ML20203B268
| ML20203B268 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203B257 | List: |
| References | |
| 70-0734-97-05, 70-734-97-5, NUDOCS 9712120395 | |
| Download: ML20203B268 (18) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION l REGION IV Docket No.: 70-734 License No.: SNM-696 l
Report No.: 70-734/97-05 Licensee: General Atomics (GA)
Facility: Torrey Pines Mesa and Sorrento Valley Sites Location: San Diego, California Dates: November 3-7.1997 g
Inspector:
C. A. Hooker, Senior Fuel Facility !nspector Approved By: Frank A. Wenslawski, Chief .
Materials Branch
Attachment:
Supplemental Inspection Information
~
9712120395 971204 PDR ADOCK 07000734 C PDR
2 EXECUTIVE
SUMMARY
General Atomics NRC Inspection Report 70 734/97-05 This inspection included a review of current operations, management organization and controls, radiation protection, and operator training related to the licensee's possession-only license and decommissioning activities. The inspection also included a review of the circumstances involved with a fire in a hot cell at the Hot Cell Facility (HCF) and independent surveys of selected equipment and facilities related to the fire and site decommissioning activities.
Doerational Safety Review
- Although a violation involving the failure to actuate a manual fire alarm was identified, the licensee's overall response to a fire event appeared adequate. There were no serious personnelinjuries and no appreciable release of radioactivity within the facility or to the environment (Section 1.1).
- Applicable safety systems were operational and security of radioactive materials was adequately maintained (Section 1.2).
Manaaement Oraanization and Controls
- Licensee management controls and staffing appeared adequate for providing oversight of decontamination and decommissioning (D&D) activitin The licensee's audit program appeared effective in identifying and correcting prvyam Jeficiencies (Section 2.0).
Radiation Protection
- The licensee was adequately controlling and evaluating workers' external and internal doses and personnel doses appeared as low as reasonably achievable (ALARA)
(Section 3.1).
- Equipment be!ng released for unrestricted use or landfill disposal was in accordance with the requirements of Annex C, Part ll of the bense, and the licensee was adequately controlling radioactive materials (Section 3.2).
Ooerator Trainina and Qualification
- With the exception of issues related to incipient fire fighting and training of fire watches, the license was implementing an effective training program (Section 4).
3 Reoort Details Summarv of Facility Status All production and research activities involving use of special nuclear material (SNM) have been discontinued. By letter dated September 30,1996, the licensee submitted a Site Decommissioning Plan, which is under NRC review.
Current licensed activities consist of D&D of the Building 23 HCF under an NRC approved decommissioning plan specific to the HCF. Activities in the TRIGA Fuel Fabrication Facility consisted of final decontamination efforts in preparation for the final release survey. Activities in Building 39 (modular helium reactor pilot facility)in Sorrento Valley consisted of removing equipment for either disposal as radioactive waste, release to a public landfill, or disposition to authorized recipients in preparation for D&D activities.
1 Operational Safety Review 1.1 Ooerational Event - Fire in HCF Facility Overview The HCF has been undergoing D&D for the past two years. The primary purpose of the HCF was to facilitate remote inspection of irradiated high-temperature gas-cooled reactor fuel. The inspection of other irradiated fuel and materials was secondary to this function. All accountable SNM was removed from the facility in the first quarter of 1996.
The licensee's characterization of accessible areas in the facility indicated that the primary radioactive contaminants in the facility are byproduct materials that are regulated by the State. Non-essential walls adjacent to the operating gallery have been removed.
With the exception of some exhaust ducting, remaining sections of underground drains, and isolated hot spots in the controlled machine shop (Room 108), the rooms adjacent to the hot bells and service gallery have been decontaminated. The licensee anticipates the facility will be at a condition to start roof removal operations on January 5,1998.
