ML20128C391

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 70-0734/92-07

ML20128C391
Person / Time
Site:	07000734
Issue date:	11/20/1992
From:	Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Rademacher R GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
References
NUDOCS 9212040382
Download: ML20128C391 (2)

Text

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\..... WALNUT CMEEM.CADFORN!A A'46-$368 NOV 2 01892 Docket No.70-734 General. Atomics P. O. Box 85608 San Diego, California 92138 Attention: Mr. R. M. Rademacher, Vice President Human Resources Thank you for your letter dated November 12, 1992, in response to our Notice of Violation (Notice) and Inspection Report 70-734/92-07, informing us of the steps you have taken to correct the items we brought to your attention.

Your corrective actions appear-to resolve our concerns regarding the violation and the other concerns with your emergency preparedness and respiratory protection programs referenced in the inspection report. Your corrective actions will be reviewed during a future inspection.

Your cooperation with us is appreciated.

l Sincerely, j'

Robert J. Pate, Chief Safeguards, Emergency Preparedness, and Non-Power Reactor. Branch cc:

Dr. Keith E. Asmussen, Manager Licensing, Safety and Nuclear Compliance 1.

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. NOV 2 01992 '

Docket No.70-734 General Atomics 4 P. O. Box 85608 '

San Diego, California 92138 Attention: Mr. R. M. Rademacher, Vice President fluman Resources

.l Thank you for your letter dated November -12,1992, in response to our Notice of Violation (Notice) and Inspection Report 70-734/92-07, informing us of the steps you have taken to correct the items we' brought to-your attention.

Your corrective actions appear to resolve our concerns regarding the violation and the other concerns with your emergency preparedness and respiratory protection programs referenced in the inspection report.- Your corrective actions will be reviewed during a' future inspection, Your uoperation with us is appreciated.

Sincerely, R'obert J, Pate, Chief' Safeguards Emergency Preparedness,. ,

and Non-Power Reactor. Branch. .

cc:

Dr. Keith E. Asmussen, Manager Licensing,. Safety and Nuclear Compliance bcc w/ copy of letter dated November 12, 1992:

Docket F'.ie Inspection file G. Cook R. Iluey B, Faulkenberry

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State of Caiifornia J.=Zolliceffer bec w/o copy of letter dated November 12, 1992:

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U.S. Nuclear Regulatory Commission ATTN Documer.t Control Dask Washington, D.C. 20555  !

Subject:

Docket No. 70 734; License No. SNM 696: Reply to a Notice of Violation

Reference:

Pate, Robert J., Letter to General Atomics, ATTN: Mr. R.N. Rademacher,

" Notice of Violation /NRC Inspection Report No. 70 734/92-07," dated October 13,1992 l l

Gentlemen:

Enclosed (Attachment 1) is General Atomics' (GA's) response to the Notice of Violation issued on October 13,1992 (Reference). This response was prepared pursuant to the provisions of 10 CFR 2.201.

Also enclosed (as Attachment 2) is GA's response regarding actions taken, or to be taken, to improve and strengthen its respiratory protection and emergency preparedness programs.

GA trusts you will find its corrective action , measures to be appropriate and satisfactory. If you should have any questions concerning this response, please contact me at (619) 455-2823. >

Very truly yours,

. M' ' ML Keith E. Asmussen, Director Licensing, Safety, and Nuclear Compliance KEA:shs Enclosures - as above cc: MrgM;@illik U.S. NRC Region V Ms. Merri Horn, U.S. NRC Headquarters Mr. John B. Martin, Regional Administrator, U.S. NRC Region V j Mr. Robert J. Pate, U.S. NRC Region V

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Attachment 1 to General Atomics

• t.atter No. 896-1983-Deted November 12,1992- I General Atomics' Response to the Notice of Violation / NRC Inspection Report No. 70-734/92-07

' During a routine inspection of General Atomics' NRC-licensed activ'ities, whi_ch was conducted on August 24-26,1992, one violation of NRC requirements was identified.

The violation is restated below followed by General Atomics' (GA's) response.

VIOLATION:

Condition 9 of License No. SNM 696 authorizes, in part, the use of licensed materials in accordance with the statements, representations, and conditions contained in Part II, " License Specifications._ " dated July 24,1981, and supplements to the license-application dated March 16,1992 through June 24,1992.

Section 8.1 of Part 11 of the License Specifications requires the licensee to develop and implement plans and procednres for coping with emergencies.

Section 10.4 of the NRC approved " Radiological Contingency Plan," dated October.

1990, states in part: "The ERRDs (Emergency Response and recovery Directors) are -

responsible for an annual review of their facility's implementing procedure."

