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Safety Insp Rept 70-0734/88-02 on 880222-26.Violation Noted. Major Areas Inspected:Mgt Organization & Controls, Criticality Safety,Operations Review,Radiation Protection, Transportation of Radioactive Matls & Environ Programs
	ML20150E816
Person / Time
Site:	07000734
Issue date:	03/16/1988
From:	Brock B, Prendergast K, Thomas R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	;
Shared Package
ML20150E806	List: ML20150E804; ML20150E813; ML20150E816;
References
	70-0734-88-02, 70-734-88-2, NUDOCS 8804040118
	Download: ML20150E816 (15)
	v • d • e

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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-734/88-02 Docket No.70-734 License No. SNM-696 Priority 0 Category II Safeguards Group:

1 Licensee: GA Technologies, Inc.

f P. O. Box 85608 San Diego, California 92138 j

Facility Name:

Torrey Pines Mesa and Sorrento Valley Sites

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Inspection at:

San Diego, California Inspection Conducted:

F bruary 22-26, 1988 Inspectors:

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8. L. Brock, uel Facilities Inspector 0 ate Signed

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K.' M. Prenaergast,(EjergencyPreparedness DAte' Signed 1

Malyst Approved by:

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R. D. Thomas, Chief Date Si'gned Nuclear Materials Safety Section i

Summary:

Inspection on February 22-26, 1987 (Report No. 70-734/88-02) l 4

9 Areas Inspected:

A routine unannounced safety inspection was conducted of management organization and controls, criticality safety, operations review, l

radiation protection, transportation of radioactive materials, emergency

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preparedness, environmental programs, and deactivation / decontamination activities.

During this inspection, the procedures covered were 88005, 88015, 88020, l

83822, 86740, 88050, 88045, and 83890.

Results:

One violation was identified in one of the eight areas inspected (emergency preparedness).

The licensee's performance in emergency preparedness training and emergency equipment inventories was not consistent 4

j with the Radiological Contingency Plan.

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I DETAILS 1.

Persons Contacted A.

G. A. Technologies, Inc. (GA T)

R. N. Rademacher, Director, Human Resources K. E. Asmussen, Manager, Licensing and Nuclear Compliance

R. C. Noren, Director, Nuclear Fuel Fabrication R. P. Vanek, Manager, Fuel Proauction Department

V. Malakhof, Manager, Nuclear Safety

K. L. Johnson, Manager, Facilities Engineering

C. Wisham, Manager, Nuclear Materials Accountability

L. R. Quintana, Manager, Health Physics

J. M. Brock, Supervisor, Emergency Services R. I. DeVelasco, Staff Engineer, Core Engineering A. L. Galli, Manager, Security R. J. Bott, Industrial Safety Engineer J. S. Greenwood, Senior Scientist, Hot Cells R. K. Krueger, Supervisor, Triga Fuel Production T. W. Keim, Senior Nuclear Fuel Waste Processor B.

Offsite Agencies City of San Diego - Office of Emergency Management W. R. Wolf, Emergency Coordinator (telephone contact)

M. Bennett, Lifeflight-Air Ambulance (telephone contact)

Denotes those attending the exit meeting.

2.

Management Organization and Control (88005)

License Condition 9 of SNH-696 incorporates the statements, representations and conditions specified in Part II - License Specifications as part of the license.

A.

Organizational Structure Section 3.1 of Part II - License Specifications permits the licensee to change organizational responsibilities, reporting locations and names, providing such changes do not adversely affect the implementation of license conditions and they are reported to the NRC within sixty days after the change.

(1) The Director of Human Resources now reports to a different Senior Vice-President who is also a member of the Board of Directors.

It does not appear that this change would adversely affect the implementation of the license conditions.

The licensee informed the inspectors that the new name for the

2 company is now General Atomics.

Formal notification will be provided as required..

B.

Internal Review and Audit j

Section 3.6 of Part II - License Specifications requires that health physics inspections be_ conducted quarterly and nuclear safety.

inspections be conducted at least annually for all areas possessing j

d SNM and at least quarterly for areas possessing more than 500 grams of SNH.

(1) The NRC inspector reviewed the licensee's nuclear safety inspections.

Six separate criticality safety inspections were conducted by the Manager Nuclear Safety.

