ML19269E805

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IE Insp Rept 70-0734/79-03 on 790305-09.No Noncompliance Noted.Major Areas Inspected:Mod & Changes to Facilities & Sys,Internal Review & Audit,Safety Committee Activities & Required Calibr
ML19269E805
Person / Time
Site: 07000734
Issue date: 04/27/1979
From: Book H, Cooley W, Riedlinger B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19269E796 List:
References
70-0734-79-03, 70-734-79-3, NUDOCS 7906290656
Download: ML19269E805 (19)


Text

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t U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V n

Report No.

70-734/79-03 I

70-734 SfN-696 safeauards croup I;

Docket No.

ttcons, no, Licensee:

General Atomic Company

},

P. O. Box 81608 San Diego, California 92138 Facility Name: Torrey Pines Mesa and Sorrento Valley Sites Inspection at:

San Diego, California Inspection conducted:

f4 arch 5-9,1979 Inspectors:

/5.-, ) [ d. /

7/;4' h/

W. J. Co'oley, F6el Facility Inspector D te signed Y.(/, l$YbIviA)

V/2(~/7'7 B. A. Riedlinged Radiation Specialist Date Signed Date Signed

/ l.d (I M1

//

7!/N Approved By:

' H. E. Book, Cnief, Fuel Facility and Materials Safety

' Dat! si'gned t

Branch summary:

Inspection on March 5-9,1979 (Report flo. 70-734/79-03)

Areas Inspected: Modifications and changes to facilities and systems; internal review and audit; safety committee activities; required cali-brations; sealed source leak test; review of operations; criticality safety; environmental program; emergency planning, fire prevention /

protection; radiation protection; radioactive waste management; con-firmatory measurements; and transportaion program.

The inspection

~

involved 76 inspector-hours by two flRC inspectors.

2 Results:

  • io items of noncompliance or deviations were found in the

?

subject areas inspected.

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2143 254 RV Form 719 (:

7 0062006TCg

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DETAILS v'-

1.

Persons Contacted 1-

  • H. H. Wellhouser, Director, Nuclear Material Control Division J
  • F. O. Bold, Manager, Health Physics Services S. D. Stevens, Health Physics Administrative Assistant G. D. Trimble, Health Physics Laboratory Operations y

J. Peters, Radiation Monitoring Programs K. C. Thompson, Health Physics Technician J. M. Keith, Health Physics Tec,Tqician R. J. Cockle, Health Physics Tec anician E. L. Spencer, Environmental Specialist

  • W. R. Mowry, Licensing Administrator
  • D. C. Pound, Manager, Nuclear Safety Control K. C. Duffy, Manager, Nuclear Materials Management C. L. Wisham, Nuclear Materials Management B. Evans, Material Custodian, Nuclear Materials Management T. W. Keim, Materials Custodian, Nuclear Materials Management H. O. Johnson, Supervisor, Hotcell Operations T. B. Crockett, Senior Section Leader, Radiochemistry N. Stewart, Manager, Triga Fuel Fabrication S. W. Rowland, Manager, Safety and Accident Prevention E. I. White, Environmental Surveillance Consultant e
  • Denotes those attending the exit interview.

2.

Organization Changes On December 21, 1978 the licensee announced the appointment of Dr. Harold it. Agnew as President of General Atomic Company effective in March, 1979.

7.

For some time, employees of Cryogenic Technology Incorporated have been conducting neutron radiography work at the licensee's Torrey M"

Pines Mesa site.

Effective November,1978 Cryogenic Technology Incorporated became a part of the General Atomic Company.

Employees of CTI are now those of General Atomic Company and the neutron radiography work is continuing.

J c

d n.

2143 255

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3.

Facilities Inspected The EAl, Triga Fabrication and Hotcell Facilities were inspected by both inspectors.

One inspector reviewed operations at the Waste Processing Facility.

4.

Facility Changes and Modifications The licensee's efforts in refurbishing hotcell facilities was h

described in NRC Report flo. 70-734/78-10 dated December 4, 1978.

1 During the presently reported insoection it was observed that cell y

interior work, cell windows and lighting fixtures and cell decon-tamination had been completed.

The decontamination cell had been enlarged and the planned roof port of the facility had been con-structed.

The new hotcell stack effluert sampler was being fabricated.

5.

Internal Review and Audit including Reviews by the Criticality and Radiation Safety Committee This inspection included reviews of reports of internal inspections conducted by members of the Nuclear Materials Control Division and by the Criticality and Radiation Safety Committee.

That review covered the period from December 10, 1978 through March 1,1979.

