ML20195J115

Insp Rept 70-0734/88-09 on 881024-28.No Violations Noted. Major Areas Inspected:Followup on Inspector Identified Items,Mgt Organization & Controls,Operator Training & Retraining,Criticality Safety & Emergency Preparedness

ML20195J115
Person / Time
Site:	07000734
Issue date:	11/25/1988
From:	Brock B, Fish R, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195J112	List: ML20195J109 ML20195J115
References
70-0734-88-09, 70-734-88-9, NUDOCS 8812010287
Download: ML20195J115 (12)

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U. S. NUCLEAR REGULATORY COP #1ISSION REGION V Report No. 70-734/88-09 Docket No.70-734 License No. SNH-696 [

Priority O. Category II Safeguards Group I Licensee: General Atomics I P. O. Box 85608  !

San Diego, California 92138 ,

3 Facility Name: .Torrey Pines Mesa and Sorrento Valley Sites Inspection at: San Diego, California Inspection Conducted: October 24-28, 1988 Inspector: 5M Inspector: < //

K. M. Prendergakt, Emergency Preparedness Ddte Signed Analyst

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Approved by: S? t., / N R., Fish, Chief Date Signed Emergency Preparedness Section Summary:

i INSPECTION ON OCTOBER 24-28, 1988 (REPORT NO. 70-734/88-09)

Areas Inspected: A routine unannounced inspection was conducted covering follow-up on inspector identified items, management organization and controls,

operator training and retraining, criticality safety, operations review, radiation protection, emergency preparedness, an<i environmental programs.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, i

83822, 88050 and 88045 were covered.

Results: The licensee's performance in the area of management oversight J appeared to need strengthening in the area of follow-up of internal audit findings. Additionally, the license needs to give continued close attention to the verification of the initial presence and the continued presence of the neutron absorber essential to the safe operation of the coater with its

!. increased batch size. Detail is provided in Sections 3.8(1) and 3.E(5) of the report. No violations were identified in the seven areas inspected. One j unresolved item related to a shipment of radioactive waste was identified, hhdd$f 8084

DETAILS

1. Persons Contacted A. _ Licensee Employees: i

• R. N. Rademacher, Vice President, Human Resources . i

• K..E. Asmussen, Manager, Licensing Safety and Nuclear Compliance '

• V. Malckhof, Manager, Nuclear Safety

• R. C. Noren Director', Nuclear Fuel Fabrication

• K. L. Johnson, Manager, Facilities Engineering i

• W. L. Whittemore, Manager,,TRIGA Reactors Facility

• J. Razvi, Deputy Manager, TRIGA Reactors Facility

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• A. L.-Galli, Manager, Security

.R. DeVelasco, Staff Engineer, Core Engineering P. Warner, Manager, Fuel Operations, Production & Material Control C. Wisham, Manager, Nuclear Material Accountability L. R. Quintana, Manager, Health Physics J. Narvaez, Supervisor, Nuclear Waste Processing Facility E. D. Weldon, Foreman, Quality Control Laboratory

• L. Adelman, Health Physics Technician S. Perlman, Health Physics Technician J. S. Greenwood, Senior Scientist, Hot Cells W. E. Simpson, Senior, Technician

.N. J. Brown, Manager, Equipment Engintaring Branch

• R. K. Krueger, Supervisor, TRIGA Fuel Production

.T. W. Keim, Senior Nuclear Fuel Waste Processor B. Evans, Nuclear Waste Control Operator

• Denotes those attending the exit meeting 10/28/88.

2. Follow-up on Previous Inspection Findings (Closed) Open Item 84-04-08: This item involving review of the Grinder holdup study requires resumption of production of HTGR fuel. The plant has been shutdown for about four years and is not likely to startup in the near future, therefore this item is considered closed.

(Closed) Open Item 87-01-06: Review the status of the air sampling PVC tubing replacement with stainless steel tubing at the TFF and the Waste Handling Facility. This item was discussed with licensee management.

They stated they will remove the PVC tubing from their stack sampling apparatus within the next two months and replace it with stainless steel tubing. The licensee plans to leave sne line of PVC tubing installed to compare the air sample results with those from the use of stainless steel tubing on the same stack. This commitment closes this item.

