ML20154D728

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0734/88-02 on 880222-26

ML20154D728
Person / Time
Site:	07000734
Issue date:	05/06/1988
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
References
NUDOCS 8805190319
Download: ML20154D728 (1)

Text

- _ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _

h!AY 6 - 1988 Docket No.70-734 General Atomics 10955 John J. Hopkins Drive P.O. Box 85608 San Diego, CA 92138-5608 Attention: Mr. K. E. Asmussen, Manager.

Licensing and Nuclear Material Control Gentlemen:

Thank you for your letter dated April 14, 1988, in response to our Notice of Violation dated March 17, 1988.

Your corrective actions will be examined during the next inspection.

Sincerely, O ( /1/4[ $ / /tC James L. Montgomery, Chief Nuclear Materials Safety and Safeguards Branch i bec w/ copy of letter dated 4/14/88:

G. Cook A. Johnson B. Faulkenberry J. Martin Docket file J. Zollicoffer bec w/o copy of letter dated 4/14/88 M. Smith REG.,10 V (/p 5 '/88 5 88 4 I

REQUEST Q_99Y ] REQUEST C PY ]

fbf5

.YES / N0 ) YES / 0 ] [/Joj SE D TO PDR ]

E / NO ]

8805190319 880506 PDR ADOCK 07000734 ){

C DCD Z E O 5~

L_.

CENERAL ATOMICS .

RECEIVED Mr EEGm V E3 I,P315 P 12:h.'

April 14,1988 696-1216 U.S. Nuclear Regulatory Cm mission ATIN: Document Control Desk Washington, D.C. 20555

~

Subject:

Docket 70-734: SNM-696; Response to Notice of Violation

Reference:

James L. Montgmery letter (NRC Inspection Report No. 70-734/88-02) to R. N. P h cher dated March 17, 1988 Genti men:

his letter is in response to the referenced letter notifying General AtcInics (GA) of a violation. We violation was identified during a j routine unannounced safety inspection of GA's NRC licensed activities I conducted February 22-26, 1988. A brief stat ment of the violation (parts 1 and 2) followed by our explanation and respnse (parts 1 and

2) follows:

l l Statement of Violation:

l

1. Secticn 8.5 of GA's a@ roved Radiological Contingency Plan states, in part, (1) Radiaticn detection instruments will be checked monthly, (3) Protective breathing equipnent will be checked monthly, (4) Other supplies designated for energency use will be checked monthly, and (6) Essential emergency equipnent will be l kept secured to prevent pilfering and misappropriation.

l Contrary to the above, at the time of the inspection, the required inventories for the Health Physics van, which contains essential emergency response equignent, had not been conducted since September 1987. Also, the essential equiptent and emergency kits were not secured to prevent pilfering or misappropriation.

2. Section 4.1.7.1. of the Radiological Contingency Plan (RCP) entitled, Emergency Response Teams, states, in part, team msnbers are trained in basic first aid, cardiopulnonary resuscitation (CPR), building familiarization, fire suppression, and the use of Self Contained Breathing Apparatus (SCBA) .

Contrary to the above, at the time of the inspecticn, the licensee had not conducted the required training for ten merbers of the Records indicated all ten were lacking Emergency Response Team.

cy n j f n m n #1 R O C) [ p'- ( V W /

10955 JOHN JAY HOPKINS ORrVE. SAN DIEGO. CA 92121 1 9 PC. 00x 85608. SAN DIEGO CA 92138 5508 g619) 455-3000

training in Self Contained Breathing Apparatus and Fire Suppression. Eight of the ten were also noted to be lacking training in CPR and first aid.

Explanation /Pesponse:

1. GA's emergency van had been inventoried on .a monthly basis for all radiation detection instruments, breathing equipent and other supplies designated for mergency use until October 1987. At that time, the Health Physics staff person who was responsible for this activity was suddenly disabled by illness. What was initially thought to be only a tmporary disability proved to be long term.

This person's duties were reassigned to other Health Physics staff personnel; however, the nonthly check of the emergency van was inadvertently left unassigned.

Corrective action was initiated inmediately. Full cmpliance was achieved on February 25, 1988, prior to the cmpletion of the subject NRC inspection. Ch that day, an inventory of the emergency van contents was empleted and each mergency kit was l sealed to prevent pilfering or misappropriation.

To prevent recurrence, this mcnthly check of the emergency van contents and of the seals on mergency kits therein has been added to a list of "required activities," thus ensuring its timely empletion in the future. Such inventories were cmpleted on March 3,1988, and April 6,1988, and will continue to te conducted on a monthly basis.

