ML20202G582
| ML20202G582 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 02/13/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20202G560 | List: |
| References | |
| 70-0734-98-01, 70-734-98-1, NUDOCS 9802200173 | |
| Download: ML20202G582 (15) | |
Text
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ENCLOSURE
~ U.S; NUCLEAR REGULATORY COMMISSION 1
- REGION IV-'
Docket No.:.70-734
)
. License No.:
SNM-696 '
Report No.:--
70-734/98-01 Licensee:
General Atomics (GA)
- Facility:
Torrey Pines Mesa and Sorrento Valiey Facilities l:
Location:
. San Diego, Califonila Dates:
January 13-16,1998 l
It: Spector:
H Dean Chaney, Fuel Facility / Decommissioning inspector Approved By:
Frank A. Wenslawski, Chief L
Materials Branch r
(
Attachment:
Supplemental Information l
9902200173 980213 PDR ADOCK 07000734 m
y '
2 EXECUTIVE
SUMMARY
General Atomics NRC Inspection Report 70-734/98-01 This routine, unannounced inspection focused on validation of the licensee's final radiological survey program and included review of eniploya qualifications, training, instrument calibration, final survey methodology, quality assuranca anc control of survey results, and implementation of the site decommissioning program. Specific attention was given to activities involving the Hot Cell Facility (HCF), Building 30 (Phase 2 release), TRIGA Fuel Fabrication Facility (TFFF), and two storage tunnels at Building 37. Limited scope confirmatory surveys were conducted in selected areas of the aforementioned buildings, by the NRC inspector.
Manaaement Organization and Controls Even though the primary health physicist for day-to-day HCF decommissioning had departed GA (December 1997), the licensee's management controls, procedures, and staffing were adequate for current decommissioning activities. The GA health physics (HP) manager has assumed day-to-day oversight of radiological activities associated with the HCF decommissioning (Section 1.1).
l Implementing procedu es for decommissioning activities were comprehensive in nature, l
properly developed and controlled, of high quality, and were being effectively used and implemented (Section 1.1).
Emolovee Trainina and Qualifications l
Decommissioning personnel possessed a satisfactory amount of experience and technical ability for their assignments (Section 1.1).
Quality Assurance (QA) and Control (OC)
The QA organization was actively involved in decommissioning oversight and assessment of activities (Section 1.1).
The licensee had implemented effective QC measures for final survey documentation and validation of results (Section 1.2).
Radio!ccical Instrument Utliization and Calibration The licensee had been using state-of the-art radiological survey instruments and utilizing techr,ically sour,d survey methodologies (Section 1.3).
The radiological calibration program met the requirements of 10 CFR Part 20.1501 and y
the guidance contained in industry standard ANSI N323,"Ra6ation Protection Instrumentation Test and Calibration"(Section 1.3).
l
4
. Licensee Final Surveys and NRC Confirmatory Survevs -
The licensee has implernented the final survey program set forth in its decommissioning -
plan. The final survey program follows the guidance contained in Draft NUREG-5849,
" Manual for Conducting Radiological Surveys in Support of License Termination" (Section 1.4).
NRC confirmatory surveys performed during this inspection were in agreement with the l
licensee's results (Section 1.4).
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.4
-Report Details Summarv of Facility Statur All production and research activities involving use of special nuclear material (SNM) have been discontinuedi By letter dated September 30,1996, the licensee submitted a Site Decommissioning Plan (SDP) which is under NRC review.-
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 GA/SDP.
Areas reviewed during this inspection involved NRO licensed activities associated with D&D st:-
' Building 23 (HCF): = Most interior walls have been remcved and the hot cells have been stripped of all penetrations, hardware, shield doors, and steel liners. The licensee was L
cleaning out the areas behind the hot cells in preparation for applying a coat of sealant
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paint to the walls and overhead for contamination control during roof removal. Licensee surveys indicated relatively low levels of contamination on the majority of interior,
surfaces within Building 23.
Beilding 22 (TFFF) has been stripped of all equipment and concrete floors have been de::ontaminated by surface abrasia y nding. Subsurface coring and soil sampling of tha teuilding footprint (including somt %. side areas) have been accomplished.. Soil contamination (enriched uranium) above current release limits was detected in several l
samples. Extensive concrete removal has been undertaken to expose the soil below the floor of TFFF for remediation and further sampling. Interior surfaces of the TFFF are free -
of residual radioactivity above release limits.