During that period of time nine audits were made by the Criticality and Radiation Safety Committee.

Those audits were addressed to Triga Fuel Fabrication, HTGR Fuel Fabrication (Sorrento Valley Building A), fuel Research and Development (Sorrento Valley Building B), Fuel Storage Facilities, Hotcell Operations, Metallurgy and Chemistry Laboratories, and the Waste Processing Facility.

Over the same period of time five additional audits were made by per-sonnel of the Nuclear Material Control Division.

Those audits were addressed to Sorrento Valley Building A Process and Pilot Plant Operations, Triga Fuel Fabrication, Fuel Storage Facilities, and Waste Processing Operations.

A number of recommendations for improvement were made by auditing personnel. As in the past, the licensee serializes and logs those recommendations, eventually " closing out" the matter when corrective action has been confirmed.

The review indicated no items of non-

<d compliance with NRC regulations or the conditions of the subject license.

The review of audit reports and discussions with licensee repre-sentatives indicated that two incidents had occurred since the last NRC inspection.

In one case the dry coater at the north annex of the Sorrento Valley A Building was double batched.

The double batching event amounted to inserting in the coater twice the process limit of fissile material.

After the double batching event at least two independent and concurrent events were still required before criticality could occur.

2143 256

~

t

The double batching occurred as a result of operator error.

The operator recognized his error almost immediately and went to the emergency removal operation which transferred the fissile material to a critically safe geometry.

The operator was following written emergency procedures when he removed the material from the coater.

Corrective actions taken by the licensee to prevent additional

,j double batching included the installation of a key operated inter-t lock on the coater loading mechanism.

The key is in the possession of the coater operations supervisor who must give his personal W

permission to open the coater loading valve.

The licensee also revised the coater run sheet providing a signed notation that the coater has been unloaded.

A second incident occurred in the Sorrento Valley Building A low-level scrap recovery area.

There, in a tubular furnace, burnable scrap material containing 150 grams U-235 and probably containing some organic material was being burned to completion.

The burning was accomplished by two independent jets one of air and one of oxygen being bled into the furnace.

The licensee's analysis of the situation indicates that the organic material had probably vaporized and condensed out in a cooler part of the turbular furnace.

It, then, subsequently ignited in the oxygen atmosphere.

A low-order explosion resulted.

The overpressure was relieved through the furnace tube which was connected with a large glove box and its loading and unloading port.

Additional pressure relief occurred through a particle trap to the filtered exhaust system.

No injury occurred although plexiglass windows of the glove box and its loading port were fractured and portions sent several feet across the recovery area room.

The furnace loading of 150 grams of U-235 was accounted for by weight measurements before and after the event.

Limited contaminated of the floor in front of the glove box was found and cleaned up.

Internals of the furnace were contaminated.

Corrective action taken by the licensee was a change in procedures for burning low-level waste in that the oxygen supply was eliminated and only air supplied to the process.

6.

Criticality Calculations 8

The licensee is recalculating the interaction d all fissik accumulations in the Fuel Production Department using the Solnew Code.

Previous interaction calculations had been done by hand using the solid angle criteria.

The Solnew Code is being used in the Sorrento Valley Building A as the need arises.

For example, (3

the calculation will be extended to the south end of the building fairly soon as equipment in that general area is reactivated.

The 9

Solnew calculations for the Sorrento Valley Building A are more

~

than 50% complete.

2143 257

._G.ac.

The Solnew Code was validated against solid angle calculations using arrays of cubes, spheres, cylinders, and planar arrays in various orientations.

The licensee has also validated Keno II and y'

is presently validating Keno IV codes.

1 The licensee has found the Solnew Code to be more conservative than the SAC calculation.

It also shows discontinuities (on the con-

,a servative side of SAC) as distances between interacting objects are varied.

The licensee plans refinements in the Solnew Code.

The i;

advantages of Solnew in its present application are that it pro-vides for shadowing effects, any spatial orientation of the inter-L acting bodies, 6nd provides for ready, recomputation in facilities in which there is frequent relocation of equipment containing fissile material.

7.

Independent Inspection Effort As an independent survey by flRC inspectors seven swipes were taken in the following locations:

(1)

EA Room 109, Clean side of change line (2) Clean side, liot cell change room (3) Triga Fuels Lab - Lunch room (4) Triga Fuels Lab - Clean side of change line (5) Triga Fuels Vault (6) Waste Processing Facility, Break room (7) Compacting shed floor, Waste processing Facility These swipes were counted on March 12, 1979 on the Region V fiMC PC-55 proportional counter.