The hot cells within the HCF consist of a high-level hot cell (HLHC), an in line low-level hot cell (LLHC) and a small offset metallography hot cell that is mostly dismantled. The hot cell steel encased walls are made of high density concrete that ranges from 3.0 to 5.0 ft. thick. The inner dimension of the HLHC is approximately 18 ft. long and 8 ft. wide and the LLHC is approximately 9 ft. long and 8 ft. wide. A solid steel door (approximately 2.0 ft. thick) between the HLHC and LLHC is maintained in an open position to allow personnel access for D&D activities. The shield door that separated the LLHC from the in line 'decon room" and service gallery area has been removed. The service gallery stea, equipped with a set of large double doors leading to the back yard area, is used for an equipment and waste staging area. With the back doors open there is a direct view into the HLHC. Normal access to these areas is thmugh a control point located at the inside entrance to the service gallery. All of the lead glass windows, outside remote handling, and inside equipment havn been removed from the hot cells.
4 s
-4 The licensee has maintained the exhaust high-efficiency paruculate air (HEPA) filtering system which consists of a booster HEPA filtering system that discharges into the intake of the main HEPA filtering system. If the booster system becomes plugged, the air flow is automatically diverted to the malr HEPA filtering system. Each of the HEPA filtering systems is also quipped with non-HEPA pre filters. The HLHC is equipped with two in wall exhaust ducts and the LLHC has one exhaust duct where HEPA filters were installed dur!ng fuel examination operations and initial decontamination of the hot cells.
The exhaust ports are also equipped with a 20-by 20 inch metal screen spark arrestor.
The facility was never equipped with a fire detection system, but is equipped with an 2
operable wet fire sprinkler system exterior of the hot cells. The hot cells were originally equipped with a remote carbon dioxide fire suppression system that was removed prior to allowing personnel access for D&D activities.
At the time of the fire, described below, the licensee was completing its last step in removing the hot cell steel liners. This involved removing some remaining small steel plates around a light fixture near the center of the overhead in the HLHC. The licensee found that torch cutting (oxygen / acetylene) was the most effective means of removing the steel casing and inner-cellliners. The inner cellliners had been significantly decontaminated (standard cleaning methods and vacuum blasted) and were free of
, removable contamination prior to completing the task. Licensee surveys of the HLHC liner on September 27,1997, using an Eberline RM 14SA equipped with a gas flow proportional beta / gamma probe (efficiency approximately 32 percent for Sr 90), exhibited localized fixed contamination levels that ranged from S.0E3 to 3.0ES cpm. Most of the surface areas were at in-cell background levels that ranged from 2.0E3 to 5.0E3 cpm.
The hot spots were generally located in corners, seams, and ledges. The liner cutting operation was planned to avoid hot spots.
- a. Insoection Sc@e ( 88104. 93702. and 2600/003)
At approximately 11:30 a.m. on November 3,1997, while onsite, the inspector heard sirens of fire trucks approaching the site and was informed by the health physics supervisor that there was a fire in the hot cell facility. At this time the inspector diverted his attention from a routine onsite inspection to review the circumstances surrounding the event.
The review of this event included observing initial actions taken by the licensee and the San Diego Fire Department, and actions taken by the licensee following the event. The inspector also interviewed personnel directly involved with the fire; and reviewed sequences relative to the event, personnel and facility contamination survey data, facility work area air sample and effluent sampling data, selected licensee procedures, and the licensee's voluntary notification to NRC of the event (Event No. 33204).
N l.
