IR 05000089/1998202
| ML20249A701 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 06/11/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20249A698 | List: |
| References | |
| 50-089-98-202, 50-163-98-202, 50-89-98-202, NUDOCS 9806180120 | |
| Download: ML20249A701 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket Nos: 50-89 and 50-163 License Nos: R-38 and R-67 Report No: 50-89/98-202 and 50-163/98-202 Licensee: General Atomics Facility: TRIGA Reactors Facility Location: 3550 General Atomic Court, Building 21 San Diego, CA Dates: May 4-7,1998 inspector: Craig Bassett, Senior Non-Power Reactor inspector Approved by: Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate ENCLOSURE 2 9806180120 980611 PDR G ADOCK 05000089 PDR
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i General Atomics TRIGA Mark I and Mark F Report No: 50-89/98-202 and 50-163/98-202 The primary focus of this routine, announced inspection was the on-site review of selected aspects of the licensee's Class 111 non-power reactor facility including: organization and staffing, review and audit functions, radiation protection, emergency preparedness, safeguards and security, operator requalification, and surveillance. A tour of the site and a tour of the Sorrento facility were also conducted.
l Chances. Organization, and Staffina e The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specification Review and Audit Functions e Audits were being conducted by the Criticality Safeguards Committee (CSC) as required by the Technical Specifications, e Audit findings and corrective actions appeared to be acceptabl e The CSC is being disbanded. Since the CSC was a subcommittee to the Criticality and Radiation Safety Committee (CRSC), the audit and oversight functions of the CSC will revert back to the CRSC as soon as a license amendment is submitted to and approved by the NR ,
Radiation Protection Proaram e Surveys were being completed and documented acceptably to permit evaluation of the radiation hazards that might exis * Postings met regulatory requirement e Personnel dosimetry was being worn as required and doses were well within the licensee's procedural action levels and the NRC's regulatory limit * The Work Authorization for the TRIGA Reactors Facility was being revised to reflect the new organizational responsibilitie e Radiation worker training was being completed as stipulated by licensee procedur Emeroencv Preparedness Proaram o Licensee emergency response plans and procedures were being maintained and updated as require e The most recent annual on-site emergency exercise was conducted according to requirements outlined in the Radiological Contingency Pla l l
e No Letters of Agreement were in effect but offsite agencies indicated that support i would be provided in case of an emergency.
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e .The training provided by the licensee to emergency responders was acceptable and complied with the requirements in the RC o One violation was identified for failure to conduct a semiannual criticality evacuation drill as require Physical Security e The NRC-approved security program at the facility was generally being carried out acceptably, e . One violation was noted for failure to change the key locks in the TRIGA Reactors Facility as required by the Physical Security Pla Reaualification Trainina Proaram e The licensee had acceptably conducted a requalification training program and was maintaining training records as required, o One violation was noted for allowing two individuals whose licenses had expired to operate the TRIGA Mark I reacto Surveillance e The licensee was acceptably completing the surveillance reviewe l l
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REPORT DETAILS j Summary of Plant Status The licensee's two TRIGA reactors remain in a shutdown status. The NRC has granted the licensee a " Possession Only" amendment to the license for each reactor. During the inspection, the licensee cuotinued to possess the two reactors but not operate them as stipulated in the licenses and applicable Technical Specification I 1. Changes, Organization, and Staffing (40755) <
a. Jnsoection Scoce The inspector reviewed the following regarding the licensee's organization and staffing to ensure that the requirements of Technical Specification (TS) Section (for the TRIGA Mark l) and TS Section 8.1 (for the TRIGA Mark F) were being met:
. the organi:.ational structure, e managemer". responsibilities, and
. staffing requirements for safe maintenance of the TRIGA Reactors Facility, b. Observations and Findinas As noted during a previous inspection, management responsibilities and the organization for the TRIGA Reactors Facility at the site were changing. In the past, the TRIGA Reactors Facility has been under the supervision of a Physicist-in-Charge who reported to the Vice President responsible for research and development. After being granted a " Possession Only" amendment to the license for each reactor, the licensee remains in the process of changing the responsibility for management of the facility. This responsibility will be given to the Manager of Decommissioning Projects so that a coordinated effort can be made to initiate the decommissioning of the reactor facility. This latter phase is dependent upon the licensee receiving approval 4 trieir Decornmissioning Plan from the NR Through review of records and through discussions with licensee personnel, the inspector determined that the staffing at the facility was acceptable to support the ongoing activities. The staffing met the requirements of the T c. Conclusions The licensee's organization and staffing remain in compliance with the requirements specified in the T . Review and Audit Functions (40755)
a. Insoection Scone The inspector reviewed the following to ensure that the audits and reviews stipulated in the requirements of TS Section 9.2 (for the TRIGA Mark 1) and TS Section 8.2 (for the TRIGA Mark F) were being completed and to ensure that the safety committee was meeting as required:
. Criticality Safeguards Committee (CSC) charter and meeting minute records,
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. Criticality and Radiation Safety Committee (CRSC) charter,
. General Atomics (GA) administrative procedures, and