Results indicated no significant removable contamination above background on any of the swipes.

b Air flow measurements were taken at four locations in the Triga Fabrication Facility and at two locations at the Waste Processing Facility.

All measurements were taken with the flRC #000381 Alnor i

Velometer with a Type 6050 fitting, which is appropriate for air velocity measurements between 0 and 300 feet per" minute.

One measurement in the Triga Fabrication Facility was between 140 and 150 ft/ min at the hood face.

The other three measurements were

?

~

300 f t/ min or greater at the hood faces.

All air flows met the requirements of the license specifications.

In addition, flaps had been installed on these hoods to keep personnel exposure as low as reasonably achievable.

2143 258 Q.,*:f Velocity measurements in the Waste Processing Facility were taken at the Compactor Sorting Station and at the Barrel Sorting Station.

The flows satisfied the requirements of Work Authorization 2303.

9 8.

External Dosimetry _

External radiation exposure data was reviewed for the period January 1978 to February 1979.

fio exposures exceeded the limits specified in 10 CFR 20.101.

The annual statistical summary report of personnel monitoring information as required by 10 CFR 20.407 was submitted for the year 1978 on February 20, 1979.

h The highest external exposure received by a G.A. employee for the year 1978 under the S!U4-696 license was 2.177 rems.

Quarterly exposures for this group did not exceed 1.25 rems.

Four G. A. employees were employed by CTI prior to flovember of 1978.

Their exposures from January 1978 through October of 1978 were visitor exposures, and their exposures in.avember and December were G.A. employee exposures.

The highest exposure received by one of these individuals during the year 1978 was 3.250 remi Quarterly exposures for these persons did not exceed 3 rem.

Three of the four personnel files for the former CTI employees were examined.

They contained completed flRC-4 forms and current fiRC-5 equivalent forms for the employees.

Two other CTI employees (who did not become G.A. employees) worked at G. A. as visitors during 1978.

One had c; exposure greater than 1.25 rems.

His quarterly exposure did not 2xceed 1.25 rems.

All other G.A. visitor exposures for 1978 were less than 0.5 rem.

Film badges and TLD finger rings are processed monthly by R. S. Landauer.

The films are inserted into personnel dosimeter holders which include two filters and two open windows for energy differentiation.

Sixteen types of computerized personnel exposure dab print-outs are available at the Health Physics Office. They.re summarized briefly below.

7; ~

a.

Employee Monthly History Detail (by errdoyee flo., date, dose, monitor, badge flo. )

Listed are:

Employee / Social Security flo./ Group / Organization / Adjustment, Adjustment Date/ Processing O

Date/ Sex / Birth Date/ Hire Date/ Dose / Monitor (film, TLD etc)/

Badge flo./ Gamma Dose / Beta Dose / Fast fleutron Dose.

fleutron measurements taken with hand-held instruments are b

entered into the detail with explanatory comments.

Prior radiation work exposures are also entered with comments.

2143 259 29

. b.

Monthly Exposure listing by organization and employee.

Listed are:

Employee flo./ flame / Social Security flo./ Group / Organization /

Dose Code / Monitor / Gamma, Beta, and fleutron doses, dose since a given date, allowable dose to the end of the year / alert flag.

l Two of these lists are printed.

One is maintained by the Health Physics Office and the other is separ ated into organi-q; zation groupings and sent to the appropriate supervisors.

H p

^

c.

flaster file of all personnel ever employed by GA listed by employee number (monthly print-out).

Listed are:

Employee flo./ flame / Social Security flo./ Age / Group / Location /0rganization/

Status (active or inactive)/ year to date exposure / maximum (5(fi-18))/ lifetime to date exposure / Balance /This quarter's exposure (including the right and lef t extremities).

d.

Monthly Visitor Print-out (alphabetica s by name or company)..

e.

Quarterly Visitor Ranking Summary.

f.

Annual Visitor Ranking Summary.

g.

Current Month - Radiation Input Listing (this is the information from Landauer with some explanatory comments added).

h.

Master listing for non-General Atomic Employees.

i.

Raw Source Input by Code - Badge.

j.

Audit - Input Error List (The raw input is checked for keypunch and filing errors.

This print-out is used when correcting such errors.)

k.

Location - Environmental - Experimental Badges.

1.

Permanent Badge Masters (by employee, badge, group or location y

numbers).

This gives the name, employee No., badge flo., group a

code, location code, social security number, and date the

[

first badge was issued for each employee.

L m.

Current Month Radiation Input List.

This gives the employee j

flo., badge flo., group, type of monitor, dose, and remarks.

