ML20140G740

Insp Rept 70-0734/97-02 on 970513-15.No Violations Noted. Major Areas Inspected:Unannounced Insp Focused on Validation of Licensee Final Radiological Survey Program Including Employee Qualifications,Training & Instrument Calibr

ML20140G740
Person / Time
Site:	07000734
Issue date:	06/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140G738	List: ML20140G732 ML20140G740
References
70-0734-97-02, 70-734-97-2, NUDOCS 9706170044
Download: ML20140G740 (13)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:

70-734 Ucense No.:

SNM-696 l

Report No.:

70-734/97-02 Licensee:

General Atomics (GA)

Facility:

Torrey Pines Mesa and Sorrento Vaiiey Facilities Location:

San Diego, California Dates:

May 14-15,1997 Inspector:

H. Dean Chaney Fuel Facility / Decommissioning Inspector Approved By:

Frank A. Wenslawski, Chief Materials Branch

Attachment:

Supplemental Inspection Information l

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. EXECUTIVE

SUMMARY

l General Atomics NRC Inspection Report 70-734/97-02 This routine, unannounced inspection focused on validation of the licensee's final radiological survey program including employee qualifications, training, instrument calibration, final survey methodology, quality assurance and control of survey results, and implementation of the site decommissioning program. The inspection focused on activities performed in Building 2 (Group 9 laboratories) and selected areas of Building 30. Limited scope confirmatory surveys were conducted in selected areas of the aforementioned buildings by the NRC inspector. Het Cell Facility (HCF) decommissioning activities were

- not observed during this inspection.

Manaaement Oraanization and Controls The licensee's management controls, procedures, and staffing are adequate for current decommissioning activities (Section 1.1).

Implementing procedures for decommissioning activities appeared comprehens;ve properly developed and controlled, of high quality, and had been effectively used

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and implemented (Section 1.1).

The licensee's documentation and retention of documents describing the radiological condition at the site comply with the requirements of 10 CFR 70.25(g)

(Section 1.1).

Emolovee Trainina and Qualifications The health physics and calibration laboratory staff training was appropriate for the I

functional duty assignments and responsibilities (Section 1.2).

Decommissioning personnel possessed a satisfactory amount of experience and technical ability for their assignments (Section 1.2).

Quality Assurance (QA) and Control l

The QA organization was actively involved in decommissioning oversight and assessment of activities (Section 1.3).

The licensee has implemented effective quality control (QC) measures for final survey documentation and validation of results (Section 1.3),

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1 Radioloaical Instrument Utilirrt!on and Calibration l

The licensee had used state-of-the-art radiological survey instruments and technically sound survey methodologies (Section 1.4).

The radiological calibration program met the requirements of 10 CFR 20.1501 and the guidance contained in industry standard ANSI N323, " Radiation Protection Instrumentation Test and Calibration" (Section 1.4).

Licensee Final Surveys and NRC Confirmatorv Survevs The licensee has implemented a program for the conduct and documentation of final

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surveys that follows the guidance contained in Draft NUREG-5849, " Manual for Conducting Radiological Surveys in Support of License Termination" (Section 1.5).

NRC confirmatory surveys performed during this inspection were in agreement with the licensee's results (Section 1.5).

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l Report Details Summarv of Facility Status l

All production and research activities involving use of special nuclear material (SNM) have been discontinued, consistent with the licensee's September 26,1995, request for a possession-only license (POL) amendment and notification of cessation of principal activities at the site. On September 26,1996, the NRC approved the licensee's POL j

request. By letter dated September 30,1996, the licensee submitted a Site i

Decommissioning Plan (SDP).

At the time of the inspection, licensee activities consisted of decontamination and

- decommissioning (D&D) of various site buildings and structures as outlined in the SDP.

Following extensive site characterization, several site areas with minimal potential for radiological contamination were being radiologically surveyed for release for unrestricted use from the NRC and state of California radioactive materiallicenses.