Building 30 (portions were used for gas cooled reactor fuel critical facility and radiation machines) is being decommissioned in several phases. - Phase 1 confirmatory surveys
- were discussed in NRC Inspection Report No. 70-00734/97-02. Phase 2 D&D activities -
include Rooms 104,105A,107,108,108A, iii, and 112. These rooms are considered unaffected areas by the licensee. All materials had tseen removed from the rooms and-final surveys had been performed by GA.
- Building 37 storage tunnels (east side) were used during the 1970s through the 1980s for-SNM and thorium storage, and packaged radioactive waste. The tunnels have been cleaned and final surveys obtained by GA.
Most recently the licensee's possession-only license (POL) activities and D&D program 1 attributes were discussed in NRC Inspection Report Nos; 70-734/97-05 (December 1997) and 70-734/97-02 (June 1997).
5-1-
Conduct of Decommissioning Activities
- 1.1 Manaaement Oraanization and Controls (88104) 4
- a.
Insoection Scooe The inspector reviewed and dis:
ed the current health physics organization structure, functional assignments, audits
<,edural controls, and staffing with licensee personnel to determine comp!iance with the description in Section 4 of the SDP.
b.
Observations and Findinos The licensee's organization was being maintained as described in Section 4 of the SDP.
During late December 1997, the primary health physicist for the HCF D&D left employment with GA. The GA HP manager took over day-to-day oversight of the HCF radiation protection activities. A senior HP technician currently performs supervisory functions for implementation of the radiological protection program at the HCF. The senior HP technician met the qualification guidance contained in ANSI 3.1 1981,
" Selection, Qualification and Training of Personnel for Nuclear Power Plants." The HP staff, including managers, met the qualification and experience requirements contained in Section 3 of Part II, " Specifications Volume," to the SNM license. A health phycicist l'
was added to the GA staff since the last inspection of this area. The new health physicist met the qualification and experience criteria established in the GA SNM license.
L The QA overcight was proactive and effective. Corrective actions were followed to completion and properly documented. QA managers and lead auditors appeared to-meet industry stancards (ANSI N45.2.6) for their assignments.
Selected D&D implementing procedures were reviewed and found current and adequate to implement a sound DAD program (see attachment to this report),
c.
Conclusions The licensee was effectively implementing a well documented and managed D&D program that conformed to regulatory requirements and the stipulations contained in the SDP.
1.2 D&D. QA and QC (88104) a.-
Insoection Scoce The licensee's QA and QC activities associrted with final radiological surveys were reviewed. The following document was reviewed during this phase of the inspection:
GA HP Manager Audit of" Hot Cell L wtamination and Decommissioning Project," Final Report. January 1998.
x B b.
Observallons and Findinas
- The licensee's most recently completed audit of the HCi: D&D activities was found to be comprehendve and challenging.- No safety significant findings were discic sed by the
- audit. - QA records indicated that all findings were corrected in a timely manner or are -
+ being tracked to corroletion, i
. The licensee,-in me, effort to help ensure optimum quality control over the final survey -
f
_ program, has implemented a program to have a second surveyor conduct a limited -
l confirmatory servey of areas found iree of cintamination during the 6nal survey. =This -
- QC survey is conducted and reviewed prior to finalization of the final surysy report for an j
-aresc c.
Conclusions The licensee's QA and GC activities associated with D&D are s.dequate to ensure :
compliance with SDP requirements.
1.3 Radiological Instrument Utilisation and C=% ration (88104) a.-
Inspection Scope.
' The licensee's radiologieel instrument inventory, control, calibration, selection and use programs were reviewed for agreement wi'h 10 CFR Part 20.1501 requirements and conformance guidance contained in NRC Information Notices and Circulars, and industry standards. The licensefs calibration laboratory is part of the QA 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 Meterial."
=
NRC Information Notice No. 8C 32, " 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 Instrumac "
= NRC Draft NUREG-5849; " Manual for Conducting Radiological Surveys in Support of License Termination."
- American National Standard N323-1978," Radiation Protection Instrumentation Test and Calibration."
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- NRC RAgulatory Guide 4.15, " Quality Assurance for Radiological Monitoring.
i Programs."