. TS duties specified for the CSC and the CRSC including the committees' review and audit function b. Observations and Findinas The inspector reviewed the CSC's meeting minutes from 1997 through the presen The meeting minutes showed that the committee met as required by the TS with a quorum being present. The inspector also noted that the CSC had cc sidered the types of topics stipulated in the T It was noted that the committee, or a designated representative, completed audits of the general aspects of the TRIGA Reactors Facility operations and programs. The audits and the resulting findings, as well as the licensee's responses and corrective actions, appeared to be acceptabl The inspector also noted that the current TS for the TRIGA Mark l calls for oversight by the CRSC while the current TS for the TRIGA Mark F calls for overcight and review by the CSC. The licensee indicated that the CSC was no longer needed at the site and was going to be disbanded. Since the CSC was initially setup as a subcommittee of the CRSC, the review and audit functions of the CSC will revert back to the ORSC during the decommissioning of the reactors. The licensee was aware of the inconsistency in the two sets of TS for the TRIGA reactors and was in the process of submitting a license amendment and TS revision for the Mark F to require review by the CRSC as wel c. Conclusions Audits were being conducted by the CSC as required by the Technical Specifications. Audit findings and corrective actions appeared to be accentabl The CSC is being disbanded. Since the CSC was a subcommittee of the CRSC, the audit and oversight functions of the CSC will revert back to the CRSC as soon as a license amendment is submitted to and approved by the NR . Radiation Protection Program (40755)
a. insoection Scooe The inspector reviewed the following to verify compliance with 10 CFR Part 20 and the applicable licensee TS requirements and procedures:
. health physics survey records,
. radiological signs and posting, e dosimetry records,
. Work Authorization records related to the TRIGA Reactors Facility, and,
. radiation worker trainin The inspector also toured the licensee's facility and observed the use of dosimetry and radiation monitoring equipment. Licensee personnel were interviewed as wel .
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b. Observations and Findinos (1) Surveys Weekly, monthly, and other periodic contamination and radiation surveys, air samples, and air flow checks were completed by Health Physics (HP)
technicians as required by TS and licensee procedures. Results were evaluated and corrective actions taken when readings or results exceeded set action level (2) Postings and Notices Postings at the entrances to the controlled areas were acceptable for the hazards present. The facility's radioactive materiai storage areas were properly posted. No unmarked radioactive material was note Copies of current notices to workers required by 10 CFR Part 19, including NRC Form-3, were posted in appropriate areas in the facilit (3) Dosimetry The licensee used a National Voluntary Laboratory Accreditation Program (NVLAP) accredited vendor to process personnel thermoluminescent dosimetr An examination of the records for the past two years through the date of the inspection showed that all exposures were well within NRC limits and licensee action levels. Most of the records showed no exposure above backgroun Dosimetry was acceptably used by facility personne (4) Work Authorization Records 1
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Selected Work Authorization records were reviewed. The inspector noted that the records were being rnaintained as required by procedure. The Work Authorization was in the process of being revised to refloct the decommissioning requirements and the new organization that will be in charge of the operation. This was stillin progress because the transition had not yet occurred shifting responsibility from the operations group to the decommissioning grou (5) Radiation Worker Training The inspector noted that the licensee had changed their training progra Previously the program had required radiation workers to be trained annuall The new pr'ogram was changed to require radiation worker training on a biennial basis. It was also noted that, in the past, the reactor operators at the TRIGA Reactors Facility had not been required to take the annual radiation worker refresher training because it was felt that their extensive operations requalification training covered all aspects of the refresher course. The operators had been exempted by a memorandum from the Director of Licensing, Safety, and Nuclear Compliance. The inspector indicated that the training offered in the refresher course would be beneficial for everyon However, since the TRIGA reactors were shutdown and most of the operators
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had been transferred to other jobs, this issue was not pursued further. Also, the group that will have responsibility for the decommissioning of the reactors said that everyone in that group would be required to take radiation worker training and refresher trainin c. Conclusions Surveys were being completed and documented acceptably to permit evaluation of the radiation hazards that might exist. Postings met regulatory requirement Personnel dosimetry was being worn as required and doses were well within the licensee's procedural action levels and the NRC's regulatory limits. The Work
' Authorization for the TRIGA Reactors Facility was being revised to reflect the new organizational responsibilities. ~ Radiation worker training and refresher training was being completed as stipulated by licensee procedur . Emergency Preparedness Program implementation (40755)
a. Insoection Scone The inspector reviewed the following to ensure that the Radiological Contingency Plan and the emergency procedures were being updated and implemented _
consistently with the TS and the requirements specified in the emergency plan:
- the review, approval, and distribution of the Radiological Contingency Plan (RCP)
and emergency procedures;
- the documentation of recent drills and exercises; e any Letters of Agreement; e emergency responder training records; and,
- records of criticality evacuation drill b. Observations and Findinas
' (1) Emergency Plans and Procedures The inspector reviewed documentation and discussed the RCP and TRIGA .