Approximately 109 !aboratories within Building 2 (Science Laboratory) had been released at I

the time of the inspection (Groups 1 through 8). Survey results and documentation for the release of Group 9, and several rooms within Building 30, undergoing internal review prior to submittal of survey results and documentation to the NRC and the state of California.

In October 1989, Oak Ridge Associated University (ORAU) personnel conducted confirmatory surveys of selected Building 2 laboratories (Group 4) and Building 9. ORAU survey results agreed favorably with the licensee's. NRC Inspection Report 70-734/96-01 detailed the results of a special NRC inspection for validating the licensee's D&D programs l

and survey results for release of selected Building 2 laboratories (Group 7). The licensee was using the NRC's interim radiological criteria for unrestricted use as set forth in " Action Plan to Ensure Timely Remediation of Sites Listed in the Site Decommissioning Management Plan," (57 FR 13389, April 16,1992).

Most recently, the licensee's POL activities and D&D program attributes were discussed in i

NRC Inspection Report 70-734/96-04 (December 1996).

1-Conduct of Decommissioning Activities 1.1 Manaaement Oroanization and Controls (88104 and 88005) a.

Inspection Scope l

The inspector reviewed and discussed the current health physics organization structure, functional assignments, audits, procedural controls, and staffing with licensee personnel to determine compliance with the description in Section 4 of the SDP.

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Observations and Findinas The inspector reviewed and discussed the licensee's current organization, staffing, programmatic QA attributes, and procedural controls with licensee management.

The licensee's organization was as described in Section 4 of the SDP. One new health physics technician (permanent GA employee) had been hired since the last inspection of this program area (December 1996). The new technician, as with other past technician hirees, met the qualification guidance contained in ANSI 3.1-1981, " Selection, Qualification and Training of Personnel for Nuclear Power Plants." Selected resumes of staff technical personnel were reviewed. The health physics staff, including managers, met the qualification and experience

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requirements contained in Section 3 of Part II, " Specifications Volume," to the SNM License.

internal and external audits of licensee activities associated with the D&D programs were reviewed and found satisfactory. The QA oversight was proactive and effective. Corrective actions were followed to completion and properly documented. QA managers and lead auditors appeared to meet industry standards (ANSI N45.2.6) for their assignments.

Selected D&D implementing procedures were reviewed and found current and adequate to implement a sound D&D program.

c.

Conclusions The licensee had implemented a well documented and managed D&D program that confo:med to regulatory requirements and the stipulations contained in the SDP.

l 1.2 Health Physics Staff and Calibration Laboratory Technical Trainina and Qualifications (83723) a.

Insoection Scope The licensee's health physics staff's qualifications and training were reviewed for compliance with Section 4.4 of the SDP and Chapter 3 of Part il to the SNM License. The quantitative qualification guidance of ANSI 3.1-1981, " Selection, Qualification and Training of Personnel for Nuclear Power Plants," was used in evaluation of health physics and calibration laboratory technicians. Health Physics staff training was evaluated based on the requirements contained in 10 CFR Parts 19 and 20, and Section 4 to the SDP.

b.

Obsgyations and Findinas

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The inspector reviewed selected employee resumes, training procedures, training i

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outlines, typical tests, and health physics staff training records. The calibration l

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laboratory technician's employment history, resume, and training certificates were reviewed and evaluated. The inspector also interviewed and observed employees l

performing radiological surveys and simulated instrument calibration involving three i

different radiological survey instruments.

The licensee's staff was found to meet license and industry standard guidance on education, experience, and technical training relative to their functional l

assignments.

c.

Conclusions The licensee's staff associated with D&D activities possessed sufficient experience and training as required by the SNM License and the SDP.

l 1.3 D&D QA and QC (88104) 1 a.