The licensee's inspections were conducted as required and were appropriately I

documented.

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C.

Safety Committees Section 3.2.3 of Part II - License Specifications requires that the j

i Criticality and Radiation Safety Committee (CRSC) report to the Office of the President via a designated Vice President.

The CRSC shall as a minimum:

(1) act in a radiological safety advisory 1

capacity; (2) review policies and criteria established for safety of I

SNM operations; (3) provide second level of review for nuclear i

safety analysis; and (4) audit work involving radioactive materials for conformance to and effectiveness of applicable precedures and

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practices including a review to determine how exposures might be

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reduced to meet ALARA.

1, (1) The second party reviewer for the Criticality and Radiition Safety Committee (CRSC) resigned his position with the CRSC to avoid a possible conflict of interest.

This review (r is scheduled to undertake second party reviews in place of the previous second party reviewer who retired at the end of 1987.

The CRSC has available another person it can call on to perform the independent review.

1 No violations were identified.

1 3.

Criticality Safety (88015) t Section 3.2.2.2 of Part II - License Spt'ification requires assurance of i

nuclear criticality safety through review of proposed SNM activities and review of proposed changes in processing equipment and procedures.

It i

also requires frequent inspection and monitoring to assure adequate j

nuclear safety control.

Independent verification of all determinations l

of criticality limits are also required.

j A.

Nuclear Criticality Safety Analysis i

l (1) The licensee indicated two stations were being evaluated for I

addition to the Triga Fuel Fabrication Facility.

One D-2

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station was for bench top disassembly of graphite crucibles.

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The other station was for an additional lathe for machining operations.

The Nuclear Safety Analyses for these changes are still in process.

(2) The Manager Nuclear Safety completed and issued (after appropriate review) the guide to assure the adequacy of nuclear safety evaluations.

The guide should also prove useful in precluding oversights.

(3) The licensee's procedure for control of transfers from the

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Building 39 (SV-8) horizontal storage tanks incorporates sampling based on the results of a sampling study co ducted by I

the licensee.

The results of-the study indicated a-conservatism inherent in the sampling technique such that the2 uranium content of the solution is overstated.

The.

overstatement does not constitute a criticality safety problem because of the direction of the difference.

A new revision of the procedure addresses incorporation of an additional continuous sampling technique which will provide a more representative sample of the solution being transferred.

The revision will yield more accurate measurement results which will be used for nuclear material accountcbility.

The decision of whether or not to transfer the solution will continue to be based on the measurement result obtained from the two samples taken earlier.

This closes item (86-06-01).

(4) The NRC inspector noted the vault storage of a few pieces of boron-carbide (B4C) that appeared similar to fuel meats in shape and color.

The licensee pointed out there were significant differences readily apparent to the two operators and the quality assurance inspector who handled the fuel meats.

However, because the Manager, Nuclear Safety clarified that this material was also intended to be included in those materials which should be excluded from storage in the vault,

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the licensee immediately removed the 84C pieces from the vault.

Further, the Manager, Nuclear Safety plans to issue a clarifying memo that will preclude further confusion as to what Lind of items are specifically excluded and what kind, because of extenuating circumstances, are permitted.

The list of items specifically allowed to be stored in the vault will be reviewed in a subsequent inspection (88-02-01).

(5) The Manager, Nuclear Safety is including a nuclear engineer as a nuclear safety evaluator trainee as he makes the quarterly audits of some of the facilities.

This engineer is not one of those for whom background information had previously been provided to the NRC.

This information is currently being prepared for submittal.

No violations were identified.

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24 4.

Operations Review (88020)

Section 3.2.1 of'Part II - License Specification requires that the 1

licensee's organization conduct their respective activities within.

i federal, state, and local rules and regulations, license criteria, and.

company policy, criteria and established practices, i

3 A.

Conduct of Operations i

q (1) Hot Cells i

The operations in this area were in a standby status.

Consideration was being given to the possibility of doing Post Irradiation Examinations (PIE) on different fuel types.

The Nuclear Safety Analysis for this facility was reviewed by the Nuclear Safety Manager to check the storage facility criticality safety limit for plutonium versus the license limit.

It appeared that the license limit for plutonium would need to be increased if any significant PIE work on other fuel types was obtained.