The licensee's radiologicai. ',de analysis laboratory, part of the HP organization, was -
inspected to determine laboratory personnel qualifications; adequacy of laboratory
! implementing procedures; availability, c:2bration, and sensitivity of radwMogical survey instruments; and QC for special media samples (soil and other solid materials).
i
- Three previously analyzed soil samples from the licensee's TFFF characterization _ phase -
- were obtained by the NRC inspector for confirmatory measurement at the NRC Region 111
- laboratory.; Four additional samples were collected, at the inspector's request, from -
areas being remediated within the TFFF (see Section 1.4, below).;.
b.
Observations and Findinos The licensee's radiological survey instrument inventory at the HCF was found to be in i
current calibration and sufficient in number for anticipated activities at the HCF.L _
-_ Licensee instrument control, calibration sources and traceability, calibration procedures, and calibration records were found adequate.1 The licensee's QC records and use procedures were thorough and current.
. Selected radiological survey procedures and licensee survey data for fixed surface -
' activity and loose activity wer: found to be well documented. All survey data reviewed were found to be complsto sad accurate. Methodologies discussed in procedures incorporated the guidance contained in NUREG-5849 and experience gained by the licensee during several other n'ajor decommissioning projects. Confirmatory surveys
. (fixed and loose alpha / beta / gamma) performed by the inspector, using NRC instruments,
- yielded results similar to those documented by the licensee.
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 radonuclide separations -
Lwhen_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 n
tracking logs were reviewed and found accurate for samples on hand. The sensitivity for various survey instruments were reviewed and found to be satisfactory for the radionuclides ofinterest.
- c.
Conclusions The licensee's radiological survey instrumentation use and calibration program was implemented in a satisfactory manner and reflected an adequate level of attention and oversight. Survey documentation was accurate and reflected a high degree of attention.
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1.4
- Licennae Final Surveva and NRC Confirmatory Survevs (88104)
- a.
Insoection Scone i-The licensee's sum y methodologies and results for selected areas within the HCF,.
- Building 30 (Phase > 2), the TFFF, and Building 37 tunnels were reviewed to determine their agreement with the methodologies contained in NUREG-584g, the licensee's SDP, 4
and the requirements set forth it 10 CFR 70.38(j).
L 1 Limited-scope confirmatory surveys (alpha, beta and gamma for fixed, loose and ambient -
gamma radiation exposure levels) of selected areas within the aforementioned buildinga were conducted by the inspector to determine the radiological status of the facilities being considered for release by the licensee.
c Several soil samples from the TFFF were collected for confirmatory measurement by the NRC Region lil laboratory.
b.
Observations and Findings (1)
Building 23 - HCF
- The NRC inspector observed workers cleaning up and packaging residual D&D materials, hot cell fixtures, and performing radiological surveys of the HCF._ The inspector discussed 'with the D&D lead engineer the attributes of the paint being
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considered for fixing surface contamination in place on surfaces within the HCF, GA engineers explained that most of the facility would be reduced to rubble and the paint would meet EPA hazardous materials regulations for disposal as a non-hazardous material when mixed with radioactivity. It was determined by the inspector that the paint
' (bright yellow type) would adequately adhere to the various surfaces of the HCF during '
- building dismemberment without releasing the underlying radioactivity, in order for 1
facility disassembly to procead, the roof (composite sheet metal and steel trusses) would
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need to be removed and structural supports for the remaining wall installed.
Various radiological surveys (general area gamma exposure rate, fixed surface activity -
l and loose surface activity, and ambient airbome radioactivity measurements) obtained by licensee personnel within Building 23 (HCF) were reviewed and found satisfactory.
. The NRC inspector performed cursory swipe and "ixed activity surveys (alpha and beta / gamma) of areas extemal to the hot cells, including the intenor side of the roof and support trusses. Ambient general area gamma e<posure rates were obtained in areas throughout the HCF, No anomateus general area gamma exposure rates or surface contamination levels were noted. Severalloose activity samples (beta / gamma and alpha) were analyzed by both the NRC inspector and the licensee with no significant differences in results noted.
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.gs All workers observed and talked to exhibited good radiological work practices and were knowledgeable of the radiological conditions within Building 23.
(2)-
Building 22 - TFFF -
During facility characterization' surveys, the licensee' identified loose enriched uranium -
. contamination in floor seams, and in some subsurface soil core samples.1 To access the
- contaminated areas below the concrete floor (4 inches thick), approximately 4 inches i adjacent to each side of each floor seam was cut out along the entire length of each seam. This resuited in exposing the underlying fill and soil. - Areas found contaminated in t
the initial sampling round were further sampled to depths up to 2 feet. All areas showing
- elevated residual radioactivity results were remediated by removal of the soil to 1 foot..
below the bottom surface of the floor. The NRC inspector observed workers excavating soil from trenches cut in the concrete floor of the facility and placing the debris in p-l-
containers for disposal as radioactive waste.
