ML20046D067

Insp Rept 70-0734/93-03 on 930621-25.Violations & Deviations Noted.Major Areas Inspected:Previous Insp Findings,Radiation Protection,Transportation of Radioactive Matls,Waste & Generator Requirements

ML20046D067
Person / Time
Site:	07000734
Issue date:	07/26/1993
From:	Brewer R, Cillis M, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20046D040	List: ML20046D039 ML20046D046 ML20046D049 ML20046D067
References
70-0734-93-03, 70-734-93-3, NUDOCS 9308160094
Download: ML20046D067 (13)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No.:

70-734/93-03 Docket No.:

70-734 License No.:

SNM-696 Licensee:

General Atomics (GA)

P. O. Box 85608 San Diego, California 92186-9784 Facility Name:

Torrey Pines Mesa and Sorrento Valley Sites Inspection at:

San Diego, California Inspection Conducted:

June 21-25, 1993 7

/

3 Inspectors:

Mike C'l'lis, Senior Radiation Specialist Date Signed h

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F 2 3 '7 3

' R. ' i r kl4rewer, R d' io Specialist Date Signed 7!1 f3 hd.

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Approved by: /JameC Reese' Chief'/

Ddte Signed

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s Va il' ties-Radiologic 61 Protection Branch 1

Summary:

Areas Inspected: This was a routine announced inspection of followup on previous inspection findings, radiation protection, transportation of radioactive materials, waste generator requirements, decontamination and decommissioning (D&D) activities conducted in the High Temperature Gas cooled (HTGR) fuel fabrication facility in Building 37 (SVA), and a tour of the licensee's facilities.

Inspection procedures 30703, 92701, 92702, 83822, 86740, 84850, and 83890 were addressed.

Results: Observations described in the report indicate a weakness in the licensee's management of their respiratory protection program.

One violation involving the f ailure to perform the monthly test and inspection of One deviation respiratory protection equipment is discussed in Section 3.f.

involving the licensee's failure to meet several committments involving the In other areas respiratory protection program are discussed in Section 2.a.

inspected, the licensee's programs appeared adequate and their programs appeared capable of accomplishing their safety objectives.

9308160094 930726

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PDR ADOCK 07000734 C

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DETAILS 1.

Persons Contacted

• R. N. Rademacher, Vice President, Human Resources

• K. E. Asmussen, Director, Licensing, Safety and Nuclear Compliance

• L. R. Quitana, Manager, Health Physics (HPM)

• M. Dolphin,- Manager, Nuclear Waste Processing Facility (NWPF)

• C. Wisham, Manager, Nuclear Materials Accountability

• J. Brock, Supervisor of Emergency Services P. R. Maschka, Health Physics Supervisor, Decommissioning Activities

• P. L. Warner', Project Manager, Decommissioning Activities

• Denotes those individuals attending the exit interview on June 25, 1993.

In addition to the individuals noted above, the inspectors met and held discussions with other members of the licensee's and contractor's staff's.

Followup - Open Items (92701) and Items of Noncompliance (92702) 2.

a.

Open Items 70-734/92-07-01 (Closed): This item involved the licensee's commitment to improve their respiratory protection program due to The inspectors verified the improvements to the NRC concerns.

licensee's respiratory protection program as specified in the commitments made in the licensee's November 20, 1992, letter to the NRC.

The licensee committed to having the improvements to the respiratory protection program completed by December 31, 1992,~

except for the database (i.e. item No. 5, below) which was to be The following commitments were completed by February 1,1993.

identified as either being completed significantly behind schedule or incomplete as of the date of this inspection.

1.

GA will assign Health Physics (HP) the responsibility for program oversight of the company's respiratory protection This effort will-be a closely coordinated effort program.

involving Health Physics, Industrial Safety / Industrial Hygiene, and Emergency Services (ES).

Current Status At the time of this inspection, HP had not assumed the f

responsibility for oversight of the respiratory protection j

The inspectors noted that communication between HP program.

and ES was minimal.

GA's Health Physics procedure HP-182, " General Atomics 2.