Insoection Scone The licensee's QA and QC program associated with final radiological surveys was reviewed. Specific QA requirements related to D&D activities were those associated with the use and handling of radioactive material shipping packages per i

10 CFR Part 71. The following documents were reviewed during this phase of the inspection:

GA QA Audit No. 96008, " Hot Cell Decontamination and Decommissioning Audit," September 1996.

GA QA Audit No. 96005, " Quality Assurance Calibration Laboratory Audit,"

April 1996.

GA QA Audit No. 95023-1, " Procedure Update and Review Audit," January l

1997.

1996 Annual QA Audit of the GA Radiation Protection Program, October 1996.

b.

Observations and Findinas The inspector reviewed the GA QA organization and staff involved in the site D&D l

activities. Several personnel were qualified as ANSI N45.2.23 lead auditors and were available for auditing site D&D operations, The inspector reviewed recent audits of site D&D activities performed by the state of California. No safety

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significant findings were identified during the audits. QA records indicated that all findings were corrected in a timely manner. The QA audit of the HCF decommissioning activities was comprehensive and probing in nature, and included i

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l auditor directed confirmatory surveys of areas identified as being suitable for l -

unrestricted release at the HCF.

To help ensure optimum quality control over the final survey programs in areas free l

of residual radioactive material, the licensee selected a second surveyor to conduct l

a limited confirmatory survey of the area prior to finalizing the survey results. The inspector cautioned the licensee that such a survey should not involve the same i

instruments as used during the original survey. Licensee representatives agreed with this observation.

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Conclusions The licensee's QA and QC program associated with D&D activities appeared adequate to ensure compliance with SDP requirements.

l 1.4 Radioloaical Instrument Utilization and Calibration (88104) a.

Inspection Scope The licensee's programs for radiological survey instrument inventory, control, calibration, selection, ai.3 use were reviewed for agreement with 10 CFR Part 20.1501 requirements and guidance contained in NRC Information Notices and Circulars, and industry standards. The licensee's calibration laboratory is part of the Quality Assurance Organization. The following documents were used in the evaluation of the licensee's instrument use and calibration activities:

NRC l&E Circular No. 81-07, " Control of Radioactively Contaminated Material."

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NRC Information Notice No. 85-92, " Surveys of Wastes Before Disposal from Nuclear Reactor Facilities."

NRC Information Notice No. 84-75, " Calibration Problems - Eberline Instrument Model 6112B Analog Teletectors."

NRC Information Notice No. 93-30, " Evaluation of Wipe Test Results; Calibration of Count Rate Survey Instruments."

NRC Draft NUREG-5849, " Manual for Conducting Radiological Surveys in Support of License Termination."

American National Standard N323197.8, " Radiation Protection 4

Instrumentation Test and Calibration."

3 NRC Regulatory Guide 4.15, " Quality Assurance for Radiokgical Monitoring l

Programs."

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l The licensee's radiological sample analysis laboratory, part of the Health Physics organization, was inspected to determine laboratory personnel qualifications; laboratory implementing procedures; counting instrument availability, calibration, sensitivity; and OC for special media samples.

b.

Observations and Findinas The inspector reviewed the licensee's radiological survey instrument calibration laboratory, including instrument inventory, instrument control, calibration sources and traceability, calibration procedures, and calibration records. Simulated calibration walkthroughs were performed on three instruments (beta, alpha, and gamma detection). The licensee's records and procedures were thorough and current. The calibration technician was well trained and possessed extensive experience in the calibration of radiological survey instruments. The calibration facility was well stocked with replacement parts and vendor manuals. Onsite l

instrument repair and calibration were performed on all types of radiation detection instruments, except for neutron detectors which were sent to outside vendors.

Selected radiological survey procedures and licensee survey data analyses were reviewed and found to be complete and accurate. Methodologies discussed in procedures incorporated guidance contained in NUREG-5849 and experience gained by the licensee during several other major decommissioning projects.