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(2) Triga Fuel Fabrication

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Operations in fuel fabrication continue at a relatively low l

level.

The licensee has improved the ventilation system of t

this facility.

A new blower was installed on Station 3.

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scope was reduced to cover only the vault, the cut-off saw, the i

centerless grinder, chip chopping, and the surface grinder.

As a result the hood and enclosure air flows ara significantly l

above the required air flow level of 125 lineal feet per minute.

This was facilitated through turning a portion of the facility over to hazardous materials storage.

The area no 3'

longer used by the fuel fabrication facility is on the west i

side of the building.

Station 4 of the ventilation system i

j serves the hazardous materials storage area.

(3) Sorrento Valley B Building (SV-B)

The modifications to the processing line appear-complete.

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system now uses source material.

The waste solutions from the processing of the fuel for the North Warning System (NWS) will apparently be shipped in the near future without further i

processing being required of the licensee.

Progress has been i

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made but this item (86-06-03) remains open.

(4) Low Level Radioactive Liquid Waste Treatment System i

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J The licensee *s procedure NWPF-2718, "Disposal of Liquid Waste to Sanitary Sewer," Issue A, October 23, 1985, addresses I

l neutralization with sodium hydroxide or muriatic acid as appropriate.

The Industrial Safety Engineer assures that appropriate safety equipment is required but does not have responsibility for the thermodynamic calculations.

The 1

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i Manager, Fuel Production made the needed calculations.

The licensee provided the NRC inspector with a corrected copy of the chemical thermodynamic calculations for the proce-.

Item (87-06-01) is closed.

(5) Facility Exhaust Stacks The licensee is continuing the review of the exhaust stack i

sampling.

Isokinetic sampling is to be assured (86-04-07) as well as preclusion of loss of particulates by plating in l

sampling tubes (87-01-06).

Action will be taken on a project basis at the completion of the review.

These two items (86-04-07 and 87-01-06) will remain open, (6) Eg erimental Building The licensee still plans to make a new survey of the portion of the Experimental Building which had previously been used as part of the old Triga Fuel Fabrication Facility.

The survey made over ten years ago has not been located.

An independent overcheck will be made af ter the NRC has reviewed the licensee's survey results.

No violations were identified.

5.

Radiation Protection (83822) i Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.

j A.

Posting of Notices I

A tour of the licensee's facilites was conducted.

The inspector verified the licensee's posting practices were consistent with 10 i

CFR 19.11 " Posting of Notices to Workers." -

B.

Portable Monitoring Instruments Survey instruments were checked by the inspectors during the tour of a

the licensee's facilities.

All instruments were operable and calibrations were current.

C.

Personnel Monitoring Records of personnel monitoring were examined.

They were observed c

to be consistent with the requirements contained in 10 CFR Part i

20.101 and 10 CFR Part 20.104.

i D.

Environmental Monitoring i

Records of environmental monitoring were examined.

The records i

indicated the licensee was implementing their environmental monitoring program as specified in their SNM license.

Records i

indicated environmental sample results were below the limits

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6 specified in 10 CFR Part 20.

The licensee has quickly investigated any sampling results that were higher than normal and has taken corrective actions.

No violations were identified.

1 6.

Transportation (86740)

Licensee's transportation activities are regulated by 49 CFR 100-177, 10 CFR 71, and 20.311.

In addition, an NRC issued Certificate of Compliance regulates the use of shipping casks used to transport fuel and components i

to and from Fort Saint Vrain (FSVR).

A.

The licensee reviewed the status of the reference document file for containers which are authorized.

The references were available for the containers the licensee uses, but not for all the containers the licensee is is authorized to use.

Therefore, the licensee revised the shipping procedure "Shipment of Radioactive Materials" (NMA-4, Issue C) by adding a step to assure that only those containers for which the appropriate references were on file would be used.

Additionally, the licensee revised the "Container Inspection Report and Shipment Checkoff List" to include a specific check for the certification and all referenced documents and drawings.

The instructions for use of this form also separately addressed the requirements of 10 CFR 71.12 and/or 49 CFR 173-178 as appropriate.

The revised procedure, Issue D, was issued 7/87.

This closes item (87-06-02).

