).
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The inspector also observed neutron radiography operations at both the Mark 1 and Mark F TRIGA reactor facilities. The operations were performed in accordance with reactor operating procedure Observed portable and fixed radiation monitoring equipment was in current calibration. The calibration data provided on the instruments was in agreement with calibration records maintained by the licensee's electronics sho Although the licensee's posting and labeling practices were consistent with 10 CFR Part 20.203, the inspector noted areas where improvements could be made. These observations were discussed with the licensee's staff. The staff made the improvements prior to the conclusion of the inspectio The inspector also observed the licensee's staff performing their routine radiation and contamination surveys. Special neutron surveys, associated with the neutron radiography operations, were also taken by the licensee's staff during the tou The Associate Physicist-in-Charge (APC) informed the inspector that cleanliness was in need of attention at the TRIGA facilities. The APC stated that steps to clean the facility and to reorganize overcrowded cable trays and other equipment had been initiated several days prior to the inspector's visit. The inspector agreed that cleanliness and reorganization of cable trays were in need of attention. This observation was brought to the licensee's attention at the exit interview. The inspector was informed that the TRIGA staff would receive the support that was needed to clean the facilit No violations or deviations were identifie . Information Notices An examination was conducted to determine if Information Notices (ins)
were routinely evaluated by the licensee's staff for applicability to activities asecciated with operations performed at the Mark 1 and Mark F
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TRIGA reactor The examination disclosed that the licensee has established a program for evaluating in The licensee's newly appointed Manager, Licensing and Nuclear Compliance, has been assigned the responsibility for coordinating the review of correspondence such as ins, Bulletins, Circulars, and Generic Letters (see paragraph 6).
The inspector observed that the program established for evaluating such documents does not provide provisions for assuring that evaluations are performed in a timely manner. The inspector also noted that the results of IN and Generic Letter reviews performed by the licensee's staff are not well documented. The licensee's staff was unable. to determine the results of their evaluations of ins issued in 1982 and others issued in early 1986. The staff could only indicate that the ins had been received
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and that evaluations of their content were performed. The results of the evaluations had not been documente The inspector brought the above observations to the licensee's attention at the exit interview. The inspector stated that although there are no regulatory requirements governing the processing of documents identified -
.herein; the importance of determining their applicability to licensee activities and documenting the results of their efforts should not be underestimate The. licensee management acknowledged the inspector's observations stating that improvements would be implemented to establish a formal method for-processing ins, Bulletins, Generic Letters, and other important document No violations or deviations were identifie . Generic Letters The licensee's evaluation of Generic Letters (GLs) issued since the previous inspection period was examine Discussions with the-licensee's staff disclosed that GL 86-11,
-" Distribution of Products Irradiated'in Research Reactors," had been received and evaluated for applicability to activities performed at GA Technologie The discussions also revealed the following:
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GA Technologies has conducted irradiation of' products identified in GL 86-11 and has applied for a license pursuant to the
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recommendations discussed in the GL for domestic distribution of the product None of the irradiated products have been distributed to domestic vendors.
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Export of irradiated R&D products has been made in accordance with 10 CFR Part 110.23, " Export of Byproduct Material," and appropriate Department of Transportation requirements prescribed in 49 CFR Parts 173-17 No violations or deviations were identifie . Licensee Action On Previous Inspection Findings Actions taken by the licensee to resolve followup items from prdvious inspections were examined. The following items were examined:
Item N Followup Number Topic 1 50-89/83-02-01 Review of 10 CFR Part 50-163/83-02-01 19.12 Training Program
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2 50-89/84-01-01 Organization and 50-163/84-01-01 staffing of the radiation protection
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3 50-89/84-01-02 Adequacy and frequency
50-163/84-01-02 'for performing surveys 4 50-89/84-01-03 Implementation of the 50-89/84-01-03 -RWP program Each of the followup items were discussed with the Health Physics 4 supervisor and reactor operating staff. Additionally, Health Physics
implementing procedures, survey records, and training records were
- reviewed and a tour of the licensee facility was conducted to verify
actions taken by the licensee to resolve the followup items. The following licensee actions ~were observed:
Item N Licensee Action 1 The licensee has established a frequency of
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once every three years for conducting 10 CFR Part 19.12 refresher training. This excludes the TRIGA operating staff who received equivalent training under the NRC approved reactor operator qualification progra One additional Health Physics technician was added to the radiation protection staff since the previous inspection and the wor load under the licensee's SNM-696 license has decreased. The inspector observed that the Health Physics surveillance at the TRIGA facility has increased rather significantly as a result of these changes.