If j

no name is listed, the reason will be listed in a log book j

kept by the Supervisor of Personnel Monitoring.

L n.

Visitor - Current Month Radiation Input List.

2143 260 ma

, o.

Annual Internal Radiation Report.

File flo., name, social security flo., birth date, sex, hire date, type of analysis, amount of material dotected, percent of maximum permissible limit.

t p.

GA Company - Equivalent of flRC-5 " Occupational External Radiation Exposure for Quarter End The following are listed:

File flo., name, social security flo., birth date, age, permissible accumulated dose, monitor (whole body, skin, L

right and lef t extremitites) date, doses for alpha, beta, and neutron, total and accumulated doses, adjustments, hire date, rU and adjustment due to previous employment data.

Also listed are whole body accumulated occupational dose totals as follows:

previous / adjustment to

/ quarterly / accumulated /

quarter prior quarter dose dose maximum permissible

/ remaining permissible accumulated dose accumulated dose and the employee status (currently employed or no longer employed).

9.

Internal Dosimetry Bioassays are carried out routinely at GA.

Helgeson Nuclear does the lung counts for enriched uranius., U.S. Testing analyzes urica samples, and total body and lung counts for thorium are done onsite.

Air samples are used to determine the frequency of bioassay testing.

The manager of the Health Physics Department stated that Regulatory Guide 8.11 was followed.

Urine samples ara used as a screening technique to decide which workers exposed to en-iched uranium will receive whole body or lung counts.

Other workers undergo bioassay checks depending on their contact with unsealed sources.

Bioassay notices are sent out each Thursday and urine samples are picked up the next Wednesday morning for shipment to Richland, Washing ton.

ig The U.S. Testing Lab would give telephone notice of any result that was 20% of a maximum permissible limit or above.

Urine samples are usually returned in a month.

They are sent to the Health Physics

]

Counting Lab where they are reviewed.

If there is a result that is greater than 10% of a maximum permissible level, the Manager of the M

Health Physics Department is notified.

He, in turn, notifies the J

Health Physics Surveyor, requesting an investigation.

This notifi-a cation procedure is documented in HPD-90.

The Manager of the Health Physics Department maintains records of these investigations.

2143 261 mg.

The internal dosimetry data for the year 1978 was reviewed.

The highest lung count for a GA employee during 1978 was 48.6% of the maximum permissible limit for U-235.

Controls have been used to m

reduce exposure in this person's work place, and urine samples are E

routinely collected from him.

6 The licensee compiled his inplant air sample data for the Sorrento

[

Valley Building A fuel production effort.

Airborne contamination y

concentrations were assembled for 18 areas of the production

~a facil i ty.

The concentration data was averaged for each area over a

cach of the four quarters of 1978.

Those averages were presented i

as a percentage of the maximum permissible concentration as specified in 10 CFR 20, Appendix B.

That data reduction indicated an average quarterly concentration of less than 10 percent of the 10 CFR 20 limts and no individual sample in excess of 10 times the maximum permissible concentration. On the basis of that 1978 data the licensee has reduced his urinalysis bioassay program frequency from twelve to four samples per year and his in-vivo lung counting pro-gram from four to two times per year.

4 Similarly, the licensee compiled data expressing removable con-taminatior per unit area in the controlled areas of the Sorrento Valley Building A.

That data was assembled for 16 identified areas where routine contamination surveys are made. The data covered the year 1978 and was averaged over each of the four quarter: of that year.

The data compilation indicated a trend toward reduced removable contamination over the year.

10.

Termination Report (20.408)

When personnel leave GA, they are asked to check out with Radiation Protection.

A log is kept there with employee numbers, names, hire dates, exposure, date the letter was sent, social securit,. umber, bioassay information, and a forwarding address.

The personnel folder of an employee terminating in the second quarter of 1978 was examined.

The folder contained a letter sent to him forwarding his exposure data.

A carbon copy of that letter had been sent to NRC headquarters.

i, _

11.

Waste Processing Facility The Waste Processing Facility, associated work authorizations, procedures, air sample results, and health physics log were in-spected.

The facility operates under three work authorizations tj which describe:

Ju 2143 262

  • W.

_9_

a.

The general operation and maintenance of the Waste Processing Facility as described in the WPF Operating Procedure Manual.

b.

The use of the Waste Processing Facility (WPF) Evaporating Ponds.

6 c.

The use of the WPF Incinerator.

Eleven procedures are also followed:

a.

Waste Yard, General A

This procedure gives general instrudions and a few specific comments:

(1) Rain water collected in the WPF must be sampled prior to release if contamination is suspected.

