ML20010F537
| ML20010F537 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 08/24/1981 |
| From: | Book H, Cooley W, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010F532 | List: |
| References | |
| 70-0734-81-09, 70-734-81-9, NUDOCS 8109100329 | |
| Download: ML20010F537 (11) | |
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e U. S. NUCLEAR REGULATORY C0fEISSION OFFICE OF INSPECTION AND ENFORCE!1ENT REGION V Report No. 70-734/81-09 Docket !!o.70-734 License No. SNM-696 Safeguards Group,
I Licensee: General Atnmic cnmnany P. O. Box 81608 San Dieco. California 92138 j
Facility Name: Torrev Pines Mesa and Sorrento Valley Sites Inspection at: San Dieco. California Inspection conducted: July 28-31,1981 Inspectors:
1 J 7 (/ d P/>/ /9/
W. J. Cooley, fisel Fa lities Inspector Date' Signed Approved by:
h&T IL M R. n. Thomas, Chief
/ Date Signed Meter' ls Radi ion Protection Section Approved by:
C-tM 2Y
/
H. E. Book, Chief Date Signed Radiological Safety Branch Summary:
Inspection on July 28-31, 1981 (Report No. 70-734/81-09)
Areas Ir"pected: Organization; Facility Changes and Modifications; Internal Audit and Review; Operations Review;. Environmental Program; Radiation Protection; and Transportation Activities. The inspection involved 27 inspector-hours onsite by one NRC Inspector.
Results: No items of noncompliance or deviations were found in the subject l
areas inspected.
Fom 2M (2)
Oo 4
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DETAILS J
1 1.
Persons Contacted
- H. N. Wellhouser, Manager, Nuclear Material Control Division
- W. R. Mowry, Licensing Administrator
- F. O. Bold, Manager, Health Physics Services
- K. C. Duffy, Manager, Nuclear Material Management C. L. Wisham, Nuclear Material Accountant i
T. W. Keim, Nuclear Material Accountant B. Evans, Nuclear Material Accountant J
R. L. McDermott, Supervisor, Nuclear Material Processing Center 3
i E. L. Spencer, Environmental Specialist W. H. Morris, Production Control, Nuclear Safety Coordinator
- J. P. Hogan, Attorney
- Denotes those attending the exit interview.
2.
Organization The licensee is experiencing a reduction in force at the Fuel Manufacturing Department of about fifty individuals including administrative and operations personnel. The Health Services Department anticipates a reduction of four individuals: two Health Physics technicians; one Records and Reports clerk; and one Waste Processing technician.
Health Physics services will retain six Health Physics technicians. One early retirement at the Triga Fuel Fabrication Facility will leave two operations personnel at that facility devoting part time to the manufacture of Triga fuel.
l The use of fissile material is presently limited to approximately twenty kilograms U-235 at the Fuel Manufacturing Department in the Sorrento Valley where it is being prepared for safeguarded storage j
until approximately September 1982. The Fuel Manufacturing Department will be devoted to the production of fertile (thorium) material j
between August 1981 through September 1982.
Resumption of the use of enriched uranium will be at the later date.
3.
Facility Changes and Modifications Phy:ical changes and modifications of the Fuel Manufacturing Department l
l facilities at Sorrento Valley were discussed in Inspection Report No.
l 70-734/81-01 dated January 26-29, 1981 in sections 3 and 7.
Of the selected changes listed in that section 7 the following tasks have been completed.
Relocation of the fuel block loading station; removal of the cure-in-place furnace; storage of special nuclear material from its present locations to the main tunnel vault and the north tunnel annex.
The old north in-process vault was being removed and the new west vault l
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. facility was being constructed. Almost all procedures and work authorizations had %en completed for the present physical set up while some revision of procedures and work authorizations for the new set up will be required.
The south in-process vault will remain intact and be used indefinitely for the storage of thorium. The soot filter and scrubber have been removed from the roof of Building SVA and installed at ground level at the north end of the building.
Fuel block storagc space has been provided in the north tunnel annex and Fort St. Vrain reactor segment
- 9 is presently stored there. Construction of the new west vault is underway. Modification of the radwaste water system and modifications of the fuel operations change rooms have not yet been scheduled.
Tamper safe stcrage of special nuclear material should be completed in September,1981 after which time only thorium will be used until about September 1982 in the Fuel Manufacturing Department.
Criticality approval had been received for the relocation of fuel block loading stations, fuel block storage space in the north tunnel vt44; installation of fuel storage racks; the design of the new west vault; and the temporary storage of packaged, finished fuel blocks.