5
- b. Observations and Findinos Gummary of Event j On the moming of November 3,1997, A worker on scaffolding was torch cutting some !
remaining steel plates in an overhead in the HLHC. He was equipped with fire retardant protective clothin:;, full leather fire protective gear, and a power assisted air purifying respirator equipped with a cutting lens. An 18 inch flexible exhaust duct used to exhaust smoke fumes was tied to the scaffolding near waist level of the worker, The exhaust duct trailed from the scaffolding along the wall onto the floor (approximately 6 ft.) and another 8 to 10 ft to the exhaust port located at the back end of the HLHC. Because the torch cutting of concrete backed steel plates created a significant amount of blow back slag, the fire watch was located at the entrance of the LLHC. The fire watch was equipped with a portable hand pump water spray unit (approximately 1 % gal.) for quenching hot slag. A portable multiple purpose "ABC* fire extinguisher was also maintained at the fire watch location. Due to the exhaust ventilation arrangement, the radiologleal work requirements did require respiratory protection equipment for the fire watch. A similar steel cutting operation was also ongoing in a room adjacent to the hot cells.
At approximately 11:20 a.m. on November 3,1997, the fire watch observed a large piece of slag fall from the ceiling and a visual check frcm his location did not identify any burning / flaming on the floor. Within a few seconds he noticed the flexible exhaust duct starting to flame at the floor INI below the scaffolding and considerable smoke being generated. The fire watch announced to personnelin the general area that there was a fire, immediately entered the HLHC with the water sprayer, and yelled to the cutter that there was a fire while spraying the flame which was rapidly spreading toward the back of the hot cell. Concerned that the fire would follow up the hose (flexible duct) and hinder the cutter's chance to escape, the fire watch pulled the non buming section of ducting from the scaffolding and tossed it toward the back end of the hot cell. At this time the work area was rapidly filling up with a black smoke. As the worker climbed off the scaffolding, the fire watch attempted to extinguish the fire with the water sprayer. Since J
the water sprayer was not putting out enough water for the existing flame, the fire watch unscrewed the cap to the sprayer and dumped the remaining water on the fire. When the worker got off the scaffolding, he and the fire watch vacated the HLHC.
While crouching low to the floor area to avoid the smoke, the fire watch re-entered the HLHC with a Class ABC fire extinguisher and attempted to put out the fire. The fire watch was joined by the area health physics technician and the worker doing steel cutting in the adjacent room who assisted in extinguishing the fire with ABC fire extinguishers. Considerable smoke had engulfed the areas inside and outside the hot cells into the service gallery. At approximately 11:30 a.m. these individuals evacuated the HCF out the back doors of the service gallery. At this time, the fire watch for the HLHC experienced nausea, dizziness, and chest conge.stion, but did not require assistance to evacuate the area. A total of 12 personnel had evacuated the building.
P ,
l
. 1 1
6 1 During the sequence of activities described above, at 11:27 a.m. the lead hot cell
- technician notified the main security office of the fire using the emergency telephone i extension. The security office immediately notified the San Diego City Fire Department who dispatched fire erigines to the site.
- By 11
- 33 a.m. the HCF Emergency Response and Recovery Director and licensee emergency response personnel from the HCF and other site locations had assembled in j front of the facility to evaluate current conditions.
At 11:36 a.m. a San Diego City fire eng!ne arrived at the HCF and a second fire engine arrived at 11:37 a.m., followed by an emergency medical services unit and two other fire engines from the County. Since the fire department was informed by the licensee that the fire had been extinguished and all personnel had been evacuated, the fire j department deferred any immediate entry into the building.
! Meanwhile, radiologica' surveys of personnel who evacuated the HCF identified a particle of contamination (300,000 dpm beta)in the hair of the HLHC fire watch which
, was removed prior to being examined by the San Diego emergency medical team.
4 Nasal smears from all individuals and personnel surveys of other persons who evacuated the HCF did not identify any other contamination.
4 An inspection by the licensee from doorways to the building determined that all of the smoke had cleared from the facility and no fire existed. Although the differential pressure (DP) gages for the pre filters on the booster and main HEPA filtering systems (located
! outside of building) were pegged (greater than 1.0 inches water), the DP across the p respective HEPA filters indicated normal DP readings, s
l Based on the assessment of existing conditions, the fire department decided not to make F an entry into the facility. At 12:09 p.m. the fire department and emergency medical services vehicle, with the fire watch, departed the site. The fire watch was taken to a medical center for further examination and overnight observation.