(2) Containers reading 100 mr/hr at the surface are labeled, roped off, and posted with " Caution, High Radiation Area" signs.

b.

WPF - Evaporation Ponds, (1) The interior and the top surfa.:a of pond areas are con-sidered to be contaminated.

Shoe covers and protective clothing are required when entering the pond area.

(2) Access gates are closed and locked unless the Waste Processing Facility or other personnel are presenu.

(3) Spills are reported to the WPF supervisor.

All spilled water is pumped, vacuumed, or mopped and returned to ponds. Affected surfaces are decontaminated.

(4) Ponds are not allowed to evaporate to dryness.

This precl; des airborne contamination problems.

m; ~

'1 If clean-out is necessary, inputs are suspended.

If greater than 350 gms of U-235 is present, a Work Authorization must be submitted to clean out the ponds.

The Health Physics office j

will be notified of the date and time the cleanout is to be 3

performed, and a surveyor will maintain surveillance.

r 5,

d Protective clothing, rubber gloves and eye protection are worn by all personnel performing the clean-out.

2143 263 y*

+ *

. G.x.

. c.

Solidification Procedure This procedure describes the neltralization and solidification

]

of acids, filtrate solutions, oil, and water.

p y

d.

Compaction of SNM Waste Into 55-Gallon Barrels in Preparation j

for Disposal

]

e.

Use of Atmosphere Supplying Respirators at the WPF J

Respirator users must have the prior approval of the Medical Department. Medical approval is documented on GA Form 1518.

Each individual must read and understand this procedure and sign a statement (GA 1517) to that effect.

Hoods may be used only in designated areas at the incinerator, evaporation ponds, and the main yard.

The user may leave an Area at any time for relief.

Breathing air supply lines are color coded light blue, and outlets have " Breathing air" nameplates.

They are fitted with quick-disconnects which may not be changed or adapted.

Respirator users must record their name, area, and tines in and out on a Form GA-1525.

Respirators are stored in the WPF Tool Room.

They may not be returned to clean storage in the Tool Room without health physics clearance.

If a hood needs to be decontaminated, it is sent to a decontamination room for cleaning.

The air supply is 6 CFM, with a pressure of 50-90 PSI Three-hundred feet is the maximum supply air hose length.

The following equipment is used:

3-M W-870, W-5005 helmet, W-2800 air regulating valve and breathing tube assembly.

W-9434 air-supply hose.

9 3-M W-856, W-5201 hood, W-2800 air regulating valve and 5

breathing tube ast,bly.

W-9435 air supply hose.

b These are Bureau of Mines - NIOSH approved systems.

This procedure is consistent with the health physics procedure for G

respiratory protection, HPD-48, which also specifies that, " Pro-L vision must be made for visual surveillanco ef, and communication with, the worker wearing respiratory protet. tion equipment."

      • 7

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~ 500.

. f.

Bunker Storage Area Bunkers are made of solidified bags of concrete and sand.

They are eight feet in height and closed on three sides.

Bags n'

are double-row stacked to a height of four feet with access through the opened end.

y a

The facility provides containment for high radiation level barrels with grfater than 50 mr/hr but less that 2 R/hr at the L

surface.

The ba rels may be awaiting processing, shipment to burial, or disposition.

The access gate is alarmed and locked.

The open end of the bunker is 50 feet from the fence.

An operating radiation detection instrument must be used inside the area.

g.

S_or_ ting of SNM Materials prior to Incineration in the Waste Processing Incinerator This procedure discusses removing non-burnable material from waste.

Sorting is carried out at a barrel sorting station which vents to an exhaust. Air samplers are used

..en the station operates, and protective clothing and safe y glasses are worn by personnel at the sorting station.

h.

Waste Yard Incinerator This procedure is for the safe and effective incineration of burnable radioactive wastes.

The incinerator is not currently in use and will not be used until the exhaust vent ducting and filter plenum are repaired.

i.

Compositing Small Inputs to 55-Gallon Drums This procedure discusses how to maintain material traceability when more than one drum is being composited.

j.

Maintenance Lock-Out and Tag Procedure m-Locks and tags are used to assure that equipment is completely

)

shut down before it is repaired.

i k.

Records This procedure applies to material accountability, trace-ability, and oroduction control.

A 2143 265

..&. j' The WPF air sample results are maintained in the health physics log book.

ThoseresultswereexaminedfortheperiodJulT218, 1977 to The highest alpha count was 6.5 x 10' uCi/ml.

March 6, 1979.

The permissible U-235 concentration in restricted areas is 1 x 10-10 m

uCi/ml.