Reactors Facility emergency procedures with licensee personnel. The last major update / revision to the RCP, Rev.10/97, was submitted for NRC review and-subsequently approved by the NRC on March 25,1998. Since then, no major revisions or changes have been made. The inspector noted that the Emergency -
Procedures for the TRIGA Reactors Facility had been updated and the latest g . revision, Rev.11, was dated September 29,1997. It was also noted that the i RCP and emergency procedures had been distributed to the staff members as E . required.
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.The inspector reviewed the results of the most recent annual on-site emergency exercise conducted at the site involving the TRIGA Reactors Facility. The exercise was conducted on April 23,1996. The exercise was conducted in accordance with, and fulfilled the requirements stipulated in, the RCP. Key licensee emergency response personnel demonstrated that they could respond to L - -
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emergencies as required. Offsite response was provided by Scripps Memorial Hospital as requi ed by the Plan. During 1997, the licensee had taken credit for an actual event that involved a fire in the Hot Cell Facility on November ,
i Using an actual event to substitute for the annual drill is allowed by the i licensee's RC (3) Letters of Agreement The inspector asked about the lack of any Letters of Agreement (LOAs) signed by offsite agencies that would ensure that they would respond in case of an l
emergency. Offsite agencies mentioned in the Plan are principally governmental- l type agencies. They have told the licensee that they have a statutory responsibility to respond in case of an emergency and that no formal, signed :
LOAs are neede (4) Training Review of the records and documentation of the training given showed that emergency response personnel were receiving the training outlined in Section 10.2 of the RCP. The training included radiation safety, basic first aid, cardiopulmonary resuscitation (CPR), and basic fire suppressio (5) Semiannual Criticality Evacuation Drills TS 9.3.c requires the licensee to have written instructions for emergency and abnormal conditions including provisions for evacuation, reentry, recovery, and medical suppor Section 10.3 of the RCP requires that criticality evacuation drills be conducted l semiannually at each facility that uses special nuclear material (SNM) in quantities sufficient to require a criticality warning alarm syste Because the TRIGA Reactors Facility has a criticality warning alarm system, the inspector reviewed the criticality evacuation drills conducted there from 1996 through the present. The inspector determined that drills were typically held as required. However, a review of the records showed that a drill was held on July 12,1997, and that no one evacuated because no one was present. When the inspector asked about this drill and the reason why no one evacuated, the licensee reviewed the matter. The licensee determined that on Saturday, July 12,1997, a four-hour class was held for HP technicians and Security personnel. One subject covered was the proper response to the Criticality Warning Alarm System (CWAS) at each GA nuclear facility having a CWAS system installed. The licensee found that the " drill" listed as completed to fulfill the requirements specified in RCP Section 10.3 did not qualify as a drill because no one was told that it was a drill and no one evacuate In response to this problem, the licensee took various corrective actions. On May 7,1998, the problem was discussed with the HP technician who had been involved with the training in July 1997. It was emphasized that an evacuation drill should have been held later in the month. Also, on May 8,1998, a memorandum was sent to all HP technicians and other appropriate individuals l
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reminding them of the importance of the CWAS drills. A letter documenting the l corrective actions was sent to the inspector on May 11,199 l
The licensee was informed that the failure to conduct a semiannual drill in l accordance with the RCP was identified as a violation of TS 9.3 (VIO 50-89/98- 1 202-01).