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The Health Physics supervisor' stated that the Health Physics surveillances have more than doubled since the previous inspectio Radiation protection procedures were changed to address the observation's related i
to this item. Changes to procedures established an increased frequency for performing surveys and provided
instructions for assuring that' surveys (e.g., contamination, air, radiation) are representative. The inspector note significant improvement in this area during
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the inspectio Health Physics and the reactor operating
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discussed in the Inspection Report and.to i
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enforce procedure HPD-21. The inspector verified that the RWP program was being effectively implemented during the inspection The inspector concluded that the licensee's resolutions in addressing the previous inspection findings were satisfactory. This matter is closed (50-89/83-02-01, 50-163/83-02-01), (50-89/84-01-01, 50-163/84-01-01),
50-89/84-01-02, 50-163/84-01-02), and (50-89/84-01-03, 50-163/84-01-03).
8. Emergency Preparedness Program The licensee's capabilities of responding to radiological emergencies in accordance with the NRC approved Radiological Contingency Plan of May 1984 were examined. Discussions related to this subject were held with the TRIGA facility operating staff, Health Physics supervisor, Emerge.ncy Coordinator, Manager of Human Resources, and Manager, Licensing and Nuclear Compliance. The inspector also verified that the emergency equipment, emergency response vans, emergency communication system, and the emergency response center identified in the plan were available, inventoried, and maintained in accordance with the pla Discussions with the licensee's staff disclosed that memoranda of understanding with offsite agencies, such as the Police Department, Fire Department, and Scripps Memorial Hospital were being maintained curren The staff stated that familiarization tours were provided to these offsite agencies whenever significant changes in offsite agency staffing occur. Normally, the licensee attempts to provide the tours on au annual basi The inspector also verified evacuation drills since January 1985 were conducted at the TRIGA facility at the six-month interval specified in Section 3.3 of the Plan. The inspector noted that no critiques were held to assess the performance of the evacuation drills. Section 9.2 of the Plan requires that records of drills and tests including the results of critiques be maintained. This was brought to the licensee's attention at the exit intervie The Emergency Coordinator (EC) stated an annual review of the Plan was in progress at the time of the inspectio Section 8.5 of the Plan requires the EC to perform an annual review and Section 9.2 requires that such reviews be documented. The EC informed the inspector that records confirming the 1985 review could not be located. He attributed this to recent moving activities and changes in personnel assignments. The EC stated that the records confirming the 1985 review may have been misplaced during the move or that they may not have been made by his predecessor. The EC added that other records identified in Section of the Plan may also have been misplaced during the mov The inspector noted the following areas needing improvement: Section 4.2 of the Plan states:
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" Training is provided to the participating agencies. This training is.usually,a simulated accident with simulated accident victim A~
scenario is-prepared and the participating agencies are requested t ,
take. part as players lor observers."
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The examination disclosed:
(1).Theblandoesnotspecifyafrequencyforconductingsuch
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a (2) To date, no training has been provided as' described by Section Section 5.4.4 of.the Plan states:
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" Arrangements have' been made with Scripps Memorial Hospital to treat ill or injured patients contaminated with > radioactive materia Periodic instructions are.provided to the hospital on handling-contaminated patients." .
Theexaminationdisclosedthatnorecordshere-availabletoconfirm that Section 5.4.4 had been accomplished and a frequency for providing the periodic instructions has not'been' establishe c. .Section 8.2.2 of the Plan states:
- " Personnel in the emergency organization receive on-the-job or additional specialized periodic training particular to their discipline."