Tg permissible Th-232 concentration in restricted areas is 3 x 10-uCi/ml.

l The Waste Processing Facility Health Physics Log was examined for the time January 1978 to March 1979.

The Manager of the Health

?

Physics Department reviews this log each month.

,(

The log indicated that the heavy rains and high winds in Jant'ary, February, and March of 1978, caused erosion and damage to the waste evaporatic.i pond covers.

For those reasons gunnite banks were fabricated.in September of 1978 to control erosion, and the evap-oration pond covers were replaced in December of 1978.

Due to erosion problems, some areas of the waste yard were cleared of waste materiG s.

Those materials were moved to other areas of the yard.

Materials are loaded on a Tri-State trailer to be sent to Nuclear Engineering Company in Beat y, Nevada for disposal.

Barrels are put on the trailer after their contents have been compacted, solidified, or if they exceed 50 mr/hr at the surface.

There is a weight limitation on the barrels that can be loaded onto the truck.

12.

Environmental Air Samples Air sample data for the year 1978 were inspected.

The environmental consultant stated that stack air samples are counted daily as a screening technique to detect abnormalities.

Later, they are re-counted after short-live' isotopes have decayed.

Outlying air samples are counted weekly.

Alert level procedures are followed for air sample results.

Levels were chosen based on operating experience.

The environ-mental consultant reviews the data to look for " spikes" or elevating 5'

concentrations.

?

Of the radioactive material used at General Atomic, uranium is our concern under SNM-696.

Therefore, the alpha counts taken when air samples are analyzed (and the yearly averages of those counts) are of primary importance.

Beta counts are also taken of the samples, L

but they are not discussed here unless otherwise noted.

1.

2143 266 m.tGM.

- Computer print-outs of average air sample results (by year or month) are maintained by the Supervisor, Radiation Monitoring Programs.

Results discussed below were obtained primarily from F

that data.

The environmental consultant stated that background levels in sampling areas are not subtracted from the reported data.

Ten outlying samplers operated throughout 1978.

Two were taken out of use.

One was taken from use because construction was occurring in the area and someone was unplugging the sampler. The other was l

taken from use because paint spray at the location (an auto body z

shop) was interfering with the sample. To replace those samples, two new stations were set up.

The uranium-235 concentration allowed in effluents to unrestricted _geas is given in 10 CFR, Appendix B Table II, Column 1 as 4 x 10 uCi/ml. The group average for

-15 1978 for the outlying samplers for the year 1978 was 1.576 x 10 uCi/ml.

Five air samplers operated at the Sorrento' Valley A Building Site Perimeter during 1978.

The uygnium-235 concentration allowed in unrestricted areas is 4 x 10-uCi/ml, as previously stated.

The group average for 1978 for the five air samplers was 3.725 x

-j 10 uCi/ml.

Four air samplers operated throughout 1978 at the Sorrento Valley A Building Roof Perimeter The yearly average for these air sample

-15 results was 16.37 x 10 uCi/ml.

The roof perimet area, so the result should be compared with 1 x 10-g is a restricted u,/m. the U-235 concentration allowed in restricted areas as given in 10 CFR Appendix B, Table 1, Column 1.

Seven samplers operated all year in 1978 on the Sorrento Valley A Building Roof Exhausts.

Ten absolute filter plenum samplers, one soot filter sample, and a furnace exhaust sample were operated only part of the year.

These samplers were phased out since stack samples rather than individual plenum samples are taken now, and thefurnacehasbeenremged.

The group average for 1978 for these sampler}0was 0.851 x 10-uCi/ml.

This may be compared with 1 x 10-uCi/ml, as has been discussed.

Two SVA roof scrubbers were operated in 1978.

They now have air samplersbeforegndafterimpingers.

The average result for 1978 1

-j wasj.660x10 uCi/ml.

Themaximumyeglyaveragewas4.680x

-j 10 uCi/ml.

This compares with 1 x 10-uCi/ml.

Three ground exhausts were operated during 1978 at the Sorrento ValleyB_Qcility.

The yearly average for thegr sample result is 8.7 x 10 uCi/ml.

This compares with 1 x 10 uCi/ml.

2143 267 o

e5.h.

_14_

Two air samplers operated throughout 1978 af3the Triga Fabrication Building.

Tg yearly average was 3.1 x 10~

uCi/al which compares

~

uCi/ml.

with 1 x 10

~

Seven air samples were collected from the E-Building Roof Exhausts from January through April of 1978.

The ventilation system was 1

then upgraded and new treatment equipment was installed.

Only two fume scrubbers and one absolute filter plenum remain the same.