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(0 pen) Open Item 88-02-05: Review the status of corrective action ,

regarding a violation for the failure to provide emergency response team

• training. This item was examined and the Radiological Contingency Plan (RCP) has been revised to make provisions for emergency response training '

to be specific to each facility. The revisions to the RCP require that emergency team training is to be coordinated between facility management and the the Supervisor of Emergency Services. Specific training requirements are to be determined by each facility manager and submittco in writing to the Supervisor of Emergency Services who will be responsible for providing the necessary training. This item will remain  :

open pending the issuance of the change to the RCP and the implementation .

of the training program described in the plan.

(Closed) Open Item 87-01-08: Review the licensee's plans for increased interfacing and more exercises with Scripps Memorial Hospital. This item L was discussed with licensee management and they stated, that very -

recently they requested the hospital to participate in an emergency  !

, drill. The hospital's reply indicated they already participate in a l I

sufficient number of drills each year and are comfortable with their

capabilities. Consequently the hospital indicated they do not wish to

add another drill to their schedule. The licensee stated they will follow the verbal request with a written request to insure their E intentions have been recognized and that for the time being there will be

no further action on this item. The licensee's efforts to include the hospital in emergency drills and exercises is satisfactory to close this item.

l (Closed) Open Item 87-06-03: The licensee was not able to locate the original surveys for the Experimental Building cleanup following i activities conducted under NRC license. The licensee, therefore, resurveyed the area. This item is considered to be closed. The resurvey is addressed under open item 88-05-05.

1 (Closed) Open Item 88-02-01: No non-SNM items resembling SNM items were

. submitted for review for continued vault storage. This item is closed.

l (0 pen) Open Item 88-05-01: The licensee's controls for verifying the initial and the continuing presence of the neutron absorber added to the draft tube were still being developed. This item remains open.

) (0 pen) Open Item 88-05-02: The licensee's procedure covering the i operation of the coaters contained administrative controls to preclude double batching. However, the procedure has not been revised yet to

addres the steps that will assure that the draft tube is in place before operating the coater. This item remains open.

(Closed) Open Item 88-05-03: The licensee removed the non-SNM items that resembled SNM items from the TRIGA vault. This item is considered i closed.

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) (Closed) Open Item 88-05-04: The licensee had discontinued routine use of the cutoff saw. The log book that included the data from tracking the

cutoff saw holdup had been sent to long term storage. Although little i

3 use is anticipated for the cutoff saw, a replacement logbook was prepared and is available to track holdup. This item is considered closed.

(0 pen) Open Item 88-05-05: The licensee's resurvey of the former TFF area of the C-Building disclosed some contamination which was at a marginal level relative to current release criteria. The licensee is undertaking additional cleanup (see Section 3.0.(1)(f) below for details). This item remains open.

3. Functional or Program Areas Inspected A. Manaaement Oraanization and Controls (88005)

(1) Internal Review and Audit The licensee conducted the license required nuclear criticality safety inspection. The previously identified items had been expeditiously corrected. No new items were identified.

! (2) Safety Committee The licensee's Criticality and Radiation Safety Conuittee (CRSC) completed and published the annual ALARA report. The

findings indicated that the licensee's operations continue to I

recognize and take advantage of opportunities to reduce personnel exposures.

Performance in this program area appears to be adequate. No violations were identified.

B. Criticality Safety (88015)

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(1) Nuclear Criticality Safety Analysis (a) The licensee's Nuclear Safety Analysis (NSA) for processing a larger batch size in the coater was completet The NSA was appropriately reviewed by the manager of nuclear safety. The reviewer from the CRSC independently verified the NSA using an alternate code.

The independent CRSC verification yielded a k-effective below the license limit. The value indicated the original analysis appeared to be conservative by about 6 percent.

(b) The licensee's operating procedure for the coaters incorporates administrative controls to preclude double batching.

(c) The licensee has evaluated the possibility of water leaking into the coater at a rate that conceivably could eject a single batch of particles out of the confines of the draft tube. The multiplication factor for this condition does not exceed the license limit. Expulsion of a double batch from the draft tube by water flooding is 6 ..

4 necessary to establish conditions that would permit a multiplication factor exceeding the license limit.

(d) The licensee increased the thickness of the neutron absorber layer in the draft tube even though the NSA indicated the initial thickness proposed was adequate.

The resultant k-effective was slightly moit conservative.

(2) Audits (a) The inspector examined the licensee's criticality safety inspections of the TRIGA fuel fabrication facility. No other areas required a current inspection. The inspection covered a broad scope with sufficient depth to identify significant items needing correction. The items identified were minor and were expeditiously corrected.

Performance in this program area warrants continued attention as the verification of the boron content of the draf t tube is crucial to meeting one of the criticality safety contingencies. No violations were identified.