Respiratory Protection Program" was to be issued by December 23, 1992, as the " Top Level" procedure for the site respiratory protection program.

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Current Status

- Health Physics procedure HP-182 was issued four months late on March 23, 1993.

3.

Procedure HP-182 was to require that Emergency Services procedures that deal with respiratory protection be reviewed

- j and approved by the Manager, Health Physics (HPM) or designee.

Current Status Procedure HP-182 was issued as indicated above requiring-Emergency Services procedures that deal'with respiratory

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l protection be reviewed and approved by the Manager, Health -

Physics or designee. However,-as of June 25, 1993, ES 3

i procedures that deal with respiratory protection had not been reviewed or approved by the HPM. HP was not cognizant i

of ES's lack of progress in developing respiratory protection procedures for the Health Physics Manager's (HPM's) review until the inspectors identified the problem.

Additionally, the inspectors noted that the Emergency Services procedures were deficient in formal documentation indicating review and approval sign-offs and lacked any formal tracking mechanisms (i.e. procedure numbers, revision numbers, and dates).

4.

GA will shift all involved groups to an approved quantitative fit test method.

Current Status Procedure HP-182, the " Top Level" -procedure for GA's respiratory protection program allowed for both qualitative and quantitative fit test methods to be used.

Additionally, HP-182 failed to provide specific guidance as to the circumstances under which each fit test method was appropriate.

5.

The training, medical examination, fit test, and qualification records for the three groups' involved (i.e.

Health Physics, Industrial Safety / Industrial Hygiene, and l

Emergency Services) will be integrated into a database set up and maintained by Health Physics. The database will be set up such that each group will have their own entry forms and reports which will have password access control required for data modification.

Current Status Little progress had been made toward completing the qualified respirator user database as of June 21, 1993. By 4

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3 the end of this inspection, June 25, 1993, the licensee was in the process of putting together a spreadsheet to serve as the database.

The licensee acknowledged that the database swas incomplete in its current form and that more effort was required before it would meet the intent of the commitment specified in their letter (i.e. each group having their own entry form and reports, immediate access to the groups involved, and access control to prevent inadvertent data modification).

The licensee had made little progress toward completing the commitments specified in the licensee's letter. This is-considered a deviation from commitments to the NRC.

Item 70-734/92-07-01 is considered closed and future tracking will be by deviation 70-734/93-03-01.

70-734/92-07-03 (Closed): This item involved the licensee's actions to be taken to strengthen the Emergency Preparedness Program as specified in the licensee's letter dated November 20, 1992.

The inspectors verified that the licensee had reestablished a formal training program for Emergency Response and Recovery Directors (ERRDs) and their alternates as specified in the Radiological Contingency Plan (RCP).

ERT member training had been conducted on the dates indicated in the licensee's letter. The inspectors confirmed that a method had been established to ensure that the EIPs were reviewed and revised annually and that they were attached to the Work Authorizations (WAs) for the corresponding facility.

The. inspectors also noted that GA Form 1499, " Health Physics Check List," had been revised to include a line item to verify whether the facility EIPs (reviewed and approved by Emergency Services) were attached. This form was included as part of every new WA, as well as every annual WA renewal package and is reviewed by the HPM. All other improvements specified in the licensee's letter were verified by the inspectors as being complete with the ex eption of the licensee's data base for respirator user

'palifications.

However, the issue of the respirator user qualification data base will be followed using Deviation 70-734/93-03-01 (see above).

The licensee's improvements to their Emergency Preparedness Program have made a positive impact on that program.

This item is closed.

b.

Violations The inspectors verified the corrective actions taken to correct the violation and prevent recurrence as stated in the licensee's timely letter dated November 20, 1992.

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70-734/92-07-02 (Closed): This item involved the failure to review the emergency implementing procedures (EIPs) for Building 39 in 1990 and 1991.

The inspectors verified that the EIPs for Building 39 were reviewed, revised and submitted to GA's Supervisor of Emergency Services for review and approval. Training records of all ERRDs were examined for the class conducted on October 6,1992, which was held to emphasize the importance and requirement for ERRDs to annually review and revise as appropriate, the EIPs for their fac.lity.