To indicate these changes in the computer print-out of air sample results, new designations were chosen for the E-Building Roof

[

Exhaust samples.

Six samples were routinely taken from that

~

locationfromMaytoDegmberof1978.

The group average f-$0the samplers was 1.22 x 10' uCi/ml. This compares with 1 x 10 i

uCi/ml.

Its yearly a Onehotcell_gackoperatedthroughout1978.This may be compared with 2 x 10 gra uCi/ml, was 9.2 x 10 uCi/ml.

the most restrictive value for plutonium or thorium releases to restricted areas.

An EA-1 Building Pu stack opeygted from August to December.

The yearly _gerage was 8.59 x 10 uCi/ml.

This may be compared with 2 x 10 uCi/ml, as discussed i~i3the preceding paragraph.

A higher than expected (1.59 x 10 uCi/ml) beta count appeared one month, due to the venting of a muffle furnace through the EA-1 stack.

In addition, the sample was a low-volume sample because water and acids had stopped the air pump.

Thorium was the material being processed in the furnace.

Amendment 2 of the subject license contains Condition No.15 which requires the licensee to modify his existing environmental monitoring program to include plutonium analysis of soil samples in the vicinity of Laboratory Building EA-1.

Those samples are required if indication of plutonium is found in air samples collected from the exhaust system monitoring that building.

To form a basis for such possible future soil sample measurements the licensee established four soil sample locations in the vicinity of the EA-1 Laboratory and obtained background samples on August 15, 1978.

Those samples had been analyzed for plutonium 238 and plutonium 239.

The maximum indication for plutonium 238 was 0 i.02 pCi/g and the maximum indication for y

plutonium 239 was 0 i.01 pCi/g of soi.

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e

13. Sanitary Sewer Releases i

r~

The releases to the sanitary sewer in 1978 from the Fuel Fabri-1 cation Facglity were examined.

The highest monthly average was 1

1.26 x 10- uCi/ml.

The permissible limit, as defined in 10 CFR R

-4 20.303(c) is given in Appendix B, Table I, Column 2 and is 8 x 10 p

uCi/ml.

The total activity released during 1978 was 274.7 uCi.

~

This is below the one curie per year limit of 10 CFR 20.303(d).

2143 268 C..;

M.

- 14.

Packaging and Transportation of Radioactive Materials The licensee has established a program to control the receipt, delivery and transport of licensed radioactive materials.

Author-ities and responsibilities for packaging and shipment of hazardous materials are given in the licensee's Policy and Procedure Manual d.

documents CPM-712, CPM-706 and CPM-708.

Those documents are g

addressed respectively to management and safety of radioactive o

materials and radiation producing devices; radiological health; and the shipment of hazarc'aus equipment and material.

Those documents d

assign the responsibility for radiological health and safety in-cluding the shipment of hazardous equipment and material to the.

fluclear Material Control Division.

Those documents further reference the Radiological Safety Guide (report GA-417); the fluclear Material Control Manual; and the Accident and Prevention Manual.

The Radiation Safety Guide and the manuals restate the responsibilities of the Health Physicist Services Department, fluclear Materials Management Department, and Criticality Control.

They go into further pro-cedural detail for the receipt and shipment of radioactive materials.

The Radiological Safety Guide further references the responsibilities of the Traffic Department, Security, and Licensing Administration with respect to their involvement in a shipment or receipt.

Any responsible employee of the licensee may initiate a shipr. ent.

A shipment may consist of a number of identical containers each of similar loading such as a shipment of reactor fuel elements.

A shipment may include a single sample of radioactive material or a unique radioactive piece of equipment.

In any case the shipment originator executes. the GA-288 form which is a request for shipment of radioactive material.

This is submitted to the fluclear Materials Management Department.

From that point on the fluclear Materials Management Department coordinates the shipmen't.

That coordination includes verification that various shipping forms and records are executed including the Radioactive Material Removc1 Record (GA-558); shipping order (GA-211); and Material Transfer Form (GA-796).

That coordination also includes a determination of the eceptability of the shipment for processing; i.e., (package integrity, package

..~~

certification); ilRC license conditions on consignee; and health physics requirements of necessary package surveys.

The various shipping forms references above (and their attachments) constitutes records of the type of materials shipped, health physics survey q

information. and summary information as to the consignor / consignee, da t.t: of shij ment, date of receipt and material transfer information.

Procedures for the receipt of radioactive material, again, place 3

i the responsibility for coordination at the fluclear Materials Management Department.