C. Operations Review (88020)

(1) Conduct of Operations (a) Hot Cells The inspectors examined the status of the hot cell operations. This operation, previously oriented towards Decontamination / Decommissioning (D/0), is now in a hold position. The current operation in this area involves tritium gas extractions. This operation is performed in a new gas handling system installed in the Service Gallery behind the Metalography Cell.

(b) TRIGA Fuel Fabrication (TFF)

The inspectors toured the TFF facility. The flexible plastic tubing used to test the hydrogen detectors near the hydriding furnace had been replaced with permanent metal tubing. This change coupled with the revision to the hydriding furnace checklist represents a significant improvement in assuring testing of the hydrogen detectors.

The test was demonstrated and the appropriate warning response and alarm were achieved. However, the alarm reset malfunctioned and was subsequently adjusted to improve its performance.

The licensee had recently received a shipment of TRIGA fuel elements from the University of Missouri. These unused fuel elements were serviceable and some were, therefore, being recladded to meet the needs of other customers.

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5 (c) Sorrento Valley B Building (SV-B)

The operations in SV-B do not currently involve processing Special Nuclear Material (SNM). The licensee anticipates making a few coater runs with normal or depleted uranium particles to check the coating parameters for processing the larger batch size.

(d) Low Level Radioactive Liquid Waste Treatment System (Building 25)

The inspectors visited Building 25 and observed the operators processing a tank of low level liquid waste.

The operators were following the revised procedure that allowed them to neutralize the liquids in the transfer tank. No poor practices were observed.

(e) Facility Exhaust Stacks The licensee acquired stainless steel tubing to replace

,the PVC tubing used in stack sampling at various locations around the site. The licensee plans to complete the replacements within two months. The PVC system at the Hot Cell will be left in place for comparison of results obtained from the new stainless steel air sampling system.

(f) Experimental Buildina (E-Buildino)

The licensee's recent surveys of the areas that previously -

comprised the TRIGA Fuel Fabrication plant identified contamination at levels close to the NRC release limits.

The licensee moved the area occupants to an adjacent location and scabbled or otherwise removed the contamination. Drain lines were also removed from beneath the floor. This cleanup effort is continuing. The licensee noted that *.he computer room which is also a part of the same area will not be cleaned at this time. The l computer room will instead be added to the list of areas

! that will need to be cleaned for release at a later date.

i This list is updated as changes occur to assure that such areas will not be overlooked.

(g) Sorrento Valley A Buildina (SV-A)

The inspector vicited the area previously considered for a r new break / lunch room. The wall area that contained what appeared to be a faint outline of a door was reexamined.

Plant drawings indicated the presence of a small shower stall on the opposite side of the wall. The shower stall was examined and found to be consistent with the historical drawings which indicated the shower had been in place before the last major plant modification.

Additionolly, the concern over the duct above the "door" was similarly resolved.

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.(h) Nuclear Warte Processing Facility (NWPF)

The inspectors observed that.the' licensee continues to test solidified wastes for residual water by tilting them sufficiently for water to seep out before the lids are installed. This check continues to be effective in assuring that the solidification process is performing successfully. A waste shipment containing 80 drums and two bins was scheduled to be made during the inspection (see Section H.(2)).

Performance in this program area appears adequate. No violations were identified.

D. Radioactive Waste Manaaement (88035)

(1) Effluent Reports The licensee's effluent reports were issued as required by 10 CFR Part 70.59. The reports indicate 6 that the licensee's effluents (liquid, gas and particulate.) were less than regulatory limits. The reports ware issued within the regulatory time requirement.

(2) Management Control Nuclear Waste Processing Procedure 2100 was examined and noted to provide an overview of the responsibilities for the Nuclear Waste' Processing Facility. Responsibilities and authorities were written and well defined. Nuclear waste processing procedures were current and had been approved by GA mancgement.

Approval of facility procedures included members of GA management with responsibilities in Criticality and Accountability, Industrial Hygiene, Production and Material Control, and Fuel Fabrication. Facility personnel are required to read and sign all changes to facility procedures to insure operators remain current with procedure changes. A sampling of recent changes to the various facility procedures were examined and noted to have been signed by facility personnel. The procedures changed included General Operating Procedure No.

2100. Transportation on Site No. 2709, and Solidification No.

2713.

(3) Records Records of releases to the sanitary sewer from Ju.ie 1988 to September 19?8 were examined and all releases were lower than the limits specified in 10 CFR 20.203. All liquid waste is filtered and processed prior to release to the sanitary sewer.

