ML20133E416
| ML20133E416 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 01/07/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133E403 | List: |
| References | |
| 70-0734-96-04, 70-734-96-4, NUDOCS 9701130034 | |
| Download: ML20133E416 (12) | |
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l ENCLOSURE l
l U.S. NUCLEAR REGULATORY COMMISSION l
REGION IV Docket No.:
70-734 License No.:
SNM-696 l
Report No.:
70 734/96-04 Licensee:
General Atomics (GA)
Facility:
Torrey Pines Mesa and Sorrento Valley Sites Location:
San Diego, California Dates:
December 9-13,1996 Inspectors:
C. A. Hooker, Senior Fuel Facility Inspector H. D. Chaney, Fuel Facility / Decommissioning Inspector Approved By:
Frank A. Wenslawski, Chief j
Materials Branch
Attachment:
Supplemental inspection Information 9701130034 970107 PDR ADOCK 07000734 C
1 4
4 EXECUTIVE
SUMMARY
General Atomics NRC Inspection Report 70-734/96-04 This inspection included a review of activities related to the possession-only license (POL),
decommissioning activities, management organization and controls, radiation safety, operator training and qualification, and followup items.
Manaaement Oraanization and Controls The licensee's management controls and staffing appeared adequate for current licensed activities (Section 1).
The licensee's self assessments appeared effective in ider,tifying and correcting deficiencies (Section 1).
i The licensee appropriately initiated an investigation to evaluate exposures to members of the public dua to state licensed materials at Building 25 (Section 2.1).
Radiation Protection The licensee was adequately controlling and evaluating workers external and internal exposures (Section 2.1).
The licensee was adequately controlling radioactive materials and contamination levels related to ongoing activities and radiation exposures were being maintained ALARA (Section 2.2).
Operator Trainina and Qualification Personnel were adequately trained and qualified for their assigned tasks (Section 3).
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l Report Details i
l Summarv of Facility Status i
l All production and research activities involving the use of special nuclear material (SNM) have been discontinued, consistent with the licensee's request (letter dated September 26, 1995) for a POL amendment and notification of cessation of principal activities. By letter dated May 1,1996, the NRC provided an interim approval of the "GA Hot Cell Facility l
Decommissioning Plan," dated July 6,1995, and supplement thereto. By letter dated September 30,1996, the licensee submitted a Site Decommissioning Plan. By letter dated l
September 26,1996, the NRC approved the licensee's request for a POL and subsequent amendments to Sections 1-3 and 5-8, Part 11 of the license application. By letter dated l
October 15,1996, the licensee submitted an amendment to Section 4, " Radiological Safety," Part ll of the license.
Current licensed activities consisted of decontamination and decommissioning (D&D) of the l
Building 23 Hot Cell Facility (HCF). There were no ongoing activities in the TRIGA Fuel l
Fabrication Facility (TFFF). Remaining TRIGA fuel was being stored in the TFFF vault l
awaiting final disposition. At Building 39 (SVB) in Sorrento Valley, the licensee was identifying and removing equipment for either disposal or disposition to the Department of Energy (DOE) and/or other tentative destinations in preparation for final facility characterization and upcoming D&D activities. The SVB facility, including its respective waste storage area, was limited on the POL to 350 grams of U-235. The current inventory was less than 280 grams U 235. The majority of the U-235 was contained in gamma counting standards. Regarding Building 2, Science Laboratory Building, the licensee had plans to request from the State of California and the NRC the release of 33 laboratories for unrestricted use in early 1997.
1 Management, Organization and Controls a.
Insoection Scoce (88104. 88005 and 83822)
The inspectors reviewed and discussed current organization and staffing with licensee personnel. Records of quarterly health physics (HP) audits / inspections for the past year, and the licensee's 1996 annual Criticality and Radiation Safety Committee (CRSC) audits of the HP and riuclear safety programs were reviewed and discussed with licensee personnel. The inspectors also reviewed work authorizations and selected associated operating procedures for each major licensed
- facility, i
b.
Observations and Findings The inspectors noted that there had been no recent changes in the organizational structure or staffing. Although significant personnel cutbacks had taken place l
during the past year, the licensee has maintained sufficient qualified staff to ensure
l i implementation of its current license commitments. The licensee's management organizational structure was consistent with Figure ll 3.1-1, Part 11 of the license.
l The CRSC audits were conducted during March through May 1996. The audits j
included an evaluation of the HP and nuclear safety programs, and related site l
operational activities (POL status, D&D at the hot cell facility, and preparation for l
D&D at other facilities). Quarterly HP audits / inspections adequately evaluated j
activities. There were no significa'it safety concerns identified by the licensee's l
audits. Corrective actions for licensee identified deficiencies appeared adequate.