GA Health Physics Procedure No.172, " Preparation and Issuance of a Work Authorization" was examined. The inspectors verified that the procedure had been revised to require that a current copy of the corresponding facility EIP be included with the Work Authorization (WA) when it is submitted for approval and that WAs are required to be renewed annually.

It was also verified that all EIPs be reviced and approved by the Supervisor of Emergency Services or his designee. The inspectors also noted that GA Form 1499, " Health Physics Check List", had been revised to include a line item asking whether the facility EIPs are attached and approved by the Supervisor of Emergency Services. This form is an attachment to GA Procedure No. 172 and is included as part of every new and renewal WA package. The inspectors noted that a formal + raining program, to be scheduled annually, had been established for the ERRDs and their alternates. This item is closed.

3.

Radiation Protection (83822)

The inspectors examined the licensee's radiation protection p*ogram for compliance with 10 CFR Parts 19 and 20, License Specifications, licensee procedures, and the SVA Decommissioning Plan.

The examination focused on radiation protection activities conducted by the licensee since the previous inspection (70-734/92-07).

a.

Changes The inspectors noted that the previous Manager, Nuclear Waste Processing Facility, had retired and the position was filled by an individual with adequate qualifications.

No other organizational or personnel changes were noted.

b.

Audits and Reviews The licensee's Criticality and Radiation Safety Committee's (CRSC) annual ALARA Review, dated August 21, 1992, for 1991 was examined.

Regarding Special Nuclear Material (SNM) activities, the report included a summary of the work areas reviewed, internal and external monitoring, air sample results and past activities. The

5 report delineated that of 631 urine samples analyzed for enriched uranium, 35 were above the minimum detection level (MDL) but well below 10 CFR Part 20.103 limits. The report reiterated the licensee's comm;tment-to keeping personnel exposures ALARA.

The licensee's CRSC annual HP Audit, dated May 18, 1993, was reviewed. No radiological discrepancies were identified by the audit. The audit appeared adequate in depth to identify rotential problem areas.

Reports of the Health Physics Manager's (HPM's). quarterly ~ safety inspections of HP activities since the last inspection were reviewed. The reports reviewed by the inspectors appeared to be of appropriate depth and scope. However, the program of conducting quarterly safety inspections did not appear to be effective in identifying the deviation and violation involving the respiratory protection program discussed in Section 2 and.in Section 3.f, below.

c.

External' Exposure Control Quarterly exchanged thermoluminescent dosimeters (TLD) vendor reports (vendor) for the previous two quarters were reviewed.

Personnel radiation exposures continue to be minimal due to limited licensee' activities. The inspectors verified that Form NRC 4's and 5's or equivalent were maintained for each individual in accordance with NRC requirements. The inspectors noted that no individual had exceeded the limits specified in 10 CFR 20.101(a).

Letters documenting ~ exposures for terminated employees pursuant to 10 CFR 19.13 had been expeditiously prepared and'sent to individual s.

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d.

Internal Exposure Control Air sample data for all facilities using SNM since the last inspection were reviewed. There were no indications of workers-being exposed to intakes of Radioactive Materials (RAM) which would exceed the 40-MPC-hour control measure requiring an evaluation pursuant to 10 CFR 20.103(b)(2). The air sample data indicated that workers exposures from airborne activity was being maintained ALARA.

The inspectors reviewed invivo lung counts (U-235) and urine The sample measurements of individuals since the last inspection.

inspectors noted that the lung counts were well below the licensee's investigation level of 100 micrograms U-235, and urine sample measurements were less than the contractors detection limit of about 0.9 picocuries uranium per liter.

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During facility tours the inspectors observed that air sample stations appeared to be sufficient in number and reasonably representative of the workers' breathing zone (s).

Engineering controls for loose contamination were evident.

Control of RAM and Contamination. Surveys. and Monitoring e.

During facility tours, the inspectors observed that adequate personn.el survey instruments were conveniently located at exits from contaminated areas. All instruments were observed to be functional and within their calibration period. Worker use of personnel survey instruments was observed to be adequate.