{ Based on the status of the facility, the licensee determined that conditions did not require .
the use of self contained breathing apparatuses for re entry in'o the HCF. However, power asslited air purifying respirators were used by the health physics staff who entered the facility to assess radiological conditions. Wipe tests revealed that the fire did not result in any spread of contamination from the HLHC. Air samples from samplers i operating during the event and the exhaust stack were exchanged and sent to the counting laboratory for analysis. The online stack monitor did not indicated any release i of radioactive material from the facility. The licensee also scheduled whole body counts 4
(counter located onsite) for individuals directly involved with the event. Accass to the i HCF was limited to personnel assessing conditions.
The licensee responded to media inquiries and notified the state of California and San Diego authorities. At 3:52 p.m. the licensee reported the event to the NRC Operations l
. Center for information only. Since the fire did not result in a threat to personnel, release of radioactive or hazardous chemicals, and did not meet any of the four classifications O
7 (unusual event, alert, site area emergency, or general emergency) in the licensee's Radiological Contingency Plan (RCP) or the reporting requirements of 10 CFR 70.50, the matter was reported for information only.
EoJ!owino the Event Except for an air sample removed from the scaffolding (worker breathing zone) in the HLHC, the gamma count indicated that none of the samples contained any detectable radiolsotopes other those in natural occurrence. The sample from the HLHC indicated some detectable Cs 137 at a concentration of 6.13E 11 uCl/ml. The derived air concentration (DAC) limit for Cs 137 is 6.0E-8 uCi/ml. Subsequent alpha / beta count results on November 5,1997, showed that the HLHC sample had a beta concentration of 6.3E 11 uCl/ml and alpha concentration of 1.5 E 12 uCl/ml. The alpha / beta counting results for the other samples respectively averaged 4.1E 13 and 3.8E-12 uCl/ml. The stack sample results were 3.18E 15 uCl/mi for alpha and 6.8E 15 uCl/mi for beta. The data indicated no appreciable release of radioactive material to the environment or within the facility.
During a tour of the HCF on the moming of November 4,1997, the inspector noted l considerable residue remained from use of the fire extinguishers. A view inside the hot l
cells from the end window port of the HLHC and small openings in covers of other windows did not reveal any evidence that fire had spread beyond the HLHC. The inspector noted the remnants of the exhaust duct consisted of the spiral steel coil and aporoximately 12 inches of the inlet end of the duct. The hot cell, essentially untouched since the fire, was void of any other items that would be considered combustible material.
The inspector also observed the licensee's inspection and changing of the pre filters on the booster HEPA filtering system which was the primary exhaust system for the HLHC at the time of the fire. The inspector noted that the DP gauge for the pre-filters was pegged at greater than 1.0 inches of water (in. H,0). The DP across the systems HEPA filters was reading 2.0 in. H,0. The DP across pre filters on the main HEPA filtering system was also pegged, and the DP for the HEPA filters was at 1.0 in. H2 0. Two masslin cloth smears (approximately 1.0 ft.8 area each) from the door opening of the pre-filters were saved for subsequent measurements by the inspector. Other than suspected soot from the fire, the inspector did not observe any signs of fire damage to the pre-filters. Following a change of the pre-filters on the main HEPA system, the inspector, at a later time, noted that the DP across the pre filters was at 0.3 in. H2 O and the DP across HEPA filters remained at 1.0 in. H,0. The licensee's inspection did not identify any fire damage to the system.