Contracy to the above, Building 39's emergency implementing procedures had not been reviewed by an ERRD in-1990 and 1991.

-This is a Severity Level IV violation (Supplement IV)-

GA's RESPONSE:

1. Reason for the Violation:

GA believes the reasons for this violation to be the.following:

-1) Personnel not adhering to the requirements stated in GA's NRC approved Radiological Contingency Plan,

2) Failure to effectively. and clearly communicate to GA's Emergency n response and Recovery Directors (ERRDs) the' significance and. import-E ance of adhering to the rt;uirement to review the' emergency plan i implementing procedures for their facilities on an annual basis.-

3) Failure to recognize that the emerger,cy implementating procedures for -

Building 39 had not been reviewed and revised as required.

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? Attachment 1 O General Atomics' Letter No. 8961983 Deted 11/12/92 -

Pope 2 of 2

2. C_orrective Steos taken and Results Achieve.d:

1) The emergency plan implementing procedures for Building 39 were reviewed, revised and submitted to GA's = Supervisor.'of Emergency _

Services for review and approval. The revised implementing procedures were approved by the Supervisor of Emergency Services and were sub-sequentlyincorporatedintothecorrespondingWork Authorization,which itself was approved on November 10,1992,

2) A training class for all ERRDs and alternate ERRDs was held on October.

s 6, 1992. This class included - emphasis on the importance and requirement for ERRDs to annually review, and revise as appropriate, the emergency implementing procedures for their facility.

3) It is now required that all emergency plan implementing procedures be:

reviewed and approved by the Supervisor of Emergency Services or his designee. ~

4) GA Health Physics Procedure No,172 " Preparation and issuance of a Work Authorization" has been revised to require that a current copy of the corresponding facility omorgency implementing procedure be included with the Work Authorization (WA) when it is submitted for approval.

(WA's must be renewed annually).

5) G A Form 1499, " Health Physics Check List," has been revised to include a line item asking whether the " Facility Emergency Procedures (reviewed :

and. approved by Emergency Services) ato attached." This form is included as a part of every new WA and annual WA renewal package.

3. -- Corective Actions that will be Taken to Avoid Further Violations:

1 Please see Steps 2 through 5 disc _ussed above._ Additionally, a formal trainin0-program has been reestablished for the ERRDs and their alternates. Training classes wili be scheduled annually.

4._ pate VV_hnComollancelwill he Achland:-

GA is currently in compliance.

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/ Attachment 2 to Conwel At:mics' i

• -Letter No. 696 1983 j ,

Deted Noyomber 12.1992 General Atomics' Response Regarding Actions for improving Management Oversight of Respiratory Protection Program and Emergency Contingency Plan During a routine inspection of General Atomics' (GA's) NRC licensed activities which was conducted on August 24 26,1992, weaknesses were observed in GA's respira-tory protection and emergency preparedness programs. These were described in NRC Inspection Report No. 70-734/92 07 dated October 13,1992. The actions GA has taken, or plans to take, to improve and strengthen each of these proDrams are stated below.  !

Actions to Stronathen Resolrator Protection Proaram:

Given below is GA's response regarding respiratory program weaknesses described In Section 2.1, items i through lx, of NRC Inspection Report No. 70-734/92 07. The .!

single rnost important change being implemented by GA is to assign to a single  ;

organization, i.e., Health Physics, the responsioliity for program oversight of the i company's respiratory pmtection program. Administration of GA's respiratory protection program will be a closely coordinated effort involving Health Physics, industrial Safety and Emergency Services. Accordingly, the " top level" procedure for GA's respiratory protection program will be a joint procedure which will be reviewed and approved by Health Physics, Industrial Safety (Industrial Hygiene) and Emergency.

Services. Other subordinate respiratory protection piogram procedures -will be-consistent with this " top level" procedure, items i through lx from Section 2.1 of th_e subject inspection report are listed below.

Following each restatement of items i through ix is GA's corresponding tesponse, ,

i)

Procedure HP 182 was in the_ process of being developed as a replace-ment for Procedure HP-48. The licensee's staff felt that Procedure HP 48 was too generic. The inspector concurred with this observation.