The inspectors noted that the licensee had purchased two Eberline model PCM-2 personnel contaminatior. monitors for use at the Hot Cell facility.

Routine and non-routine contamination surveys of radiologically controlled areas were examined.

Based on review of survey records, the inspectors verified that the licensee's radiation and contamination survey program was consistent with Section 4.0 of the License, commitments outlined in the SVA Decommissioning Plan and the requirements specified in 10 CFR 20.201.

Work Authorizations and Radiation Work Procedures (RWPs) were 4

reviewed for adequacy. The WAs and RWPs reviewed provided adequate worker instructions.

RWPs were signed by the workers to acknowledge their understanding of the requirements. During facility tours, workers were observed complying with the conditions specified in the applicable RWPs.

The inspottors noted that radioactive materials and radiation areas were posted in accordance with the requirements of 10 CFR 20.203.

f.

Respiratory Protection i

An examination of the licensee's respiratory protection program was performed during this inspection for the purpose of determining compliance with License Specifications, implementing procedures, 10 CFR 20.103(c)(2), and with the NRC approved Radiological Contingency Plan, dated October 1990.

The examination included inspector observations, discussions held with members of the licensee's staff, and a review of the following documents:

Procedure HP-182, " General Atomics Respiratory Protection Program," dated March 1993.

Procedure HP-303, " Respiratory Protectior Program," for the e

joint GA/BNI SVA D&D project, dated June 1992.

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7 Emergency Services, Respiratory Protection Procedures.

Various respirator users lists:

e The users lists contained such information as the training status of respirator users, dates of medical examinations, dates of fit tests and associated results, type of respirator users are qualified to use, and the qualification dates of the respirator users.

The inspectors' review focused on the verification of respiratory protection program improvements discussed in Section 2.a. above.

The inspectors noted that the licensee was in the process of bringing the Health Physics, Emergency Services, and Industrial Hygiene respiratory protection programs under the cognizance of the Health Physics organization as directed by GA HP procedure HP-182.

During facility tours, the inspectors noted that four emergency use self contained breathing apparatus (SCBA) respirators at the TRIGA fuel fabrication facility were not stored in accordance with procedure HP-182 and were in a degraded condition.

Face pieces were not stored in sealed bags to prevent oxidation and dust collection.

Visibility through the face pieces was impaired due to dust and dirt. The face pieces were loaded with specks of dirt which could have affected the operability of the units if a speck of dirt got into a regulator.

In addition, the hoses and fittings were cracked and brittle. The. inspectors also identified two emergency use SCBA respirators at Building 37 which were in a degraded condition and their monthly check had not been performed for the month of May 1993, as required by licensee proctdures.

Regarding non-emergency use respirators, the inspector fcand similar maintenance and storage problems. At the SVA facility, the inspectors noted two bags of respirators where each bag contained approximately 15 respirators. At the Waste Yard (Building 41), the inspectors observed a 55 gallon drum stacked full of respirators. The improper storage of respirators as described can permanently damage the respirator sealing surfaces thus making a proper respirator fit impossible.

The inspectors noted that procedure HP-182 did not adequately address maintenance and storage practices in that it provided little guidance regarding storage to prevent the types of problems identified above and it provided no guidance regarding what to if such degraded respirator conditions were identified.

The inspectors identified an instance, which occurred during the week of June 14-18, 1993, in which a HP technician at Building 41 issued an individual a respirator without first verifying that the individual was a qualified respirator users.

In fact, Building 41-

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8 personnel did not have immediate access to a list of qualified respirator users.

It was only learned after the fact, by the NRC inspector, that the individual was a qualified respirator user.

This was the only respirator issues at Building 41' at that time.

The inspectors discussed these findings with the licensee immediately upon identification and later at the exit interview.

The inspectors emphasized the importance of proper maintenance and storage to ensure safe operation of respirators (i.e. good scaling surf ace's, respirator integrity, proper performance of valve bodies, etc.) when needed.

The inspectors noted the failure to perform the monthly inspection of emergency use SCBA respirators at Building 37.as a violation of licensee procedures (70-734/93-03-02).