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l The licensee's Soil Sampling Plans 1 and 2 were examined and appeared to be comprehensive in nature and capable of determining the adequacy of the remediation.
The analytical results for 44 soil samples (Sampling Plan No.1) were reviewed. The.
. inspector obtained three of these samples for confirmatory analysis at the NRC Region lll laboratory. - Four additional samples were obtained by the licensee at
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locations determined by the NRC inspector. The licensee split these four samples with the NRC inspector. The four NRC samples were sent to NRC Region lli for enriched 1
uranium and cther radioisotope analysis.
. The results of the confirmatory analysis of the seven soil samples obtained during this inspection will be reported by separate NRC correspondence; this was identified as an inspection followup item (70-734/9801-01).
Soil sample preparation was performed in the counting rcom located in the access trailers for Building 23. Soil preparation facilities include ventilated preparation tables, balances, and drying ovens (standard household microwave units).- The soil sample accountability program and cross contamination prevention methods were adequate.
All areas within the TFFF were suitable for surveying.
(3)
- Building 30 The licensee's final survey plan and draft release report for Building 30 (Rooms 104, 105A,107,108,108A,111, and 112) were reviewed and fcund to address allitems contained in Appendix C to NUREG-5840 and tne specific requirements contained in 10 CFR 70.38(j).
All of the above referenced rooms within Building 30 were suitable for surveying.
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=, _ (4)-
Building 37 Tunnelsi The licensee's final survey plan for the tunnels was reviewed and no deficiencies were -
noted.
1 Upon entering the tunnels, it was determined from the erratic insults of the alpha and -
beta / gamma surface surveys that the area had elevated redon progeny levels from being closed up. The tunnels were allowed to purge for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and surveys were re-attempted. No anomalous gamma exposure rates or surface con 6 amination levels were noted during subsequent surveys. Several loose samples %we obtained from floors, drains, and walls for beta / gamma and alpha analysis. All loose samples were allowed to sit for_72 hours prior to counting. No alpha or beta / gamma residual-radioactivity was detected in any of the samples.
All areas withh the Building 37 tunnels were suitable for surveying.
(5)
General License Survey Protocols 1The inspector vertfied 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 iodide microRoentgen-instruments.
(6)
NRC Radiological Surveys The inspector performed limited-scope surveys using the following r4RC instrumentation:
Eberline E-600, NRC No. 063473, coupled to SHP-260 and SHP-360 detectors.
Due for calibration on April 20,1998.
Eberline PRM 7, NRC No. 008596, microRoentgen gamma scintillation detecte '.
Due for calibration on April 20,1998.
Background determinations were made and agreed with licensee values for similar type survey instruments. The majority of the inspector's fixed radioactivity measurements -
were made using the 100 cnf Eberline SHP-260 detector (beta / gamma) and the
. SHP-368A zinc-sulfide scintillation detector (alpha). Loose radioactivity smears were counted in the fuld using both the SHP-260 and the SHP-368A (alpha) zinc-sulfide scintillation detector.
Instrument debction efficiencies and minimum detectable levels were established using traceable tho,.am-230, uranium-234/235, cesium-137, and technetium-99 calibration sources. Minimum detectable levels were established below the residual radioactivity criteria establish by the NRC and included in Table 6-1 of the licensee's SDP, revision dated April 18,1997, as noted below.
".a-
. Alpha and Beta Emitters:
Total Activity (hed a removable surface actMey)
-1,000 dpm/100 cm', averagad over 1 trf 3,000 dpm/100 cm', maximum in 100 cnf-Removable Activity 8
200 dpm/100 cm =
1 The above guideline for thorium (in equilitx.um with radioactive progeny) is based y
. on alpha activity and was selected as a conservative guideline value in lieu of the l'
natural uranium or general beta / gamma radionuclide guideline value, which _are five. times higher, Instrument sensitivities were established at approximately 50 percent of the guideline v31ues with a 95 percent confidence value. For 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,
, General Area Gamma Exposure Rate Limit:
. Less than 5.0 uR/h above background - when measured at approximately -
1 meter (-3 feet) above surfaces / floors,
- Loose and fixed surface lata and alpha residual radioactivity measurements and
ambient. gamma radiation exposure rates (uR/hr) were obtained in the following areas
? (considered affected and nonaffected areas):
Building 30, Rooms: 104,105A,107,108,108A, iii, and 112 (no residual 1 --
- radioactivity was detected in this portion of the building by the licensee) '
Building 23, HCF general area (residual enriched uranium, strontium-89, cesium-137, and tritium contamination were identified in this facility by the y
licensee).