GA's Response to item i): 1 GA's Health Physics Procedure HP-182_will replace HP-48, which is too  !

generic. The scope of HP-182 will be increased to make it the " top 1 level" procedure for GA's respiratory program while GA continues to evaluate the situation so as to determine the most effective procedural approach. Due to the increase in scope of this procedure and interfacing with in_dustrial Safety / Industrial Hygiene and Emergency Services, the procedure will need to be revised further to incorporate additional information. GA expects to issue a revised procedure, HP-182, by December 23,1992, i

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ ~ - - - ~ - - - - - - ~ ~ - ~ ~ - ~ ~ ~ ~ ~

' Attachment 2 to General Atomics' l.etter No. 6961983 Deted 10/12/92 s Page 2 of 6 li) Procedures used by the SES for training SCBA users had not been reviewed by the radiation protection group for compliance with the license conditions referenced above.

GA's ?asponse to item 11):

HP-182 will require that the Emergency Services procedures that deal with respiratory protection be reviewed and approved by the Manager, Health Physics or designee.

iii) Two differont methods were used to accomplish respirator the fit tests recommended by NUREG 0041 The fit test of SCBA users, performed by the SES is a basic qualitative fit test by exposing the user to a u

cha engir,g atmosphere around the face mask. The hralth physics fit test consists of both a qualitative and quantitative fit test, using the latest state of the art fit test equipment. '

GA's Response to item lii):

General Atomics presently uses the two approved methods for fit testing  !

from NUREG-0041 for different area programs. The industrial Hygienist and Emergency Services use a qualitative fit test and Health Physics uses both qualitative and quantitative fit tests. With the restructuring of the respiratory program and closer contact of the groups involved there will an effort made to shift all groups to a quantitative fit test. ,

iv) The training provided by the SES for SCBA users did not include a  ;

written examinatien at the conclusion of the training period; whereas,  !

the training provided by the health physics staff is concluded with an approximate tivo hour written examination.-

GA's Response to item Iv):

The Emergency Services training on Self Contained Breathing Apparatus (SCBA) will be reviewed, and revised if appropriate, and approved by the Manager, Health Physics or designee. The training willinclude classroom training and an exam,-a practical factors session with a sign off sheet -

and appropriate fit testing with the appropriate documentation, v) The instructions provided to the respirator users by the SES's training program disallows the growing of beards; whereas, the train;ng provided by the health physics group does permit users to grow a beard if the individual maintains shaving equipment readily available. The inspector saw two qualified respiratory users at the SVA project with beards. One-

' Attachment 2 to General Atomics' Letter No. 6961983 Datad 10/12/92

,. Page 3 of 6 of the individuals did maintain shaving equipment in his desk while the other individual stated he had shaving equipment in his automobile.

GA's Responsa to item v):

Personnel who have beards and/or any facial hair that interferes with a mask seal will not be quallfled for wearing respiratory protection. Any oerson who is an emergency response team member must be clean shaven. (Personnel who use respiratory equipment on a non emergency basis may have beards but will not be issued respiratory equipment or fit tested until they have snaved.)

vi) The inspector could not readily deterrnine if the training, respiratory fit-tests, and respirator medice' were current. Nor could it be readily determined the types of respiratory equipment that individuals were qualified to use. The records previded to the inspector were unclear. -

poorly organized, and had conflicting data.

GA's Response to item vil:

The training records for the three groups luolved,i.e., Health Physics, industrial Safety / industrial Hygiene and 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.

vii) GA's Emergency Services department procedure does not addiess all of the recommendations of Regulation Guide (RG) 8.15, " Acceptable Programs for Respiratory Protection."

GA's Response to item vii):

Emergency Services' respiratory protection procedures will be m com-pliance after the procedures are revised, reviewed and approved. Health -

Physics will be an integral part of the review ond approval process for >

these procedures.

viii) Discussions with the SES disclosed t;. . ..a was not aware of 10 CFR 20.103 requirements, the recommendations provided~in RG 9.15 and NUREG 0041, or the conditions contained in Part ll of the license,

Attachment 2 to(DenerC) Atomics' Letter No. 6961983 Dated 10/12192

, , Pogs 4 of 6 GA's Rosponse to item vill:

The Supervisor, Emergency Services and his rJtornato have boon given copios of 10 CFR 20.103, Ro0ulatory Guido 8.15, NUREG 0041 and the rospiratory section frorn Part 11 of the licenso. Health Physics will conduct a documented trainin0 session with the supervisor and alternate (s) by December 23,1992.

ix) The training records maintained by both the Emergency Services department and the Health Physics Group woro poorly organlrod and contained conflicting data.

GA's Hosponse to item v): .

The database Health Physics is Doing to use will allow records (l.a.

medical documents etc.) to bo scanned into the database for easy retrieval. The master filos will be kept in Health Physics. The database will be sat up to allow reports to be generated to notify personnel of upcomin0 training and/or medical requirements that are necessary for them to mainte!n their qualifications.