Records of releases were well documented and included the appropriate analysis and dilution factors supporting the releases.

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- Records of air sampling results at numerous locations were examined. The' records indicated weekly air samples are collected and the analyses included beta, gas, and The weekly samples are compared to the limits particulates. .,

specified in 10 CFR Part 20, Appendix B, Table II. The l releases were less than the specified limits. Air sampling

.results exceeding 20 percent of the limits specified in Table  !

II require (by procedure) an examination to determine the reason for the increase and identification of the corrective action needed.

(4) Quality Assurance for Effluent Stream Monitoring Equipment The licensee's quality assurance program for the nuclear counting equipment (Canberra 2404) used to monitor effluent releases was also examined to determine the reliability of the system. Discussions with personnel and a review of the functional tests indicated the licensee has not established an adequate Quality Assurance Program for the equipment. The only routine checks performed on the counting equipment appeared to be weekly 10 minute counts using a prepared standard. A review of the May to October 1988 weekly checks displayed significant non-random variances. Prepared americium-241 and cesium"137 standards used for 10 minute counts in the alpha and beta channels resulted in variances of up to 20 percent. The non-random variance was explained as possibly due to substandard gas. Also, there did not appear to be any guidelines or procedures to address investigative and corrective actions to be taken when the control standard measurements fall outside of the normally expected ranges.

The inspector concluded that the licensee needs to establish a quality assurance program for the nuclear counting equipment located in the health physics laboratory. Appropriate procedures should be prepared and operator training should cover the procedures as well as use of the equipment. The licensee should also determine if such a program is applicable to other facilities on site to insure the reliability and accuracy of the data used for quantifying radioactive materials. Licensee performance regarding this issue will be followed as open item 88-09-01.

Performance in this program area appears adequate with the exception of nerd =d improvements described in section 0.(4). No violations were identified.

E. Radiation Protection (83822)

! (1) Posting of Notices 1

The inspector's review of the postings during the walk-through

' of the licensee's facilities verified the licensee continues to comply with the requirements specified in 10 CFR 19.11.

Surveys were also performed at numerous facilities, using a 1

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8 calibrated survey meter, and the results verified that radiation warning signs were appropriately posted, b (2) External Exposures Records of external exposure from April 1988 to June 1988 were examined. The examination determined that all exposure were within the requirements contained in 10 CFR Part 20. The records also documented that the licensee audits exposure records to determine the exposures are within normal expected ranges. Should a higher than normal exposure occur, the licensee would perform an evaluation to determine the reason and take corrective action if appropriate.

(3) Termination Reports Termination reports were also examined and noted to ba satisfactorily completed and furnished to individuals within the 30 day time period specified in 10 CFR 19.13.

(4) Bioassays The inspector examined the invivo lung counts for U-235 i performed in October 1988. The lung counts were all less than

the licensee's 100 microgram investigative limit. The inspector also examined the urinalysis results for the period from June 1988 to September 1988 for low energy alpha and tritium. The results showed that no exposures above the i airborno regulatory limits in 10 CFR Part 20 had been exceeded.

'(5) Audits

' The ifcensee conducts quarterly audits of the radiation safety program implemented at numerous site facilities. The facilities audited included: Sorrento Valley A and B Buildings, TRIGA and TRIGA Fuel Fabrication Buildings, Hot Cell Building, Waste

! Facility, and numerous science buildings.

The audits examined radiation work authorizations, posting and labeling, instrument calibration and operability, ventilation surveys, facility operations, and airborn contamination levels.

I 4 Quarterly audits for September 1988 were examined and the i reports indicated the licensee is actisely following radiation i sai'ety practices. A few of the audit fhdings from the

. September audits were followed to determ he if appropriate l corractive actions were taken. In general, the licensee has an 1 acceptable audit program for radiation safety. However, two audit findings were identified in which there had been no corrective action. One item dealt with the posting of barrels in the fenced area behind the TRIGA Reactor building. The i audit finding recommended that the barrels, one of which

! exhibited 27 mr/ hour at the surface, be removed to the waste facility or that the area be posted. This area was visited I during this inspection and it was noted that no action had been

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, g taken. However, it should be noted that the barrels were quickly posted at the time of the inspector's visit when the lack of corrective action was brought to the licensee's

' attention. The other item involved several instances where the licensee's internal audit identified that the double gates i adjacent to the Hot Cell Building were left unlocked. This area contains radioactive materials and is posted "caution radioactive materials" and "caution radiation area." It must, therefore, remain locked or be attended pursuant to 10 CFR 20.105. This area was visited during the current inspection and the NRC inspector observed that the gates were again I

unlocked and unattended. Again the licensee initiated expedient corrective action by replacing the locks and limiting the keys to only 3 individuals with'a need to access the yard.