4.
Internal Review and Audit criticality audits and various correspondence on the subject of criticality with respect to the operations in the Fuel Manufacturing Department, Sorrento Valley, were reviewed during this inspection. The source of the information was a file maintained by the Nuclear Safety Coordinator at the Fuel Manufacturing Department.
Ths.t file indicated that criticality inspections had been conducted at the manufacturing facility and reported on at least four occasions between January and May, 1981. The areas visited included vault storage, pilot plant, and process areas. The first of those inspections (January 21, 1931) noted that all previous recomendations made through the year 1980 had been corrected.
Additional recomendations for improvement were made, one requiring imediate corrective action. That matter was the positioning of an unattended move cart in the barrel storage area.
A written reply to that inspection indicated that all recommendations had been followed and corrective action taken.
Various pieces of correspondence dating from January 10 through March 27, 1981 indicated consideration of the NRC requirements regarding Radiological Contingency Plans for Fuel Cycle and Materials facilities.
In connection with that planning a new criticality alarm system has been ordered and a study of the building air change rate after loss of ventilation power was calculated, tested, and reported complete on May 6,1981.
Additional correspondence in the Criticality Coordinator's files indicated requested approvals by the Nuclear Safety Control Department from the Criticality and Radiation Safety Comittee for the relocation of a
. weigh station, a V blender and its glove box, and the deletion of a centrifuge filter.
Another request for approval covered the interaction calculations associated with the fuel element loading, handling and storage areas in the SVA building.
5.
Operations Review / Radioactive Waste Management This inspection included a visit to the Waste Processing Facility.
The licensee had constructed a metal building to house a shredding machine and a compactor-baler along with required ventilation equipment for the volume reduction of low level radioactive waste. The shredder had already been delivered to the building; the compacter-baler arrived during the inspection on July 31, 1981.
Additionally the liccisee was modifying a purchased liquid waste filter system.
His intentiot was to filter to the one micron particle size liquid waste containing thorium and uranium. Ultimately the licensee planned to discharge the filtrate under controlled conditions to the San Diego Sanitary Sewer System. The licensee had no plans to handle liquid waste emanating from the hot cell complex in that manner but rather to continue to solidfy that waste for licensed land burial.
A laroa accumulation of low level waste had been packaged and stored in td. Jaste Processing area.
The licensee presently has no waste land burial site available for waste containing fissile material.
Some of the accumulated waste can be handled through the newly acquired shredder and compacter-baler reducing some of the backlog volume.
Simultaneously additional waste will be~ generated.
The licensee plans on abandoning solar evaporation as a primary method of volume reduction of liquid waste.
Some consideration may be given to resumption of incineration.
6.
Environmental Programs The licensee's environmental program includes 30 soil, 26 vegetation, and 9 surface water samples which are analyzed annually by an independent laboratory. That analysis is for gross alpha and gross beta and additionally analyzed by isotopic scans. At the same locations as the soil, vegetation and water samples the licensee obtains an air sample which is changed weekly.
All the above samples are obtained ' ' site and to a radius of approximately three miles off site.
The licensee regards ventilation stack effluent samples as part of his environmental praram.
a'* effluents are presently obtained from stacks at the Triga Fuel Fabrication Laboratory, Hot Cell, Fuel Manufacturing Department, and laboratory stacks.
The environmental program akso includes weekly samples of incoming tap water at both the Sorrento Valley and Torrey Pines Mesa facilities as well as weekly samples of sewage effluent from both of those facilities.
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. Alert levels have been established for each of these measurement types and a reporting mechanism set up for reporting any monitoring result which exceeds the alert level. The alert levels and their reporting are established in health physics procedures.
This inspection included the review of the maximum observed environmental alpha and beta activity as measured during the months of January through June, 1981.
Over that period of time the alpha results were observed to be approximately a factor of two greater than normally experienced while the beta results ranged between a factor of approximately 10 to 20 times the results normally experienced. The maximum environmental air egncentration was experienced in February,1981 and indicated 233 3
fci/M beta. A maximum of 19 fci/M alpha was measured during January,1981. A review of mon:hly composites of air sample filter papers was made for the months, June 1980 through February 1981.
Isotopic scans of those composites indicated natural isotopic activity between June and October, 1980 followed by identifiable weapons fall out between November,1980 and February,1981.
A similar comparison can be made between the soil, vegetation, and water samples attained in April 1980 and in April 1981. Among those results for soil and vegetation, traces of weapons debris were found in the isotopic scan.