All actions except for the database will be in place by Decomtwr 2% 192 which will Dive General Atomics a stron0 respiratory protection pmram. it will_ be further stron0thoned by the database which Health Physics is strWn? to have ir, place by February 1,1992. This is an estimato subject to chan00 No to uncertaintler associated with the availability of the hardware, software and pio0rammin Jirati to set up the system.

littl0DLlQ Ittf DD1hA!LEtnn10ROCLEffDMaduMLEt0DUISU Given below is GA's response regarding stops taken to strengthen its omorgency pro-paredness pro 0 ram. The response lncludes a description of the actions GA has taken, and those it plans to take, to address the concerns raised in Section 5.0 of NRC inspection Report No. 70 734/92 07.

First, it. should be noted that a number of the actions described -above for strengthenin0 GA's respiratory protection progran; will also work to improve its emer00ncy preparedness pro 0 ram. In particular, the integrated database (soo abovo items vi and ix) that will be set up and maintained by Health Physics should result in much improved recordkoopin0. It will also be useful in generating remindors of scheduled training, etc.

Other actions GA has taken, or plans to take, to improve and strengthen its emergency preparedner.s program include:

l '

., Attachment 2 to General Atomics' Letter N). 8961983 Dated 10/12/93

,,, , Page 5 of 6

1) Heestablishment by the Emergency Coordinator (EC) of a formal training program for Emergency riaspcnse and Recovery Directors (ERRDs) and their altern6tes.

This training pro 0 ram w!Il also extend to other key emergency personnel such es: alternate emergency coordinators, the managers of Nuclear Safety, Industrial Safety and Nucleer Material Accountability, the Chair-man of the Criticality and Radiation Safety Committee and the Director of Facilities or his designee.

2) It is presently required that till emergency plan Implementing procedures be reviewed and approved by the Supervisor of Emergency Services, or his designee. The ERRDs have been advised of this requirement,includ-Ing the need to have the review and approval denoted by Emergency Services'siun off (approval).

3) G A's Emerooney Coordinator (EC) has been reminded of the importance and significance of his responsibility to assure that the emergency plan implementing procedures for each facility are reviewed and revised, as needed, annually.

4) As an added administrative control to assure that each facility has its emergency plan implementing procedures (EPIP) teviewed annually, G A's Health Physics Procedure, HP 172, " Preparation and issuance of a Work Authorization," has been revised to require that a current (up to date) copy of the corresponding facility EPIP be included with the Work Authorization (WA) when it is submitted to Health Physics for renewal annually.

5) G A Form 1499, " Health Physics Check list," has been revised to include a line item asking whether the " Facility Emer0ency Procedures (reviewed and approved by Emergency Services) are attached." This form is included as a part of every new WA, as well as every annual WA renewal packa00.

6) G A's Supervisor of Emergency Services and the Emergency Coordins'or have been instructed to raise to the Director, Licensin0, Safety and Nuclear Compilance's attention,in a timely manner, any problems related to implementation of GA's Radiological Contingency Plan.

7) In the past, most of the emergency preparedness training has been provided by the Supervisor of Emergency Services. A qualified emer0ency services technician has now been dele 0ated responsibility for much of this trainin0. This action is intended to allow the Supervisor of d

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'* Attachment 2 to Gorietal Atomics' Letter No,6961983 Deted 10/12/92 '

Page 6 of 6 Emergency Services more time to provide oversight to the implementa-tion of the RadioloD i cal Contingency Plan.

8) With regard to concerns specific to GA's Building 39, several specific actions have been taken, or have occurred:

a) the emergency implementing procedures were revised, and then reviewed and approved by Emergency Services; b) all emergency response team members were trained; c) there is now a now PrincipalInvestl0ator; ano, d) there is now a new ERAD.

9) Other specific actions taken in support of implementing the GA Radioloolcal Contingency Plan include the following:

a) a training class for ERRD, alternate ERRDs and other key -

emergency plan personnel was held on October 6,1992; b) Emer0ency response team Member trainin0 was conducted as-follows:

1) CPR and First Aid on 9/8/92,10/8/92 and 10/20/92;

11) Fife ExtinDuishers and evacuation procedures on 9/14/92, 10/8/92 and 10/29/92; ill) Self contained breathing apparatus on 9/29/92, 10/7/92 and 10/29/92.

NOTE: Emergency Response Team Training will continue until all -

training for all members is completed. This is expected to be accomplished by December 23,1992, c) Health Physics technicians are in the process of being qualified in the use of Self Contained Breathing Apparatus. This will be done on an annual basis.