The licensee's performance in the area of radiation protection appeared adequate and their program appeared capable of accomplishing its objectives. One violation vas identified as discussed in Section 3.f.

above.

4.

Transportation of Radioactive Materials (86740) and Waste Generator Requirements (84850)

The inspectors examined the licensee's radioactive materials transportation program for compliance with 10 CFR Parts 20, 30, 71, and naprtment of Transportation Regulations (DOT), 49 CFR Parts 171 through 178. The examination included a review of the licensee's radioactive waste program for compliance with 10 CFR Parts 20 and 61. The examination also included a review of the following licensee procedures:

HP-1, " Receipt, Pickup and Opening of Packages Containing Radioactive Materials," dated March 1989.

NMA-4, " Shipment of Radioactive Material," dated September 1992.

NMA-5, " Receiving Radioactive Material," dated October 1989.

e NMA-8, " Transport of Radioactive Material," dated October 1991.

e Transportation of Radioactive Materials a.

Records of ten shipments and receipts of SNM for the period of October 1992 through June 1993, were reviewed.

Based on the review, the inspector determined that the receipts and shipments of SNM were accomplished in accordance with the regulatory requirements referenced above. Copies of current DOT regulations, Burial Site license requirements, and shipping package certifications were maintained by the licensee's staff.

The licensee also maintained documentation to certify recipients were authorized to receive the radioactive material shipped to them as

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required by 10 CFR 30.41 (c). The inspectors noted that the receipt and opening of packages was accomplished in accordance with-licensee procedures and 10 CFR 20.205.

The examination disclosed that the licensee had not experienced.

any transportation incidents that would require reporting since

'i the previous inspection in this area.

The licensee's performance in this area appeared adequate, and their p'rogram appeared capable of accomplishing its objectives.

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b.

Waste Generator Reauirements The inspector examined the licensee's radioactive waste program for compliance with 10 CFR Parts 20 and 61. The inspection included a tour of the licensee's nuclear waste processing l

facility (NWPF) and waste storage areas.

The inspectors noted that the solidification and filtration area had been enclosed since the previous inspection.

Liquid and slurry wastes are solidified in this area.

Some liquid wastes are-also filtered in this area prior to discharge to the sanitary sewer.

Discussions with the licensee's staff disclosed that the Department of Energy (DOE) has agreed to accept all of the radioactive wastes containing SNM which has been generated as a result of the D&D activities associated with Building 37. The only D&D waste shipments made to date have been to the Nevada Test.

Site (NTS). To date the licensee had made 5 shipments of 50 to 55 boxes each to the NTS for a total of 650 boxes. The licensee is in the process of obtaining approval-to ship bulk D&D solid waste to DOE Hanford.

The examination included a review of applicable licensee-procedures used for ensuring compliance with the waste classifications and characteristics required of-10 CFR 61.55 and l

61.56.

Based on discussions with the licensee's staff and j

observations made during facility tours, the inspector concluded that the licensee's activities in this area were consistent with 10 CFR Part 61. The inspector also concluded that waste manifests and marking of wastes shipped since the previous inspection had been accomplished in accordance with 10 CFR 20.311.

Inspections.

of waste handling and packaging observed during this inspection l

were determined to be in accordance with 20.311 (d)(3).

r The licensee's performance in this area appeared adequate and 1

their program appeared capable of accomplishing its objectives.

No violations or deviations were identified.

10 5.

Decommissioning and Decontamination (83890)

The licensee has been conducting decontamination and decommissioning (D&D) work in the SVA Building 37 for approximately the last two years.

Region V Inspection Report 70-734/93-02 identified that Phase I of the D&D activities were completed on May 12, 1993, and that the NRC and-State of California authorized General Atomics to proceed with the dismantlement, e.g., Phase II, of the superstructure of the SVA The NRC authorization required health physics coverage during facility.

removal of-tiie drain lines and concrete floor and also required GA to submit a soil sampling and remediation plan for NRC approval prior to proceeding into the final phase of D&D activities.