Surface water samples did not show that effect.
Soil, vegetation, and water samples in the Environmental Program show no particular trend in gross alpha and gross beta activity. Gross alpha re.tivity ranges typically from 0-27 pci/g in soil samples.
Gross beta activity in soil samples ranges typically from 23-100 pci/g. Gross alpha results for vegetation samples are typically zero pci/g.
Gross beta results for vegetation samples typically range from 10-60 pci/g. Alpha results for surface water samples are typically zero pci/l and gross beta activity for surface water samples ranges typically from 7-35 pei/l.
A review of hot cell exhaust stack results for the months January through June,1981 indicated that some difficulty had been experienced with over that period of time was approximately 4.4 x 10 gation experie ces the HEPA filters in that system. The maximum concen microcuries/cc beta activity.
Filters were replaced and DOP tested by an independent l
organizatig resulting in a reduction in the effluent concentration to 2 x 10-microcuries/cc by June, 1981.
The fuel manufacturing building in Sorrento Valley is presently equipped with five exhaust stacks discharging at a level above the roof, and one fume scrubber and one soot filter which were removed from the roof I
and placed at ground level in June,1981. The latter two devices are not presently in operation.
. A review of three of the fuel manufacturing building exhaust stacks identified as the north, middle, and south gacks indicated maximum alpha discharges of approximately 1.4 x 10 beta concentrations of approximate microcuries/cc from January through June,1981.
Measuiements of influent tap water used at the Torrey Pines Mesa site indicated alpha concentrations of about 5 pci/l which lies near the limit of detection.. Beta concentrations of the tap water were similarly near the limit of detection of approximately 3 pci/1. Measurement of the effluent (sewage) water from the Torrey Pines site typically ranged higher than the tap water by a factor of two. Tne maximum sewage concentration experienced between tpe dates of this review (January through July 19) was approximately 2 x 10- microcuries/cc alpha.
wasapproximately1.5x10-gageconcentrationoverthesixmonthsreview The average Torrey Pines se microcuries/cc alpha Those concentrations may be compared with the concentration of 8 x 10~4 microcuries/cc for U-235 in Appendix B, Table 1, Column 2 of 10 CFR 20 or the concentration of 4 x 10- microcuries/cc which appears for unidentified isotopes in the 10 CFR 20 Appendix B Note 2.b.
A licensee representative gave the opinion that the sewage radioactivity concentration is effected by occasional laboratory discharges to sinks which drain to the sanitary sewer line.
This inspection review of tap water and sewage discharge occuring at the Sorrento Valley Plant indicated approximately the same results.
7.
Radiation Protection This inspection included a review of Health Physics Services annual report on the results of air sampling in the SVA building #37.
Reports of that nature are accumulated on a quarterly basis. Average airborne concentrations expressed in percentage of maximum permissible concentrations are calculated for each of the number of well defined areas in the Sorrento Valley production facilities. That data is averaged for each of those areas and again averaged over ail the areas for each quarter of the year and for each of the three operating shifts. The results of the process are reported to the Manager, Fuel Manufacturing for his infomation.
That report presents the quarterly airborne concentrations for each area measured and for the facility as a whole for each quarter and each shift. The report also presents removable surface contamination levels for the areas monitored for each quarter and presents the highest single air sample for each quarter and each shift of that quarter in percent of maximum permissible concentrations. Any observable trends are highlighted in the transmittal of the report to the Manager, Fuel Manufacturing.
This inspection included a review of all results of that nature for the year 1980 and for the first and second quarters of 1981.
. All three reports indicated that the average concentration in operating areas of the Fuel Manufacturing Department were less than 10% of MPC for the entire year 1980 and for the first and second quarters of 1981.
The highest single sample obtained during the year 1980 was approximately 7 x MPC; 4.2 x MPC for the first quarter 1981; and 4.9 x MPC for the second quarter, 1981.
exceedapproximately3100dpm/100cm{.;220[dpm/100c 1980 did not during the first quarter of 1981; and 1290 dpm/100 cm during the second quarter of 1981.
Over the period of time reviewed there did not appear to be any significant trends in specific operating areas. Trends toward higher airborne concentrations were observable between the fourth quarter,1980 to the first quarter,1981 and to the second quarter,1981.
Highest single air sample results showed no particular trends over this period of time.
However, those highest single samples appeared more frequently at the dry coater operation and at the wet and dry scrap recovery operations.