The audits were consistent with Section 3.6, " Internal Inspection and Audits,"
Part 11 of the license. In addition to the license specified audits, the HP department was also in the process of performing its annual review of the radiation protection program as required by 10 CFR 20.1101(c).
The inspectors noted that work authorizations were current and the associated operating procedures had been revised to reflect current operations at each facility.
l The procedures were well written and provided adequate instructions to facility l
personnel. The procedures also adequately addressed criticality safety requirements for removal, assembly, and storage of equipment. The licensee also maintained procedures that adequately incorporated the provisions of Annex C, " Guidelines for Decontamination of Facilities and Equipment Prior to the Release for Unrestricted l
Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material,"
Part ll of the license, dated April 1993. The inspectors noted some minor editorial errors concerning release limits and survey methodology in a summary guidance I
posted at SVB which were provided to the HP Manager. These errors wers subsequently corrected.
c.
Conclusion The inspectors concluded that the licensee's management controls and staffmg appeared adequate for providing oversight of D&D and other licensed activities.
The licensee's audit program appeared effective in identifying and correcting program deficiencies.
2 Radiation Protection l
2.1 External and Internal Exoosure Control a.
Inspection Scoce (88104 and 83822) l The inspectors discussed external and internal exposure controls with licensee l
personnel, and toured licensee facilities to observe ongoing activities. The i
inspectors reviewed selected records of air sampling data for the past 6 months and l
quarterly vendor thermoluminescent dosimeter (TLDs) results from January 1 l
through October 31,1996. The inspectors also reviewed a licensee evaluation of a l
significant non-conservative discrepancy between the licensee's electronic l
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. l dosimeter exposure tracking data and quarterly vendor TLD results for several workers at the HCF.
b.
Observations and Findinos l
Due to reduced site activities during the past 2 years, internal and external exposures have been minimal. The licensee's evaluations have determined that l
without the use of respiratory protection, workers are unlikely to receive intakes of l
radioactive materials from routine operations that would exceed 10 percent of the l
applicable annual limit of intake specified in Appendix B of 10 CFR Part 20.
l Therefore, a committed effective dose equivalent is not included in the total effective dose equivalent. The licensee's air sampling data supported this determination.
i Air sample data for combined NRC and state licensed materialindicated that I
airborne radioactive materials were normally less than 10 percent of the applicable limits listed in 10 CFR 20, Appendix B, Table 1, Column 3. During clean out of the metallography cell at the HCF, the licensee measured its highest airbome l
concentration of approximately 51 derived air concentrations (DACs). The 51 DACs l
included 46 DACs of alpha activity (based on Pu-239) and 5 DACs of beta activity I
(based on Sr 90). Typically, airborne concentrations are less than 10 percent of the l
respective DAC for alpha and beta activity. The highest accumulative internal exposure for any one individual was less than 10 DAC-hours.
Based on current site activities and relatively low concentrations of airborne radioactivity, the licensee has discontinued urine bioassay sampling for SNM. Also, i
quarterly lung counts for U-235 have been changed to annual counts. The licensee had scheduled lung counts for January 1997. Based on site history and current l
operations, and the review of air sampling data, the inspectors had no concerns relative to these changes.
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Regarding external exposures, the maximum individual deep dose equivalent (DDE) l from external exposure was 0.390 rem. This exposure was associated with l
cleanup activities at the HCF where the external exposure contributor is byproduct materiallicensed by the state. No intakes resulted in a committed effective dose equivalent (CEDE) to be assigned to personnel at the HCF. The maximum total effective dose equivalent for any one person at other site locations previously I
involved with SNM activities was 0.125 rem, also primarily from state licensed material.
Regarding the licensee's evaluation of a discrepancy between electronic dosimeters and TLD results, the licensee observed that the 1996 first quarter vendor TLD results were significantly higher (26-57 percent) than the data provided from electronic dosimeters used to track day-to-day exposures. The discrepancy was noted for personnel involved with the removal of waste from the metallography cell.