The licensee's radiological sample analysis laboratory was equipped with state-of-the-art gamma spectrometry, liquid scintillation, and automated low energy beta / alpha counting equipment. The laboratory performed various wet chemistry radionuclide separations, when necessary. Laboratory procedures for counting and calibration of instruments were current and available to laboratory personnel. The inspector reviewed the daily instrument consistency checks and daily performance graphs. Sample receipt and tracking logs were reviewed and found accurate for samples on hand.

The licensee's sensitivities for various survey instruments were reviewed and found to be satisfactory for the radionuclides of interest.

C.

Conclusions The licensee's radiological survey instrumentation use and calibration program was implemented in a satisfactory manner.

1.5 Licensee Final Survevs and NRC Confirmatory Survevs (88104) a.

Inspection Scope The licensee's preparation, final survey plan, conduct of the final survey, and analysis of the results for selected areas within Buildings 2 and 30 were reviewed to

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determine their agreement with the methodologies contained in NUREG-5849, the licensee's SDP, and the requirements set forth in 10 CFR 70.38(j).

i Limited-scope confirmatory surveys (alpha, beta, and gamma for fixed and loose contamination, and ambient gamma radiation exposure levels) of selected areas l

within Buildings 2 and 30 were conducted by the inspector to determine the radiological status of the facilities included in the Group 9 release being prepared by j

the licensee.

b.

Observations and Findinos The licensee had submitted a final survey plan to the NRC prior to the inspection for Building 30 and the Group 9 laboratories. During the inspection the licensee finished the final surveys for the seven rooms in Building 30 and the five l

laboratories in Building 2. Residual radioactivity above the guideline values used by the licensee was found in Room 441/449 of Building 2. This contamination was l

l remediated prior to the start of this inspection. The licensee obtained paint and surface material samples in all areas surveyed.

The licensee's draft release report for Building 30 (Rooms 115,114,125,126, 127,128, and 129) and Building 2 Group 9 Laboratories (Rooms 441, 439/441, i

511/513,517, and 645) was reviewed and found to address all the attributes contained in Appendix C to NUREG-5840 and the specific requirements contained in 10 CFR 70.38(j).

The inspector verified that the licensee routinely utilized large area gas flow proportional detectors for surface surveys involving alpha and beta radioactivity.

Ambient gamma radiation exposure levels were routinely measured using sodium l

iodide microR-type instruments.

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The inspector performed limited confirmatory surveys using the following NRC instrumentation:

Eberline E-600, NRC No. 063473, coupled to SHP-100C/GS, SHP-260, and SHP-368 detectors. Due for calibration on November 4,1997.

Eberline PRM 7, NRC No. 010839, microR gamma scintillation detector. Due i

for calibration on July 7,1997.

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Instrument detection efficiencies and minimum detectable levels were established using traceable thorium-230, uranium-234/235, cesium-137, and technetium-99 calibration sources.

Loose and fixed surface beta and alpha residual radioactivity measurements, and I

ambient gamma radiation exposure rates (microRoentgen per hour-R/hr), were obtained in the following areas (considered affected areas):

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Building 30, Rooms 114,115, and 126 (no residual radioactivity was detected in this portion of the building by the licensee).

Building 2, Laboratories 441 and 439 (residual enriched uranium and natural thorium contamination was identified in this laboratory by the licensee).

A review of the licensee's historical data on radioactive material use in the areas survoyed by the inspector showed that enriched uranium, thorium, and cesium-137 were previously used in the areas. Approximately 5-6 smears for loose beta and alpha radioactivity were taken in each area where surveys were performed by the inspector.

The following residual radioactivity release guidelines (taken from NRC Policy and Guidance Directive FC 83-23) were used in analysis of the confirmatory survey results.