. Building 22, TFFF general area (residual enriched uranium identified in this facility by the licensee).
Building 37, east side tunnels (no residual radioactivity was detected in this O
portion of the building by the licensee).
- A review of the licensee's historical data on radioactive material used in the areas surveyed by the inspector showed that enriched uranium, thorium, and cesium-137 were
'previously us0d in the areas. Approximately 10 -15 smears for loose beta and alpha
12-I radioactivity were taken In each area where surveys were performed by the inspector.
No residual radioactive contamination above NRC guidelines for thorium radioactivity was detected during the inspector's surveys. This was consistent with the licensee's I
survey results obtained in the areas noted above. Specific survey results and diagrams l
obtained and used by the inspector will be placed in the Region IV license docket file, c.
Conclusions The licensee's radiological survey program had been conducted in a manner that should ensure thet residual radioactivity is significantly below applicable NRC guidelines and that no areas will be released with residual radioactivity exceeding NRC guideline values.
The licensee's final survey plan and final survey results for Building 30 (Phase 2) and 'he Building 37 tunnels were suitable for determining the final status of the subject areas and their suitability for release for unrestricted use.
2.
Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on January 16,1998. The licensee acknowledged the findings presented. The licensee did not identify as proprietary any information provided to or reviewed by tro inspector.
6TTACHMENT SUPPLEMENTAL INFORMATION
- PARTIAL LIST OF PERSONS CONTACTED Licensee K. Asmussen, Director, Licensing, Safety and Nuclear Compliance L. Gonzales,~ GA Radiation Safety Officer /HP Manager P. Maschka,' Senior Health Physicist 4
G. Branblett, Project Manager, GA D&D
- S. Ccwan, Senior HP Technician i
- l. Cruz, Health _ physicist (Laboratory) '
B. Hunter, Lead HP Technician -
P.-: Poole, Senior HP Technm' ian (contractor) l D. Keesling, GA Health Physicist (now hire) l INSPECTION PROCEDURES USED IP 88104 Decommissioning Inspection Procedure for Fual Cycle Facildies ITEMS OPENED AND DISCUSSED Opened 70-734/9801-01 IFl Review TFFF Solid Sample Confirmatory Analysis Results LIST OF ACRONYMS USED D&D:
decontamination and decommisslaning
. GA-General Atomics llCF -
Hot Cell Facility.
1 HP:
health physic::.
POL.
possession-only license
-QA; Quality Assurance QC Quality Control
- SDP
- Site Decommissioning Plan SNM special nuclear material
-TFFF-TRIGA Fuel Fabrication Facility 1
'u g
. LIST OF DOCUMENTS REVIEWED Procedure Revision Number li1[g Revision Date 1
Receipt, Pickup and Opening of Packages AG 10/97 Containing Radioactive Material 64 Procedures for Performing a Routine Wipe AB 09/97 and Meter Survey 122 Routine Duties for Health Physics Technicians AH 02/95 Assign 6d to Bldg. 23 (Hot Cell Facility) 156 Routine Duties for Health Physics Technicians AH 04/97 Assigned to Building 30 l
169 Release of Equipment & Other items to AE 08/96 Unrestricted Use 170 Quality Control in the Health Physics Laboratory AC 09/95 182 Respiratory Protection Program H
09/97
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183 Operation of the Ludlum Floor Monitor B
05/93 186 Instructions for Surveying Outside Controlled C
07/97 Areas 196 Determination of Monitoring Requirements H
12/97 500 Radiological Surveys A
03/94 502 Control of Health Physics instrumentation A
07/94 522 HCF Soil, Sample Media, Water and Vegetation A
08/94 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 t
_w
3 1006 Annt al Review of the Radiation Protection B
11/97 Progsam 1008 Filtratk.9 and Radiometric Analysis of A
03/96
. Suspenowl Solids l
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