As part of the licensee's bioassay program an independent laboratory made 100 lung counts of 100 employees during May 18-22, 1981. Those counts indicated 23 positive indications, the maximum of which was 132 micrograms + 48 micrograms U-235. There were no positive uranium urinalysis bioassays over that same period of time. The lung count portion of the bioassay program will contin"9 through September, 1981 but the services of the independent laboratory will cease at that time because the Fuel Manufacturing Department will devote itself entirely to the use of natural thorium. The licensee has imediately available a whole body counter capable of measuring thorium deposition.
The use of enriched uranium will continue in approximately September,1982.
8.
Transportation Activities T:,a licensec had designated in writing the individuals and organizations assigned responsibility for transport activities; explanation of the authority and duties of those individuals and organizations; and written procedures or instructions for carrying out the various processes and details of the transport activities. The organizations becoming involved in the receipt and transfer of radioactive material are the Health Physics Services, Nuclear Material Management, Traffic Department, Security Department, and Licensing Administration.
Those management controls are documented in at least two licensee manuals: Nuclear Materials Custody Control manual; and the Radiological Safety Guide (GA 417).
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. Section NMM-4 of the Nuclear Materials and Custody and Control Manual addresses the Nuclear Material Manageraent Operating procedures for the shipment of radioactive material.
It presents the responsibilities and procedures of the Nuclear Materials Management Department which include the proper handling, preparing, packaging and documenting of shipments of radioactive material.
It also presents the general responsibility of maintaining nuclear materials management records and reports; the responsibility of the material custodians for completing the details that require documents for a given shipment; the Health Physics Department for performing surveys as required; the Traffic Department for making final arrangements for transport of the shipment; the Security Department for arranging the physical protection requirements for strategic quantities of special nuclear material; and the Licensing Administration Department for obtaining and verifying the licenses required for all offsite shipments including export shipments along with the permits for special containers or packaging required.
Nuclear Material Management-Section 4 goes on to detail the responsibilities and interfacing of the Material Custodians and Material Technician in making the detailed arrangements for this shipment including the completion of the Radioactive Material Removal Record (GA558); Shipping Order (GA211); material transfer of source and special nuclear material (GA796). When the packaging requirements have been determined and pr for to the Nuclear Material Management Department's acceptance of the shipment the individual requesting the shipment is required to obtain proper packaging and a packaging certification if required.
After health physics surveillance has been completed the Nuclear Material Management Technician is responsible for affixing required labels to the inner package, mounting the inner package into external shipping container, making the necessary record of packaging identification; and making all required measurement data and records which might involve shipper-receiver evaluation for mos.t special nuclear material shipments.
The procedures go on to require confirmation of required tamper-indicating seals, affixation of tamper-indicating seals, recording both external shipping container number and tamper-indicating seal numbers and affixing appropriate labels to external shipping containers. After the material has been so packaged the Nuclear Material Management Technician is required to complete the shipping container inspection report and the shipment check off list and the radioactive material shipping data form (GA-1831). The procedures continue to require Nuclear Material Management to assemble all documentation for completeness and to furnish its final approval along with carrying out certain requirements for physical protection of strategic material. The shipment is then referred to the Shipping Department and a final inspection is made to assure that tamper-indicating ' seals are intact and container and seal numbers are in agreement to those initially applied.
Post shipment actions specified require maintaining certain documents until the receipt of the shipment has been acknowledged by the receiver.
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,. Lctear noterial Management Section 4 is oriented both towards strategic material and byproduct material.
The accompanying container inspection report check off list appears to include additional requirements regarding packaging such as the placement of absorbent material; internal bracing and cushioning; assurance of container sealing; model numbers on shipping containers; proper marking and labeling; and others.
Nuclear Material Managemeat Section 4 of the Nuclear Material Custody and Control Manual is identified as document GA1688-A.
Nuclear Material Management Section 5 of the Manual is referred to as document GA1281 and is entitled Nuclear Material Management Operating Procedures Receiving Radioactive Material. That section of the Control manual is similar in format to Nuclear Material Management Section 4 in that it gives general responsibilities and procedures to be followed upon receipt of radioactive material. Again it is oriented toward strategic material but includes byproduct material. Health Physics Services is called for assistance early in the series of procedures to evaluate any apparently damaged incoming containers. The inspectiori of Nuclear Material Management personnel as well as Health Physics personnel is required when damage is suspected. Opening and verification of the receipts of shipping containers is performed by Nuclear Material Managemer.t with the instructions and guidance of a Health Physics Services representative. Records of the receipt of radioactive material are maintained by the Nuclear Material Management Department.