While in the HCF, the inspector took large area wipes on selected floor areas of the operating gallery area (Room 105), at the step-off-pad leading into the service gallery, and one wipe just inside the service gallery. NRC measurements with an Eberline Model 600 (NRC Serial No. 063473, calibration due October 31,1998) equipped with an SHP-380A alpha scintillation detector and an SHP-360 beta / gamma detector did not identify any detectable loose contamination. Measurements of the masslin cloth smears
l B- {
l from the booster filtering system averaged 5.065 dpm beta / gamma and 8.0E2 dpm alpha. A subsequent 30 minute gamma scan of the masslin wipes in the counting i laboratory showed Cs 37 as the primary radioisotope followed by Cs 134 and Co-60. No appreciable uranium radioisotopes were detected.
The licensee completed whole body counts for personnel directly involved with the fire, including the fire watch who had been released from the hospital with no medical restraints. Although traces of Co 60 were identified with some of the counts, there was no indication that the fire had caused any intakes of radioactive material that would require further investigation.
Initial Emeroency Resoonse issue During the initial response, the inspector did not hear an audible fire alarm at the facility.
Based on subsequent interviews with cognizant licensee personnel, the inspector was informed that the manual fire alarm at the HCF had not been actuated. The inspector was informed by HCF personnel that due to the status of the facility and noise associated with decommissioning activities, the fire alarm was barely recognizable because it is in a remote location of the facility. Licensee representatives also conveyed to the inspector that use of voice communication and manual air homs located a various work stations w6re a more effective means of notifying and evacuating personnel from the facility as was done during the fire.
The manual fire alarm system at the HCF consists of one pull station at the front entrance (south end) of the building and an audible fire alarm belllocated on the outside west wall. There are no fire alarms inside the 7400 ft? structure. The fire alarm also activates an alarm at the main security station (Emergency Support Center) whers onsite emergency response personnel are notified over a radio network and by telephone of an event. Telephone notification to offsite emergency support groups is also conducted from this location. Although the fire alarm may not be effective for all areas inside the facility, the inspector considered the device as a safety feature designed to provide immediate local and remote notification of a fire. Such alarms also provide a means of warning personnel on the outside of the facility of a potential condition and could prevent an unknown entry into a building during the initial phases of a fire.
Safety Condition S-23 of SNM License 696 requires the licensee to maintain and execute the response measures described in the Emergency Plan (Radiological Contingency Plan (RCP)) dated August 1995 and revisions thereto.
Section 10.1," Written Procedures,' of the licensee's RCP states, in part, that emergency procedures detailing the actions to be taken to implement this emergency plan will be prepared for each facility covered by the plan.
.g.
Section 11.2,' Fire in contaminated areas of HCF,' of HCF Emergency Response Procedure No. HCP-4.0 states,in part,"The proper response to a radiologically related fire at the HCF is as follows:
11.2.1 Activate the fire alarm ... and evacuate personnel frem the HCF.
11.2.2 Notify the GA Emergency Support Center ... Security Sation #1, at ...."
Although the personnel were appropriately evacuated from the facility and the security station was appropriately notified by telephone, the failure to actuate the manual fire alarm at the HCF was identified as a vlotation of Safety Condition S 23 of the license (70-734/9705-01).
Other issues The inspector also identified two other issues relating to training and qualification of fire watches (see Section 4 below).
Licensee Followun Since the licensee had not completed its investigation, the inspector informed the licensee that a subsequent NRC inspection would independently assess the licensee's evaluation of root cause(s) of the event, corrective actions, and overall event analysis.
The inspector also informed the licensee that it would be expected that any issues, in addition to root cause(s), identified during the investigation be addressed as well NRC's review will also include a determination of any similarities in causes associated with a fire that occurred in the LLHC on October 11,1996. The results of NRC's review will be documented in a subsequent inspection; this was identified as an inspection followup item (70-734/9705 02).
- c. Conclusions Although a violation involving the failu'e to actuate a manual fire alarm was identified, the licensee's overall response to the fire event appeared adequate. There were no serious personnelinjuries and no appreciable release of radioactivity within the facility or to the environment.
1.2 Other Facilities
- a. Insoection Scoos (88104. 88020. and 2600/003)
The inspector toured selected facilities with cognizant licensee personnel at the Torrey Pines Mesa (main site) and Sorrento Valley sites to discuss and observe ongoing activities.