No violations were identified.

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7, Emergency Preparedness (88050)

License Condition 23, of SNM-696, requires the licensee to implement, maintain, and execute the response measures of the Radiological Contingency Plan (RCP ) submitted to the Commission on May 25, 1984 and supplemented on August 22, 1984.

The licensee shall also maintain implementing procedures for the RCP.

To determine if the licensee has established an adequate program for emergency response, the inspection included: an examination of the RCP and implementing procedures, discussions with offsite agencies, an examination of drill / exercise records, a review of training records, and an inspection of emergency facilities and equipment.

i A.

Offsite Support Agencies (1) Discussions with offsite agencies verified the licensee has established interface and formal agreements with appropriate state, local, and federal agencies regarding emergency response. Numerous agreements with local agencies, along with documentation supporting the agreements were still in effect.

However, the agreements for the City of San Diego, Office of Emergency Management and the County Department of Disaster Preparedness were not located during this inspection.

These

7 agreements will either be located or reestablished and examined during a subsequent inspection (open item 88-02-02).

(2) Lifeflight, one of the licensee's offsite support groups, was contacted and it was confirmed that niembers of Lifeflight have visited GA-Technologies, Inc. (GA-T) and have an informal agreement to provide medical support to GA-Technologies, Inc.

(GA-T).

It was also stated that landing areas for the helicopters have been arranged. However, from discussions with Lifeflight personnel, it has been a considerable period of time since these arrangements were made and numerous personnel changes have occurred. Considering the licensee has discontinued their own ambulance service, this area should be examined to determine if a more formal agreement would be beneficial.

B.

Emergency Plans (1) The licensee is currently in the process of making significant revisions to the RCP in response to changes in regulations involving hazardous materials and also to account for changes in the GA-T organizations and facilites.

The revisions to the RCP are expected to be completed in June of 1988.

When these changes have been completed, an exercise and an independent audit of the Emergency Preparedness Program are recommended as a method of verifying the adequacy of the licensee's Emergency Response Program.

Items 87-01-07 and 87-01-08 remain open.

(2) The Licensee's Emergency Call List was examined in Security Station No. 1.

It was noted to be c"crent and up to date.

However, as a suggestion for improvement, a copy of the RCP should also be included in the inventory of Security Station No. 1.

C.

Facilities and Equipment (1) The inspection of the licensee's emergency facilities included an examination of the licensee's Health Physics Van, records of required monthly inventories, an inspection of the Emergency Services vehicle, and an inspection of the decontamination facility located in hot cell building.

The inspection of the decontamination facility showed the facility was adequately stocked with equipment and supplies for its intended purpose.

The Emergency Services Van was noted to have been replaced by a three quarter ton truck and these changes were noted to have been addressed in the planned revisions to the RCP.

There were no problems encountered during the inspection of the decontamination facility or the Emergency Services Van.

However, the inspection of the Health Physics Van identified numerous problems.

The inventories were not current and had not been performed since September 1987, the inventory sheet was out of date with some changes in the instrsmentation of the van.

The contents of the van were not sealed to prevent pilferage as required by the Section 8 of the RCP.

Prior to

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the end of this inspection the van was inventoried and the inventory sheet was corrected.

The failure to perform the inventories required by the RCP is identified as a violation 3

and will be tracked as an open item (88-02-03).

D.

Environmental Monitoring I

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(1) Emergency environmental monitoring.was discussed with the licensee and it appears that the licensee has adequately i

addressed this area.

The licensee has installed continous air samplers and stack monitors at appropriate locations throughout the site.

During an emergency, the licensee stated, they would quickly replace and analyze samples from the air monitors and conduct appropriate soil, vegetation, and liquid sampling to determine the impact to the environment and any necessary mitigative actions.

The licensee also has portable air i

samplers for placement in other areas of interest.

The licensee's methodology for. dose assessment was also discussed.

It was determined some improvments are warranted.

Since there were some problems'in dose assessment encountered, the licensee is considering creating a simple "fill in the blanks" procedure

.l for dose assessment using the site meteorological instruments and air sample result..

The licensee is also considering l

1 pre-calculating worst case accidents for each facility using Special Nuclear Material for making a rapid assessment of the l

accident for classification purposes.