Those procedures include the responsibilities 2143 269

- of the Traffic Department and the Health Physics Department. The receiving procedures include coordination between the Traffic Department :nd Health Physics Department in determining damage and

(

the extent of damage to received packages and the arrangements for handling damaged and/or unsafe containers.

Health physics respon-sibilities include monitoring the shipment vehicle and driver and

o directing cleanup operations as necessary if there is evidence of M

damage to a shipping container.

The above statements of respon-sibilities and procedure detali are contained in Sections 4.8 and j

4.9 of the Radiological Safety Guide (GA-417).

g.

Actual loading of shipping containers with radioactive material is done by the requestors who are most of ten representatives of the Fuel Production Department and the Triga Fuel Fabrication Group.

The shipping containers used by those persons are Model FSV 3 (Certificate of Compliance flo. 6347) and Models Triga 1 and Triga 2 (Certificates of Compliance flos. 9034 and 9037).

Package loading and unloading procedures as well as acceptance tests and a maintenance program for reuse of Models Triga 1 and 2 were presented in application for certification and were available during this inspection.

Similar package loading procedures have been written for the Model FSV-3 package and it appears as a part of the Fuel Production Department Procedure FPD-503.

Additionally, Quality Assurance Department procedures exist for packaging and inspection for reuse of package Models FSV 3 and Triga 1 and 2.

Those are used by representatives of the Quality Assurance Department in verification that the packages used are in acceptable condition and have been properly loaded.

Records of that verification are maintained by the Quality Assurance Department.

The Nuclear Materials Management Department, in its capacity as co-ordinator, also records its verification of the acceptability of the package and its loading.

This inspection included discussions with the licensee concerning the Model FSV-1 spent fuel shipping cask which is intended for use by the licensee and others to transport spent HTGR fuel.

Tha t r

spent fuel cask is described in the licensee's document GADR55 and

}

its Addendum 1, Revision A, dated February 21, 1979, the letter of 9

which is presently under review by the NRC.

Those documents j

contain cask loading and unloading, leak test, and cask maintenance y

procedures.

E Annual audits are conducted by the licensee's Criticality and

]

Radiation Safety Committee which are addressed to the performance of the departments of the Nuclear Material Control Division in-cluding the Nuclear Materials Management Department.

2143 270

- This inspection included a review of the licensee's file of Cer-tificates of Compliance for shipping container models authorized m

for use.

That sampling indicated complete files including all backup material referenced in the Certificate.

This inspection included a review of Nuclear Material Management Department records for the shipment of both Triga and HTGR type

[.

feel. Those records appeared to be complete and responsive to the

[

requirements of 10 CFR 71.

)

The licensee has occasion to use the DOT specification 7A con-tainer. _ This inspection included a review of one such use.

On that occasion a certified (tested) 7A container was built by the shipment requestor.

One dimension of the container exceeded that dimension of the certified container and its use was not authorized by fluclear Materials Management Department without additional qualifying tests.

The required tests were prescribed by fluclear Materials Management, were performed, recorded, and witnessed by representatives of Nuclear Materials Management, Quality Assurance, Experimental Engineering personnel and other licensee personnel.

Af ter that testing, the fluclear Materials Management Department approved the use of the qualified type 7A container.

Finally, additional written procedures are available in the Health Physics Department specifying the actions required by the Health Physics Technicians with regard to receipts and shipment.s of radioactive materials. Those procedures are addressed to the use of shipping forms (including survey records) calculating the curie content of shipping casks, and detailed actions and notifications required upon receipt of damaged packages.

15. Sealed Source Leak Tests This inspection included an inventory of the licensee's plutonium sealed sources.

That inventory indicated the licensee possession of 42 plutonium 238 sealed sources.

Forty-one of those sources contained approximately 0.18 grams plutonium 238.

One source contained approximately 6.02 grams plutonium 238.

The licensee h

also possesses 0.2' grams plutonium 239 as an flBS standard and 0.14 j

grams plutonium 239 as a spent fuel sample.

j Each of these sources was leak tested in June,1978 and indicated less than 0.005 microcuries of removable activity.

Subsequent to A

that leak test the various sources were placed in three sealed metal cans.

Those cans were leak tested on October 25,1978 and d

ind..ated less than 0.005 microcuries of removable activity.

L 2143 271

.t. c 4.Ji.

I

~ 16. Management Interview The results of this inspection were discussed with licensee repre-p sentatives at the conclusion of the inspection on flarch 9,1979.

The inspection results were also discussed with W R flowry by telephone on April 6,1979.

Those individuals were informed that no items of noncompliance or deviations were observed within the scope of this inspection.

L 2.

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,n 2143 272 e

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