From a comprehensive study and tests between the TLDs and the electronic L
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6-l dosimeters, in an area where the TLD powder ampules were housed, the licensee i
determined that the discrepancy was due to high energy beta radiation (Sr-90/Y-90) penetrating the open and thin arcas of the badge. All of the abnormal exposures were significantly below GA administrative dose limits and NRC limits. Based on the results of the study, new type TLDs have been procured for use by workers when working in areas where high energy beta contaminants exist.
During a review of the licensee's routine surveys, the inspectors noted that the radiation dose rates in the liquid waste processing f acility (Building 25) had i
increased during the past year. The facility is used to process (filtration) radioactive liquids before discharging to the sanitary sewer system by batch releases. In previous years, the dose rates were typically less than 0.0002 rem /hr due to the low concentrations of radioactive liquids processed in the facility. Starting in 1996, i
the licensee began processing liquid waste from the HCF that contained significant quantities of Co-60 and Cs-137 (state licensed material). The inspectors noted that the licensee's routine monthly surveys of the facility since January 1996, indicated dose rates from 0.0002 to 0.013 rem /hr. At the time of the inspection the licensee's most recent monthly survey ranged from 0.0002 to 0.003 rem /hr. The licensee was also aware of the increased radiation levels. On August 30,1996, to facilitate the evaluation of the dose to the unrestricted area, the licensee placed a TLD badge on the outside East wall where a dose rate of 80-90 micro rem /hr had been measured. The TLD was changed on September 30,1996, and sent to the vendor for processing. On December 12,1996, the vendor sent a facsimile report of the results to the licensee which indicated a dose of 0.090 rem. This dose exceeded the licensee's alert level of 0.065 rem per quarter (includes background) requiring an evaluation to ensure compliance with 10 CFR 20.1301 and 1302, the dose requirements for members of the public which has been adopted by the State of California.10 CFR 20.13u2(b)(1) permits the use of occupancy times to show compliance with the 0.1 rem annual dose limit specified in 10 CFR 20.1301
((Reference, Answer to Question 207, NUREG/CR-6204," Questions and Answers Based on Revised Part 20," dated May 1994). Relative to the TLD results, the licensee appropriately initiated an investigation / evaluation of the dose to members of the public.
The licensee's respiratory protection program was adequately addressed in licensee procedures. The licensee maintained procedures for cleaning, inspecting, and issuance of respiratory protection equipment. The inspector noted that respirators were primarily used only at the HCF Training, medical qualification, and fit testing were consistent with licensee procedures and the requirements of 10 CFR 20.1703.
c.
Conclusions The inspectors concluded that the licensee was adequately controlling and evaluating external and internal exposures. The licensee appropriately initiated an l
evaluation of the potential dose to members of the public from state licensed materials at Building 25.
l 2.2 Control of Radioactive Materials and Survevs j
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Insoection Scope (88104 and 83822)
Records of routine and non-routine contamination surveys of controlled areas were l
reviewed and discussed with the licensee. Work activities, radiation warning postings, and controls were observed during facility tours. The licensee's radiological characterization and soil sample results of approximately 7,000 cubic yards of soil, asphalt, and gravel recently removed from the yard area adjacent to the SVB facility were also reviewed and discussed with the licensee.
b.
Observations and Findinas The inspectors noted that the licensee's radiation and contamination survey program was consistent with Section 4.0, Part ll of the license. Removable alpha contamination levels on the floors of the former manuf acturing area in the TFFF, the SVB f acility, and the Building 25 liquid waste processing facility were typically maintained at less than 10 disintegrations per minute (dpm) per 100 square centimeters.
The licensee's survey data and analysis of contaminants for the HCF indicated that the primary radioisotopes detected were Co-60, Cs-134 and 137, and Sr 90 that are licensed by the state. With the exception of low level residual SNM contamination from handling irradiated fuel in the hot cells, the licensee's data indicated no SNM contamination was present in the remaining areas of the facility.
Recent wipe tests of the low-level and high-level hot cells, after significant cleaning, indicated a nominal average for removable contamination of 5.6 E4 dpm per 100 2
square centimeters (dpm/100 cm') for beta activity and 75 dpm/100 cm for alpha activity. Although there is no accountable SNM remaining in this facility, the licensee was maintaining an operational criticality monitoring system until an appropriate assessment could be made of any potential SNM in non-accessible portions of the drain and ventilation systems, and the empty hot cell storage pits.
During a tour of the HCF, the inspectors noted that the licensee was preparing for remote loading of a shielded shipping cask with a removable hot cell waste liner.