This area will be examined in a subsequent inspection (open item 88-02-04).

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E.

Training l

The RCP and implementing procedures were examined to determine if i

they contained adequate provisions for the conduct of emergency response training to include drills and exercises and that appropriate training was conducted.

Based upon this examination the following were identified.

i (1) The RCP does not address adequate provisions for conducting I

I drills and exercises with appropriate frequencies.

The only j

reference to drills and exercises is provisions for evacuation drills not to exceed six months and a reference in Section 4, Offsite Coordination, for a simulated arddent with the offsite l

participating agencies requested to participate.

Records of l

l drills and exercises were examined and the records indicate 1983 and 1984 were the last years when exercises were conducted at GA-T.

It is recommended the RCP be revised to include provisions for annual drills and exercises and provide guidance l

l for the conduct of drills and exercises.

Included should be i

i critiques and the methodology for correcting deficiencies j

identified during drills and exercises. Also, the RCP does not I

appear to contain adequate guidance for emergency response training.

This portion of the plan should be revised to make i

provisions for initial training on the RCP, annual retraining for directors and coordinators of emergency response, accident assessment personnel, radiological monitoring teams, dose I

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9 assessment personnel, and personnel responsible for the transmission of emergency information and instructions.

(2) The examination of the Emergency Team training records indicated the training requirements contained in Section 4.1. 7.1 of the RCP, were not met. The RCP, Section 4.1.7.1, provides a description of the Emergency Team and sets requirements for Emergency Team training in basic first aid, cardiopulmonary resuscitation (CPR), fire suppression, and the use of self-contained breathing apparatus. Discussions with Emergency Services and an examination of the training records provided by Emergency Services, indicate that required Emergency Team training was not satisfactorily accomplished.

Records of ten individuals were examined for the specific training mentioned above and all ten were noted to lack required training in numerous areas.

Specifically, there were no records to indicate any of the ten were current in SCBA or fire suppression.

Also,'there were no records to indicate eight of the ten had received training in first aid or CPR. In addition, although not specifically required by the RCP, the RCP does mention in Section 5.3, that the SCBAs located in the Health Physics Van are intended for use by the health physics personnel.

Discussions with health physics personnel indicated they also are not current in SCBA training.

The failure to provide RCP required training was identified as a violation and will be tracked as Open Item (88-02-05).

F.

Radiation Protection (1) The RCP was noted to contain provisions for all individuals working with radioactive materials to attend a radiation safety course and pass an examination at the end of the course.

Records of radiation safety training for individuals working in Buildings 27 and 37 were examined and appropriate training appears to have been conducted.

G.

Fire Protection (1) Fifty-nine fire extinguishers were checked during the course of the inspection and all were found current with regard to their monthly inspections.

It was noted that some fire extinguishers were set aside for servicing.

The above two items, nos. (88-02-03) and (88-02-04) associated with the RCP, constitute one Severity level IV violation, Supplement VIII.

8.

Environmental Programs Section 6 of Part II - License Specifications requires that an environmental surveillance program shall be maintained to evaluate the effectiveness of the radiological safety program and to provide information to assist in timely corrective action in the event of accidental releases.

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l A.

Inspection Report 70-734/87-12 noted that high results were obtained from the samples taken at Callon Ponds in response to the'NRC-Temporary Instruction 2800/9 "Reconcentration of Radionuclides In Sanitary Sewerage Systems." The values were higher than'the Option 1 limits (30 pCi U/g) of the Branch Technical Position (SECY

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81-576). - The licensee has arranged for shipment of the material to 1

a radioactive waste disposal site.

The material was allowed to air l

dry to a pliable consistency af ter which it was covered to protect it from rainfall.

The licensee indicated the materials accumulated I

from cleanup of the Callon Ponds site will require about twenty (20) shipments at about two shipments per week.

The shipments are expected to start in March 1988 after a dry run is made to identify potential problems so they can be corrected.

The licensee will use a different container from that used previously for the soil

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shipments.

This particular container will not be emptied at the

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disposal site as the others were, but instead will be buried at the I

disposal site.

The containers are metal with strengthening ribs and are closed by four metal lids secured over a gasket by 175 bolts.

No violations were identified.

9.