Aloha and Beta Emitters:

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Total Activity j

1 (fixed & removable surface activity) 2 2

1,000 dpm/100 cm, averaged over 1 m 2

2 3,000 dpm/100 cm, maximum in 100 cm i

Removable Activity l

2 200 dpm/100 cm The above guideline for thorium (in equilibrium with radioactive progeny) was based

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on alpha activity and was selected as a conservative guideline value in lieu of the natural uranium guideline value, which was five times higher. Instrument sensitivities were established at approximately 50 percent of the guideline values with a 95 percent confidence value. During beta activity only surveys, the guideline value was reduced by approximately 33 percent to account for the reduced beta emission rate relative to the alpha emission rate for natural thorium, l

1 General Area Gamma Exoosure Rate:

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Less than 5.0 R/h above background - when measured at approximately 1 meter

(~ 3 feet) above surfaces / floors.

f Background determinations were made and agreed with licensee values for similar type survey instruments. The majority of the inspector's fixed radioactivity l

measurements were made using the 100 cm Eberline SHP-100C/GS gas flow 2

proportional detector. Loose radioactivity smears were field counted using both the

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l' SHP-100C/GS and the SHP-368A (alpha) zinc sulfide scintillation detector.

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i No residual radioactive contamination above NRC guidelines was detected during the inspector's surveys, inspection Procedure (IP) 88104, Appendix A Field Notes, details tSe inspector's survey data and diagrams and will be placed in the Region IV

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Conclusions 1

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.The licensee's final survey plan and final survey results for Buildings 30 and 2 areas i

j were sufficient for determining the final status of the subject areas and their i

suitability for release to unrestricted use status.

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2 Exit Meeting Summary The inspector presented the inspection results to members of the licensee management at the conclusion of the inspection on May 15,1997. The licensee

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acknowledged the findings presented.

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'V ATTACHMENT I

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED t

Licensee 1

K. Asmussen, Director, Licensing, Safety and Nuclear Compliance L. Quintana, GA Radiation Safety Officer / Health Physics Manager J. Sills, Hot Cell Facility Health Physics Manager P. Maschka, Senior Health Physicist S. Finchum, Health Physics Technician S. Cowan, Senior Health Physics Technician M. Monreal, Senior Electronic Specialist

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D. Pettycord, Manager, Quality Systems

l. Cruz, Health Physicist 1

INSPECTION PROCEDURES USED

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IP 88104 Dec)mmissioning Inspection Procedure for Fuel Cycle Facilities i

IP 88005 Mar agement Organization and Controls i

l LIST OF ACRONYMS USED j

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D&D decontamination and decommissioning j

GA General Atomics HCF Hot Cell Facility i

ORAU Oak Ridge Associated University POL possession-only license QA Quality Assurance QC Quality Control SDP Site Decommissioning Plan j

SNM special nuclear material j

LIST OF DOCUMENTS REVIEWED Procedure Revision Number Title Revision Date i

4 64 Performing a Routine Wipe and Meter AA 12/83 Survey i

122 Routine Duties for Health Physics AH O2/95 I

Technicians Assigned to Bldg. 23 (Hot Cell Facility)

, 156 Routine Duties for Health Physics AH 04/97 Technicians Assigned to Building 30 169 Release of Equipment & Other Item to Unrestricted Use 170 Quality Control in the Health Physics AC 09/95 Laboratory 174 Monitoring Tritium Contaminated Surfaces B

10/91

- 176 Operation of the Berth old Tritium Surface A

08/91 Contamination Monitor 181 Liquid Scintillation Analysis AA 09/91 183 Operation of the Ludlum Floor Monitor B

05/93 186 Instructions for Surveying Outside Controlled B

04/95 Areas 500 Radiological Surveys A

03/94 502 Control of Health Physics Instrumentation A

07/94 522 HCF Soil, Sample Media, Water, and A

08/94 Vegetation Sample Preparation and Exceptions List 526 Performance Testing and Operation of Scaler B

08/94 Counting Systems 1004 Laboratory Procedure for Gamma Spectroscopy B 05/96 via GENIE ESP System 1005 Laboratory Procedure for Alpha / Beta System B

09/95 Using GENIE ESP System 1008 Filtration and Radiometric Analysis of A

03/96 l

Suspended Solids l

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