No other probleas were identified in the licensee's audit program.

Based upon Section E.(5) above, there is a need for further management oversite in the licensee's audit program. No violations were identified in this program area.

G. Deactivation / Decontamination (D/D) Activities (83890)

The inspectors learned that the structures (digesters etc...) in the recently released Callon Ponds area were being demolished to clear the land. The action had NRC prior approval based on the Oak Ridge Associated University Report which found the area had been cleaned to less than NRC release limits.

It appeared that the licensee's efforts in this program area were adequate.

H. Transportation of Radioactive Materials (86740)

(1) The licensee had recently been informed that a cask he shipped to a reactor site was found to be contaminated above NRC limits. The NRC inspectors reviewed the records of the licensee's shipment of the cask. The licensee had surveyed the cask before preparing it for shipment and found contamination.

The licensee removed the contamination, resurveyed the c.tsk, and found it now met NRC limits. The records adequately documented these actions and the results. The clean cask was turned over to the carrier for transport. The cask was not taken directly to the reactor site, but instead spent several days at the carriers Joplin Missouri facilities where the trailer was sandblasted and painted with the cask still on it.

Subsequently identified contamination (Cs-134, Cs-137, and Co-60) was likely the result of weeping from the metal cask wall. It appears that the licensee did not violate any requirements with regard to his initial receipt and survey of the cask. However, the NRC inspector indicated it would be prudent to survey the cask expeditiously on receipt so that the licensee would be in the position of providing timely notification whencver he receives a cask subject to question I'

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(2) The inspectors examined the records for a shipment scheduled

, during the inspection. Additionally, the inspectors observed the licensee's performance in preparing the shipment for transport. The barrels scheduled for shipment had all been surveyed prior to the arrival of the motor carrier. The carrier's vehicle was surveyed on arrival. The truck was loaded with the 80 barrels and two waste bins. The truck survey was made with instruments that were within their calibration periods. The results of the surveys were within NRC regulatory limits. Never-the-less, the licensee elected to i

reenter the trailer and move the higher reading barrel further back in the trailer and also rotated the hottest spot on the barrel toward the rear of the trailer. This change reduced the reading at the cab from 0.5 mR/hr to 0.1 mR/hr. After the addition of the two large metal waste bins about an inch of space remained between the boxes and the trailer doors.

Bracing war, nailed to the trailer bed to keep the boxes from shifting during transport. The licensee's practices were in accordance with his written procedure. The paperwork associated with the shipment was examined and found to be in order. During a November 22, 1988 telephone conversation with the licensee, the inspector was informed that the bracing against backward movement of the final bin had been removed prior to closing the door and installing the seal. Because of the State of Washington's recent action concerning this shipment, we are considering this an unresolved item (0 pen Item 88-09-02).

Performance in this program area appeared adequate. No violations were identified.

4. Exit Meeting (30703)

The results of the inspection were discussed with the licensee's staff identified in Section 1. The topics included a review of the findings in each area inspected and the status of the open items covered, o The need for verification of the initial presence of the neutron absorber in the coater and confirmation of its continued presence was emphasized. Assurance that the boron used in the standard and the draft tubes is all of the same B-10 abundances is also essential.

The licensee indicated they were still developing their approach for dealing with this issue.

o The benefit to be gained by surveying casks expeditiously was discussed from the standpoint that the licensee would be able to provide feedback regarding contamination to the shipper in a

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.11 timely manner. The shipper could then follow-up. identifying a possible source of contamination at his end and thus possibly reduce the spread of previously undetected contamination.

The licensee agreed to consider revising his receiving procedure for casks.

! o The status of the previous open items: closed 7 of 11-items o Additional attention is needed with regard to follow-up of corrective actions identified during internal audits.

The licensee agreed to give additional attention to this area.

Resolution of the specific problems were well underway by the time of the exit meeting.

• The need for establishing a quality assurance program for nuclear countirg equipment, including training and procedures, to insure data is reliable and in accordance with SNM-696 and 10 CFR Part 20 was discussed.

1 The licensee agreed with this recommendation and stated they will establish a quality assurance program for their nuclear

counting equipment.

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