The waste had been characterized and classified per DOE requirements for disposal at the DOE disposal facility in Richland, Washington. The waste consisted of byproduct materiallicensed by the state and did not contain any accountable SNM.
The licensee expected that this would be the last waste shipment requiring the use of a shielded shipping container. The inspectors also noted that the licensee's industrial safety inspector was observing the lifting and transfer of the shipping cask to the HCF. The licensee was noted to be taking photos and video taping the entire operation for its D&D records and future training and procedural references.
l The inspectors noted that the licensee had cleared the hot cells of debris, removed interior office area walls in several areas surrounding the hot cells, and remediated
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the former machine shop attached to Building 23. To date, several thousand cubic feet of clean and radioactive D&D material has been removed from the HCF site.
A review of material release logs at the SVB facility indicated that adequate radiological surveys were performed on equipment removed from the facility. The i
survey data indicated that items dispositioned for unrestricted use were well below l
the release limits specified in Annex C, Part il of the license. Based on the nature of previous operations at this facility, most of the equipment in the process area does l
not contain significant quantities of residual SNM contamination. The primary radioactive contaminants appear to be source material.
The licensee's sampling data for the approximately 7,000 cubic yards of soil removed from near the SVB facility indicated that the concentrations of thorium, depleted uranium, and enriched uranium were well below previously established criteria allowing release for unrestricted use. The licensee had taken 35 samples which appeared representative of the material for disposal. Procedures and sample counting methodology were consistent with previous NRC confirmed practices. By letter dated December 11,1996,the licensee requested from the NRC and State of California approval to dispose of the soil at a locallandfill. A summary of the sample results were also provided with the request. The soil and other debris were from an operation involving the removal of old non-contaminated underground
- piping, During facility tours, the inspectors observed that personnel were dressed in appropriate protective clothing. Survey instruments in use appeared operational and within their current calibration period. The inspectors also noted that radioactive materials and radiation areas were posted in accordance with 10 CFR Part 20. The j
licensee was also maintaining adequate security of radioactive materials at each of the facilities visited.
c.
Conclusion The inspectors concluded that the licensee was adequately controlling radioactive materials and contamination levels related to ongoing activities were being maintained ALARA.
3 Operator Training and Qualification a.
Inspection Scope (88104 and 88010)
The inspectors reviewed and discussed the applicable licensee training programs i
with cognizant licensee personnel, reviewed records of training, observed ongoing activities, and held discussions with selected personnel.
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Observations and Findinas New employees received the licensee's radiological worker training, which included radiological fundamentals, biological effects, radiation limits, radiation emergencies, and the licensee's ALARA program. Personnel assigned to work with SNM, or in areas where SNM is handled, received training in the fundamentals of criticality safety, which included basic nuclear theory, consequences of criticality accidents, controls and limits to prevent criticality accidents, and internal reporting requirements (highly emphasized) when upset conditions involving SNM occur.
Personnel were provided annual refresher training commensurate to their assigned l
work areas. Following each training class, all employees were tested to evaluate their knowledge of the material presented.
l In addition to the above training, each facility maintained procedures under its respective work authorization that defined personnel training and qualification requirements. Each facility also maintained a data base of current training on facility procedures that included, but was not limited to, general operating and safety requirements, materials and equipment removal, radioactive and hazardous waste handling and packaging, waste shipping requirements, and facility emergency procedures. The inspectors noted that training was being conducted as specified by each facility. No concerns were identified relative to the qualification of licensee personnel, c.
Conclusion The inspectors concluded that personnel were adequately trained and qualified for their assigned tasks.
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4 Followup a.
Violation (92702)
(Closed) Violation 70-734/9603-01: Failure to provide annual refresher training on the use of self-contained breathing apparatuses. Based on discussions with cognizant licensee personnel and a review of licensee training records, the inspectors verified that the licensee had completed the corroctive actions, as stated in its timely letter dated November 8,1996. The inspectors noted that the licensee had contracted the services of a consultant to perform the training and had assigned the site industrial hygienist the responsibility to assure that such future training
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would be conducted in a timely manner. The inspectors also noted that the licensee i
was modifying its training data base to indicate that training was needed before the i
required elapsed grace period ended.