Similar responsibilities and procedures are contained in sections 4.8 and 4.9 of the licensee's Radiological Safety Guide (GA-417). Those two sections refer respectively to the receipt and offsite shipment of radioactive material. They are more brief than the Nuclear Material Management procedures but demonstrate the responsibilities of the same organizations: Nuclear Material Management, the individual making the shipment, Health Physics Services, the Traffic Department, Security, and Licensing Administration. They also go into detail regarding the surveys required by Health Physics Services and provide examples of the various shipping forms required for each shipment. One of the forms previously mentioned was GA-588 which includes infomation regarding the name of the radionuclide, the total activity, the quantity of special nuclear material and/or source material, chemical / physical form; removable contamination levels; rcdiation levels at the surface and three feet from the package; and special radiation level considerations for exclusive use vehicle.
The licensee has a documented program for indoctrination and training of personnel performing transport activities.
' femal program is attended by members of.the Nuclear _ Material Ma. Agement Department annually. That program is presented by Federal Express in the form of a seminar and includes radioactive materials along with all other hazardous materials regarded by the Department of Transportation.
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That course was last attended by three members of Nuclear Materials Management Department and one member of the Shipping Department on April 8-9,1980. Additional in house training is continuous along with the standard training courses which am given in the subjects of radiation safety and criticality safety by the licensee.
Audits of the transportation program are covered by the Criticality and Radiation Safety Comittee (CRSC) and have been reviewed in previous reports.
Additionally, audits of the transportation activities of the licensee are conducted as scheduled by a senior member of the Nuclear Materials Management Department. The subjects covered are custodian log keeping; physical inventories; production prccess; tamper safing; shipping / receiving; and waste yard operations. The subjects involved are given at bi-monthly to annual frequencies and specific training auditors are assigned in the case of each subject. The 1981 Nuclear and Material Management audit schedule was presented along with the names of subjects and auditors by letter to distribution dated March 18, 1981.
A documented program of Quality Assurance as required by 10 CFR 71.12 and 71.51 has been submitted to the NRC and approved.
The licensee possesses approximately 33 certificates of compliance covering special containers although many of those are seldom used.
The licensee depends largely on D0! specification 17H,17C, and 6M containers for shipment of material.
Certificates of compliance are invoked in the case of the m. del Trige I and Triga II shipping container.
Quite often a 7A specification container is selected from Document MLM2228-TID 4500 " Certification of ERDA Containers Packaging with Respect to Compliance with D0T Specificaton 7A Perfomance Requirements".
The licensee does not use foreign made packaqes nor any small packages less than the approximate size of a five gallon drum. NRC, Region V has confirmed that the licensee has registered a number of package certifications and their package identification number.
On one occasion a specification 7A package as taken from document MLM2228 did not meet that document's required dimensions for the load anticipated.
On that occasion the licensee performed the required tests before making use of the package. The licensee does not use the DOT specification 55 container. The only time special form is invoked by the licensee in the shipment of radioactive material has to do with the return of spent radiography sources. The licensee has recently shipped by aircraft three heart pacemaker plutonium 238 batteries (total 9 curies) for experiments at one of the national laboratories. That material has been returned to the licensee's inventory.
In the preparation of packages for shipment-the licensee is assured the packaging meets the required design and construction for the contents
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being shipped; that it is in good physical condition and that any s
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.. special instructions for loading the package have been followed by executing the packaging check off list, attachment 6, to Nuclear Material Management Section 4 of the control manual.
A review of the paperwork accompanying'a shipment of low level radioactive waste to a licensed land burial site on March 12, 1981 was reviewed.
The number of packages (78) as metal drums, radioactive naterial, LSA, nos were described with respect to their chemical and physical contents and total activity' contained in curies. The individual isotopes being shipped and their quantity in curies (grams in the case of uranium and thorium) were given. -The paper specified exclusive use apf vehicle requested along with instructions as to no loading or unloading or adding.or removal from the original consignment. The name of the shipper and the consignee were given and a further description of the shipment indicated fissile exempt.
Additional accompanying paperwork identified each of the 78. barrels by serial number, volu:re, weight, physical form of contents, chemical form of contents, radionuclides contained, amount of each nuclide, radiation levels at the surface of each container and at three feet, and transport group identification.
9.
Management Interview The scope and the results of this inspection were discussed with licensee management on July 30, 1981.
Those individuals were informed that no items of noncompliance or deviations from NRC requirements had been observed in the scope of the inspection.
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