2. When Section 4.1.7.1. of the Radiological Contingency Plan was l

written, it was not intended that it be interpreted to mean that

! each meber of a facility's Emergency Response Team would be trained in all of the subjects enumerated in the pragraph. GA's facilities (buildings) have different emergency response requirements, depending upon the nature of the work being I

performed and the materials involved. Each facility's Emergency Response and Recovery Director is responsible for reviewing the facility's emergency requirments and specifying those areas in j which various of his team mebers should be trained. Section l 4.1.7.1 lists the various subjects in which team members could be trained to satisfy the unique requirments of their specific facility. Again, they need not all be trained in all, or the same, subjects.

l

! The role of the emergency response team merrber is that of the first respnder; they do what they can to control the situation until GA's Emergency Services personnel arrive. For example, in the event of a fire their participation is restricted to the incipient stage. Response team members are given specific assignments calculated to reduce risk and damage during an emergency, such as shutting down certain equipent, turning off gas and power, etc. These tasks are generally work related.

l

It was never intended that all response team mebers be trained in the use of a self-contained breathing apparatus (SCBA) . Prior to being certified to use a SCBA, a person must first have satisfactorily undergone a lung stress evaluation. Not all personnel are physically capable of passing such a test, yet they are very valuable menbers of a response team. All response personnel do receive instructions relative to the SCBA to better understand the device and to guard against its accidental use by uncertified personnel.

SCBAs are primarily used under circumstances where there is a need to enter a facility during an emergency to rescue a person, shut off gases, p:wer, equipnent, etc. and/or clean up spilled materials. Ibwever, the presence of SCAB equipnent in a facility -

does not necessarily mean that smeone there has been, or should

be, trained to use the itm. Rather, sme have been l pre-positioned for emergency use by trained specialists (i.e. ,

l GA's Emergency Services Personnel); for example, if the item has been used in a contaminated area, it might be kept at that facility for future use.

( @e Fuel Fabrication Facility was approved for shutdown in 1985; l the working force was eliminated and the production area has since been virtually unoccupied except for the security force, maintenance and an occasional enployee. hose conducting training j assumed that the training was no longer required after the

! facility was placed in the shutdown mode since there was no longer a work force and the facility (for which portiens of the plan had been developed to support) was no longer active.

The Emergency Procedures for the Fuel Fabrication Facility are current and, as noted in the inspection, there is an eight-person Emergency Response Team. He team is cmp 3 sed mostly of management and office personnel and their main focus is the administrative areas. Since the facility is in a shutdown mode these persons often work on programs requiring their presence elsewhere.

We other persons referred to in the report, whose training records were checked, are meIers of the Dnergency Response Team for a Chenical Analysis Laboratory. %e maximum amount of special nuclear material that can stored and used in this location at any given time is 350 grams of U-235. ne energency equipnent at this facility consists of hand-held fire extinguishers, washes and ,

lights. Emergency training was not up-ter-date due to a misinterpretation of the type of training required. ,

As corrective action, training was initiated inmediately.

Further, all personnel responsible for scheduling, conducting, and maintaining records of training were lectured as to the urgency and importance of an exacting training program and as to their individual responsibilities.

i We emergency response team members whose training was in question will have been trained in those subjects that are applicable to their respective activities by June 1, 1988. In fact, eight of the ten team meters have already empleted their training.

Additionally, training records for other meters of the Radiological contingency Plan response teams are being reviewed and any needed training will likewise be accmplished by June 1, 1988. Selected Health Physics technicians will also have received SCBA training by that date.

To prevent recurrence, the following actions have been or will be taken. An additional person has been detailed to interface with the Emergency Response and Recovery Directors to determine their training needs and objectives. %e individual will assist in the -

administrative aspects of notifying team menbers of the need for training and retraining. Wis same person will monitor records to ensure training is given in a timely manner.

The Radiological Contingency Plan is currently being updated, he wording of Section 4.1.7.1. will be restated to more precisely reflect the training objectives.

We trust you will find our response and corrective actions to be appropriate and satisfactory. If you should have any questiona or require additional information, please contact me at (619) 455-2823.

Very truly yours, Cvs&

Keith E. Asmussen, Manager Licensing, Safety and Nuclear Cmpliance KEA/Ek cc: John Martin, Regicnal Achinistrator, NRC Region V l