I c. Conclusions l Licensee emergency response plans and procedures were being maintained and updated as required. The most recent annual on-site emergency exercise was conducted according to requirements outlined in the Radiological Contingency Pla l No Letters of Agreement were in effect but offsite agencies said that support would '
be provided in case of an emergency. The training provided by the licensee to emergency responders was acceptable and complied with the requirements in the l RCP. One violation was identified for failure to conduct a samiannual criticality l evacuation drill as require . Physical Security (40755)
i a. Insoection Scoce To verify compliance with the licensee's NRC-approved Physical Security Plan (PSP)
and to assure that changes, if any, to the plan had not reduced its overall effectiveness, the inspector reviewed- 1
- logs, records, and reports, i e the security organization, e intruder detection and physical barriers,
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b. Observations and Findinas ,
i The licensee's PSP, entitled " Fixed Site and Transportation Plan for the Protection of Special Nuclear Material of Moderate and Low Strategic Significance," dated April 1997, requires in Part 11, Section 3.2 that key locks and combinations for controlled access areas (CAAs) will be changed anytime a new area is activated or . . . at least annually. Section 1.3 of Part ll stipulates that the Mark I reactor CAA encloses all accesses to the reactor's pool, control console, and shop are The inspector determined that the licensee's physical protection program conformed to NRC requirements and to the licensee's PSP and implementing procedures with one exception. Upon review of the documentation of the key lock changes made at the TRIGA Reactors Facility, the inspector noted that the key locks had been changed in March 1995, February 1996, but then not again until December 1997 (for 1998). This indicated that the key locks had not beeri changed for 1997 as i require ,
When this matter was brought to the attention of the licensee, other records were searched to determine whether a record of a 1997 key lock change existed. During
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the inspection the individual who is currently in charge of key lock changes was on j
vacation and some records were not readily available. The licensee reviewed those other records following the inspection and concluded that the locks were not changed in 1997. In a letter to the inspector dated May 11,1998, the licensee stated that the oversight in not changing the key locks in 1997 was thought to have occurred during a transition of locksmith personnel in early 199 The licensee was informed that failure to change the key locks annually as stipulated in the PSP is a violation (VIO 50-89/98-202-02).
c. Conclusion i The NRC-approved security program at the facility was generally being carried out acceptably. One violation was noted for failure to change the key locks in the l TRIGA Reactors Facility as required by the Physical Security Pla . Operator Requalification Program (40755) i l
a. Insoection Scone The inspector reviewed the licensee's reactor operator requalification training program and reactor operations logs to determine compliance with the requirements in 10 CFR 55.3 and 55.5 b. Observations and Findinas 10 CFR 55.3 requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator as defined in this par I 10 CFR 50.54(i) requires that, except as provided in 10 CFR 55.13, the licensee !
may not permit the manipulation of the controls of any facility by anyone who is not a licensed operator or senior operator as provided in 10 CFR Part 5 CFR 50.54(k) requires that an operator or senior operator licensed pursuant to Part 55 of this chapter shall be present at the controls at all times during the operation of the facilit The inspector verified that the operators, who were qualified to operate the TRIGA reactors during the time when the reactors had been operational, had completed the requalification program. However, it was noted that the operator licenses of two individuals had not been renewed in a timely manner during a period from late 1995 through early 199 In late 1996 the NRC had become aware of this problem (failure to renew operator i licenses) at a few non-power reactor (NPR) facilities and in January 1997 had
[ telephoned all NPR licensees to inform them of the problem. When GA reviewed the status of their operators, it was noted that two individuals no longer held current operator licenses. Because the individuals had completed the requalification program at the facility, the licensee subsequently submitted license renewal applications for them on January 28,1997. The Director of Licensing, Safety, and L
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l 8 l Nuclear Compliance also issued a memorandum to the Director of the TRIGA Reactors Facility on February 21,1997. The memorandum reiterated that, when a person's operating license expired, that person could no longer operate the reacto On March 17,1997, the NRC issued a letter to GA officially informing them of the problem of untimely operator license renewal. The NRC reviewed the licensee's license renewal applications and each of the two individuals received another operating license dated March 21,199 Through a review of reactor logs, the inspector determined that the licensee's TRIGA Mark i research reactor was operated on various occasions in 1996 and 1997 by the two individuals whose licenses had expired. Individual A, whose reactor operator license had expired on November 8,1995, operated the reactor on
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I various occasions in 1996 and on January 23,1997. Individual B, whose reactor operator license had expired on November 7,1996, operated the reactor on various occasions in 1997 including February 21 and March 4. It was noted that individual B had operated the reactor after the license renewals had been sought and after the memorandum had been sent to the Facility Director reiterating the fact that the i reactor should not be operated by anyone whose license had expire The licensee was informed that allowing two individuals whose licenses had expired to operate the TRIGA Mark i reactor is a violation of 10 CFR 55.3 (VIO 50-89/98-202-03).