Deactivation / Decontamination Activities (83890) 1 License Condition 24 requires that at the end of plant life, the licensee I

shall decontaminate the site and facilities authorized as a place of use for special nuclear materials.

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A.

The licensee expects to complete the redesign of the pump house soon I

and has selected a site location.

This relocation site is expected l

to be completed in the month of Ma). The licensee plans to ask for an independent overcheck survey of the old pump house location and the Callon Ponds area, after relocation of the pump house.-

B.

The licensee had requested an independent overcheck of three rooms l

during the inspection.

The inspectors endeavored to complete the i

requested overchecks after the licensee provided a copy of their results of the surveys conducted in the areas.

All of the rooms were in the L Building where several similar rooms had been recently overchecked by the Region (see inspection Report 70-734/87-15).

Room L-313 appeared to have been cleaned to less than NRC release limits with regard to fixed contamination except for one spot on the outside of a drain pipe.

The licensee removed the contaminated i

portion of the drain pipe and disposed of it as radioactive waste.

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The remaining section of pipe was carefully surveyed by the NRC l

inspector and was found to meet NRC release limits.

The results of the wipes taken in L-313 indicate the removable contamination is less than NRC release limits (see Table 1).

Based on the results of the NRC overcheck, Room L-313 of the Science Laboratory Building was satisfactorily decontaminated by the licensee for release to i

unrestricted use in accordance with NRC guidelines.

The licensee i

must still provide the formal report of the evaluation of Room j

L-313.

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11 Room L-236 was found to contain at least two hot spots above NRC release limits.

The NRC overcheck of room L-236 was not completed and the licensee scheduled further cleanup and.'esurvey of the room.

The third room, a two room combination (L-419 and L-421), was separated from the adjacent room by a chain link fence. Although the radioactive material handled in this room was encapsulated, the NRC inspector noted there was no assurance that the operation would not be permitted to handle unencapsulated radioactive material in the future.

The inspector indicated that some consideration should be given to this possibility of a significant operation change and its potential for contaminating a ' released' room.

Tha licensee agreed that the overcheck of this area should be canceled until they could appropriately review the situation and develop an appropriate caveat to the operation of the adjoining rooms.

l The instruments used during the NRC overchecks included an Eberline l

PRM-7 Micro R Meter, Serial No. 247 (calibrated 1/20/88, due 7/20/88) and an Eberline E-520 used with a Geiger tube and alternately with an HP-260 pancake probe, Serial Ho. 2776 (calibrated 1/6/88, due 4/6/88).

No violations were identified.

l 10.

Exit Meeting l

l The results of the inspection were discussed with the licensee's staff j

identified in Section 1.

The topics included:

l The areas inspected.

Status of open items.

Closed items:

86-06-01 Measurement of effluents from the SV-B horizontal storage tanks.

l 87-06-01 Review the licensee's chemical thermodynamics review l

of the neutralization process for procedure NWPF-2718, 87-06-02 Review the results of the licensee's effort to locate the reference documents to the Certificate of Compliance for the containers in use.

Continuing Items:

84-04-08 Review grinder holdup study conclusion (requires HTGR plant restart).

86-04-07 Isokinetic sampling of exhaust stacks.

f 12 86-06-03 Review licensee's actions _in shipment of boxed drums of NWS liquid scrap.

l 87-01-06' Review corrective action on PVC tubing with 90*

bends in the exhaust air sampling systems at the TRIGA Fuel Fabrication and the Waste Handling Facility.

87-01-07 Review the licensee's plans for an independent review of the Emergency and Radiological Contingency Plans.

87-01-08 Review the licensee's plans for increased interfacing and more frequent exercises with Scripps Memorial Hospital.

87-06-03 Review the documentation of radiological surveys of the E Building-made after cleanup following activities conducted under federal license.

New Items:

88-02-01 Review new vault storage list of non SNM items allowed in the vault.

88-02-02 Review formal agreements _with the City of San Diego and the County Department of Disaster Preparedness.

88-02-03 Examine corrective action for failing to conduct inventories of emergency equipment (see Appendix A),

t 88-02-04 Review dose assessment and accident classification 4

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methodology.

88-02-05 Examine corrective action for failing to conduct i

required training (see Appendix A).

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ML20150E816

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