An examination was conducted during this inspection to determine the status of the dismantlement of the SVA Building 37.

The inspection consisted of a review of radiation and contamination reports, observations, independent measurements, discussions with the licensee's staff, and a tour of Building 37.

Independent surveys of clean trash and concrete rubble generated from dismantlement activities were performed during the inspection using a Ludlum Model 3 Survey Meter Serial No. 022879, with a pancake probe, Geiger-muller (GM) tube, and scintillation probe, due for calibration on 19, 1993.

Background dose rate measurements were taken in November unaffected location and adjacent to Building 37 prior to performing the The background count rate for the pancake probe was 50 cpm, survey.

<0.2 mr/hr for the GM tube (open window and closed window), and 250 cpm with the scintillation probe. The review disclosed that copies of the dismantlement schedule had been provided to the State of California and to the NRC during the performance of this inspection.

The examination of dismantlement activities disclosed follows:

The dismantlement operation was proceeding as schedule. The a.

contaminated Machine Shop had been dismantled,_except for.the floor, drains, and outer steel support structure (e.g., I-Beams).

The material removed from this portion of the dismantlement project had been package as radioactive waste for subsequent disposal to an approved Department of Energy (00E) site.

The HEPA filtered exhaust system had been removed from top of b.

Building 37.

The asbestos abatement project on Building 37's roof top was c.

nearing completion. The work was expected to be completed by June-18, 1993.

Approximately 95% of the West Vault had been demolished and most d.

of the concrete debris had been taken to the clean land fill for disposal.

Portions of the Vault's roof top were in a dumpster awaiting transfer to the clean land fill.

All measurements were at background levels during the performance of the direct radiation survey.

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Dismantlement of Building 37's North Annex was in progress during e.

the. inspection.

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The West HEPA shed had been dismantled except for the floor and j

drains.

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The development of a soil sampling and remediation plan.was in the process of being developed.

The inspector noted that the dismantlement crew were conducting meetings r

twice daily to discuss the~ schedule and radiological control requirements for dismantlement activities.

The inspection revealed that the dismantlement work force consisted of. a labor force of 20 and a Health Physics (HP) staff of 15.

Most of the labor force and HP staff were returnee's who worked on D&D activities during Phase I.

Both the labor force and HP staff had been trained in accordance with the Decommissioning Plan and other licensee commitments.

All work observed appeared to be consistent with the Radiation Work Permits (RWPs) that were established for the dismantlement phase. The inspectors noted that-HP staff were performing pre and post dismantlement radiation and contamination surveys.

No abnormal l

radiation or contamination levels have been reported up to this stage of i

the dismantlement operation.

The review of radiation, contamination, and air sampling survey records did not disclose any abnormal results.

Airborne concentrations for I

alpha and beta-gamma were well below the limits provided in 10 CFR Part 20, Appendix B.

The inspectors noted that results of contamination surveys performed for the release of material-associated with D&D activities were being reported as less than the release limits provided in Table 1 of Regulatory Guide 1.86, as opposed to the actual' values that were measured. The HP D&D supervisor in most.all cases the actual vales were at or less than the established Minimum Detectable Activity (MDA) values. The MDA values were a just a small fraction 'of the values provided in RG 1.86, Table 1.

This observation was discussed at the with HP D&D supervisor and licensee staff attending the exit interview.

The licensee informed the inspectors that the D&D HP staff had been instructed to report actual values for all surveys.

1 The li'ensee's performance in this area appeared adequate and their c

program seemed capable of accomplishing its safety objectives.

No violations or deviations were identified.

6.

Exit Interview (30703)

The inspectors met with the licensee representatives, denoted in Section 1, at the conclusion of the inspection on June 25, 1993. The scope and findings of the inspection were summarized. The licensee was informed of the deviation discussed in Section 2.a and the violation discussed in Section 3.f.

4 12 The Vice President of Human Resources acknowledged the inspectors findings by~ stating that immediate corrective actions would be taken to correct the'. findings.

30, 1993, from the A three page FAX message was received on Junelicensee provid been taken or those planned with regards towards improving the respiratory protection program.

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