c. Conclusion The licensee had acceptably conducted a requalification training program and was maintaining training records as required. One violation was identified for allowing two individuals whose licenses had expired to operate the TRIGA Mark i reacto . Surveillance (40755)
a. Ipsoection Scoce The inspector reviewed selected surveillance test documentation to determine compliance with the requirements in TS 3.4,5.2.3, and b. Observations and Findina_ s The inspector reviewed documentation regarding various activities required in the TS such as sampling pool water conductivity, calibrating the area radiation monitoring system, and maintaining a specific number of fuel elements in one storage wel The inspector determined that the licensee was completing the surveillance as require l c. Conclusion !
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8. Follow-uo on Previousiv Identified items a. Insoection Scoce
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The inspector reviewed the licensee's actions taken in response to a previously identified Non-cited Violation (NCV) and an inspector Follow-up ltem (IFI).
b. Observation and Findinas
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(1) (Closed) NCV 50-163/93-02-01 - During a previous inspection in August 1993, it was noted that, due to a deficient lock design, a reportable safeguards event had occurred in December 1992. The licensee had not recorded the event in the Safeguards Event Log within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by 10 CFR 73.71(c). The licensee subsequently discovered the error, recorded the event 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the event had occurred, and reported the failure to the regional office. Following that, the NRC conducted an inspection to review the event, the licensee's procedures, and the reactor emergency plan to assure that security events are reported as require During this inspection, the inspector again reviewed the licensee's procedures and reactor emergency plan to assure the proper reporting of security event The procedures and emergency plan were determined to be acceptable. This item is considered close (2) (Closed) IFl 50-89/95-01-02 - During a previous inspection in September 1995, it was noted that the TRIGA Reactors Facility had never been the building directly involved in an emergency exercise scenari During this inspection, the inspector reviewed an emergency drill that the licensee had conducted in April 1996. The drill included the TRIGA Reactors Facility and involved a scenario in which two reactor facility personnel had
" fallen" into the pool. The drill also included off-site support from the Scripps Memorial Hospital. The inspector verified that the drill had been completed as indicated by the licensee. The drill was acceptable. This item is considered close c. Conclusion The licensee had taken appropriate actions regarding previously identified open items. These items are considered close . Exit interview The inspection scope and results were summarized on May 7,1998, with members of licensee rnanagement. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspecto ___----------------__ _ _ _ _ __ _
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PARTIAL LIST OF PERSONS CONTACTED Licensee K. Asmussen, Director, Licensing, Safety, and Nuclear Compliance G. Bramblett, Manager, Decommissioning Project E. Drees, Chair, Criticality Safeguards Committee J. Edwards, Vice President, General Counsel and Secretary L. Gonzales, Manager, Health Physics H. Kleinsorge, Security Administrator W. LaBonte, Manager, Hot Cell Decommissioning P. Maschka, Health Physicist Supervisor K. Moore, Health Physics Technician
- J. Razvi, TRIGA Products and Services W. Stout, Senior Reactor Operator, TRIGA Reactors Facility INSPECTION PROCEDURE USED IP 40755 Class lll Non-Power Reactors ITEMS OPENED. CLOSED, AND DISCUSSED Ooened 50-89/98-202-01 VIO Failure to conduct a semiannual drillin accordance with the Radiological Contingency Pla /98-202-02 VIO Failure to change the key locks annually as stipulated in the Physical Security Fra /98-202-03 VIO The TRIGA Mark I reactor was operated on various occasions during 1996 and 1997 by two individuals whose licenses had expire Closed 50-163/93-02-01 NCV Failure to record a security event in the Safeguards Events Log within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as require /95-01-02 IFl Follow-up on the lack of direct involvement of the TRIGA Reactors Facility in an emergency exercise scenari I J
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LIST OF ACRONYMS USED CAA Controlled Access Area CFR Code of Federal Regulations
- CPR Cardiopulmonary resuscitation CSC- Criticality Safeguards Committee CRSC .' Criticality and Radiation Safety Committee CWAS Criticality Warning Alarm System G General Atomics HP Health physics IFl Inspector Follow-up item IP, Inspection Procedure LOA Letter of Agreement NCV Non-cited Violation NPR Non-Power Reactor NRC Nuclear Regulatory Commission
~ NVLAP National Voluntary Laboratory Accreditation Program
- PDR Public Document Room PS Physical Security Plan RCP.- Radiological Contingency Plan RO Reactor Operator SNM Special Nuclear Material SRO: Senior Reactor Operator TS- Technical Specification VIO Violation
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