L The examination disclosed:
(1) No records were available of the specialized or. the on-the-job
. training provided to the emergency organization members; (2)-.There were no records to indicate that theLemergency
. organization had been instructed on the plan since its approval
~ and issue in late 1984; and (3) The licensee's staff were not aware whether or not backup personnel assigned to the emergency orgeaization are-qualified to fill in or have received any specialized training with respect to implementation of the Plan. The inspector met with and discussed the Plan with key members of the licensee's staff. All of the members' indicated that they have copies of the Plan and that they have read and understand their role The above observations were discussed at the exit interview. The inspector emphasized the importance of reviewing the commitments made in the Plan, clarifying the ambiguous areas of the Plan, instructing the emergency organization and support organizations, and then assuring that the Plan is fully implemente _ - _ . _ _ _ _ . - . . .__ . _ . , . _ _ _ . ~ . _ . _ _ _ . . _ _ _ _ . . _ _ _ . . _ - _ , ~ _ _ .
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The inspector's observations were acknowledged and the inspector was assured by the Manager of Human Resources that the observations discussed at the exit-interview would receive GA Technologies'
immediate attentio Na violations or deviations were identifie . Environmental Monitoring Program General The. licensee has implemented and maintained an environmental monitoring program as . prescribed in SNM-696 license. The program includes: (1) air sampling, (2) water sampling, (3) soil and vegetation sampling, and (4) external gamma radiation measurement The minimum detectable sensitivity applicable to the program are provided below:
MINIMUM DETECTION SENSITIVITY Sample Type Radiation Sensitivity I
Water alpha 6 pCi/1 beta 4 pCi/1 gamma 3 pCi/1 Soil alpha 10 pCi/gm beta 2 pCi/gm gamma 0.1 pCi/gm Vegetation alpha 15 pCi/gm beta 2 pCi/gm gamma 0.5 pCi/gm 0.025 pCi/m3
Air alpha beta 0.010 pCi/m Radiation gamma 10 mR-beta 40 mR Dependent on total solids conten May vary dependent upon accompanying organic residu Seven day sampl The results of a review of environmental monitoring sampling records are discussed in the subsequent paragraphs of this sectio No violations or deviations were identifie .
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annual reports were discussed with the-licensee's' staf Significantly higher levels of Argon-41 releases were reported in'
1985 when compared to the proceeding years of 1982, 1983, and 1984 (i.e., from less than 0.5 Curies pre-1984_to approximately 2 Curies in 1985). The Health Physics _ supervisor stated that the data provided in'the' reports were determined by calculating the g production ~ of Argon-41 during reactor operations. _ The supervisor stated that the' calculations provide extremely conservative values 1 (e.g., a. factor of 5-6 higher) when compared to the values i determined from direct measurements seen'by the Mark 1 and Mark F monitoring system. The supervisor stated that this difference _is i not normally discernible during slack reactor operating periods.
l The supervisor added that the differences became prevalent when Mark F reactor usage was increased from less than an 8-hour / day operation
. pre-1985 to essentially a 24-hour operation in 198 The Health Physics supervisor informed the inspector that the basis
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for the-Argon-41 releases expected during Mark F operations was derived from the Mark III reactor Safety Analysis Report. The supervisor added that this-method was used because of;the similarities between the Mark F and Mark III reactor .
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The examination disclosed that the Mark 1 and Mark F airborne
. monitoring system is currently being modified to provide a more
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representative isokenetic sampling system. .The Health Physics supervisor said that Argon-41 releases reported after June 1986 will
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be based on measured values seen by- the Mark 1.and Mark F monitoring
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system. Argon-41 releases for the period of January through June 1986 were calculated as 10.40 Curie ~A' review of weekly particulate air samp' ling records did not reveal'
4- any airborne concentrations that were above the minimum detection
, sensitivity of 0.010 pCi/m3 limit established by the licensee's_
environmental monitoring program, t .
j No violations or deviations were identifie i' Water, Soil and Vegetation
. The review of water, soil, and vegetation sample analysis records
, did not reveal any levels above the minimum detection sensitivity provided in paragraph 4(a) this repor .
i l No violations or deviations were identified.
l Radiation Measurements
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The examination disclosed that film badges and thermoluminescent
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dosimeters are used at selected air sampling locations (e.g., such
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as the site boundary) to gain information on the environmental integrated dos The review ~of-direct radiation monitoring records supported the conclusion in the licensee's semi-annual environmental report that reactor operations have not contributed to radiation exposures outside the site boundar ,
No violations or deviations were identifie . Exit Interview The inspector met with the licensee's representativesf(denoted in paragraph 1) at the conclusion of the inspection on October 10,,198 The inspector summarized the scope and findings of the inspection. The inspector informed the licensee that.no violations'or deviations were
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