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Licensee Events (90712 and 88104) l (Closed) Licensee Event Report No. 31165: Small fire in empty hot cell during D&D. On October 16,1996, the licensee initially reported to the NRC that at approximately 4:45 p.m. on October 15,1996, they discovered that a plastic paint tray had burned inside of the licensee's low-level hot cell. The licensee had been in the process of applying a strippable paint to remove contamination. The licensee l
suspected that the plastic paint tray may have ignited from metal cutting (torch and i
grinding) operations outside the low-level hot cell door on October 11,1996. Since i
the low-level cellis negative in air pressure to the outside cutting area, a spark may have been pulled into the cell igniting the paint tray that was on the floor near a small gap at the bottom of the cell door. The fire was not detected until the lights were turned on inside the cell on October 15,1996. The licensee reported this matter in accordance with the requirements of 10 CFR 70.50(b)(2)(ii) as particulate from the burnt plastic may have plugged and rendered the HCF's exhaust ventilation high-efficiency particulate air (HEPA) filtering system inoperable. The licensee also reported this event to the DOE and State of California.
The licensee subsequently retracted the report because the fire did not directly involve radioactive materials, there was no release of radioactive material, there was no damage to the facility, and the main HEPA filtering system had not been affected. Although the differential pressure of a booster fan HEPA filtering system exceeded the licensee's action level for filter replacement, the main HEPA filtering system was not affected and was capable of performing its safety function. The booster system discharges to the intake of the main HEPA filtering system and if the booster fan HEPAs completely plug, all air flow automatically diverts to the main HEPA filtering system. The HEPA filters on the booster system were replaced.
The licensee's investigation determined that the root cause was due to personnel error in that suitable procedures were not used. The paint tray had been left near the door following an interruption in the cutting work to apply strippable paint to the cell. When cutting operations resumed, there was no inspection of the area on the other side of the door (cell side) and the paint tray was not visible to the fire waten on the opposite side of the door. Thus, conditions were altered from the original approved conditions, without the knowledge of the fire watch when the torch cutting resumed. Corrective actions included reviewing the event with HCF personnel with emphasis on work organization and planning, improvement in communication, and the performance of safety reviews prior to resumption of work following interruptions.
The inspectors concluded that the licensee's corrective actions were appropriate.
l The inspectors also performed a walk-down of booster and main HEPA filtering l
systems with operations personnel and did not find any operational concerns. The inspectors had no further questions related to this event.
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. Exit Meeting Summary The inspection results were presented to members of the licensee management at the conclusion of the inspection on December 13,1996. The licensee acknowledged the findings presented.
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Although proprietary information was reviewed during this inspection, such information is not knowingly described in this report.
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ATTACHMENT SUPPLEMENTAL INSPECTION INFORM ATION PARTIAL LIST OF PERSONS CONTACTED i
Licensee L. K. Alfonso, Corporate Industrial Hygiene and Environmental Science K. E. Asmussen, Director, Licensing, Safety and Nuclear Compliance V. J. Barbat, Manger, Engineering and Maintenance, Hot Cell Decommissioning G. C. Bramlett, Manager, Hot Cell Project F. C. Dahms, Manager, Fuel Fabrication Equipment M. B. Dolphin, Manager, Nuclear Waste Processing Facility R. C. Noren, Director of Fuel Fabrication L. R. Quintana, Manager, Health Physics J. M. Sills, Manger, Health Physics, Hot Cell Facility Decommissioning C. L. Wisham, Manager, Nuclear Materials Accountability J. Yi, Manager, Nuclear Safety INSPECTION PROCEDURES USED IP 83822: Radiation Protection IP 88005: Management Orgar 'ation and Controls IP 88010: Operator Training /F,waining IP 88104: Decommissioning Ir.t iection Procedure for Fuel Cycle Facilities IP 90712: In-Office Review of Licensee Events IP 92702: Followup on Corrective Actions for Violations and Deviations ITEMS OPENED, CLOSED, AND DISCUSSED Closed 70-734/9603-01 Violation: Failure to conduct annual refresher self-contained breathing apparatus training.
Closed 70-734/31165 LER: 10 CFR 70.50(b)(2)(ii)- Fire in hot cell
i LIST OF ACRONYMS USED ALARA as low as is reasonably achievable cm centimeters CRSC Criticality and Radiation Safety Committee DAC derived air concentration DDE deep dose equivalent dpm disintegrations per minute per 100 square centimeters D&D decontamination and decommissioning DOE Department of Energy
.HEPA high-efficiency particulate air HCF Hot Cell Facility POL possession-only license rem /hr rem per hour SNM special nuclear materlat SVB Building 39 TFFF TRIGA Fuel Fabrication Facility TLD thermoluminescent dosimeter l