10-
- b. Observations and Findinos Activities in Building 39 consisted of removal of non essential equipment in preparation for D&D, The current SNM inventory is primarily limited to assay standards containing less than 150 grams of U 235. An operable criticality accident monitoring system was being maintained until an appropriate assessment can be made of any potential SNM in the exhaust ventilation systems. The HEPA exhaust filtering systems and fire sprinkler system were maintained in an operable status. Housekeeping appeared very good.
In the TRIGA Fuel Fabrication Facility, the licensee was in ihn final stages of D&D.
Except for short sections of ducting extending through the wall to the operating HEPA filtering system, all of the inside exhaust ducting had been removed from the facility. The licensee had made cuts along each side of the seams in the cement floor for subsequent removal to facilitate soll sampling under the building. The licensee was performing preliminary contamination measurements in the overhead and establishing survey grids in preparation for a final release survey planned for February 1998.
There were no ongoing activities in the main site SNM vault. The current predominate inventory of SNM continues to be TRIGA fuel rods loaded in shipping containers. The licensee has experienced difficulty in obtaining foreign authority approval of the shipping packages but expected approval in the near future. The inspector noted that SNM materials were stored in accordance with the licensee's criticality safety analysis and license requirements, and the criticality accident monitoring system was fully operable,
- c. Conclusions Applicable safety systems were operational and security of radioactive materials was adequately maintained.
2 Management, Organ'zation and Controls
- a. Insoection Seone (88104 and 88005)
The inspector reviewed and discussed current organiza'. son and staffing with licensee personnel. Records of quarterly health physics (HP) audits / inspections for the past year, and the licensee's 1997 annual Criticality and Radiation Safety Committee (CRSC) audits of the HP and nuclear safety program:,were reviewed and discussed with licensee personnel,
- b. Observations and Findinas The inspector noted that the management organizational structure was consistent with Figure 113.1-1 Part 11 of the license. The inspector noted that an individual who performed second-party reviews of criticality safety analyses (CSAs) and a member of the CRSC had transferred to an out of state organization. Since there have been no new CSAs for the past 2 years, and due to the current status of the site, the licensee does not envision having the need for new CSAs in the future. Although not designated
11-as a second party reviewer, another onsite person met the qualifications should the need for a second party review arise, or the service could be contracted. The vacancy in the CRSC was filled by the health physics manager. No concerns were identified relative to these changes. The health physics group had added several new qualified health physics technicians and a health physicist to its staff to support onsite D&D activities.
The CRSC audits were conducted during April through June 1997. The audits included an evaluation of the HP and nuclear safety programs, and related site operational activities (possession only license status, D&D at the hot cell facility, and preparation for D&D at other facilities). Quarterly HP audits / inspections adequately evaluated activities.
There were no significant safety concerns identified by the licensee's audits. Corrective actions for licensee identified deficiencies appeared adequate. Licensee audits were consistent with Section 3.6," Internal Inspection and Audits," Part 11 of the license, in addition to the license specified audits, the HP department was also in the process of performing its annual review of the radiat!on protection program, as required by 10 CFR 20.1101(c).
In addition to the review of the above audits, on November 5,1997, the inspector attended a quality assurance (QA) audit exit meeting being held with HCF management personnel. This recent audit was conducted to verify that the HCF was adequately implementing its QA requirements for D&D activities. The audit appeared to be performance based and concluded that the program at the HCF was functioning well, and the QA program for D&D activities was being effectively implemented. There were no findings identified requiring formal corrective actions. Some minor, isolated administrative errors were identified involving recording of proper instrument calibration dates on survey forms, which were subsequently corrected. Closure of previous audit findings were also discussed. Although not part of the audit, the QA spokesman informed the HCF management personnel that the QA department will be involved in the
' Operation Readiness Review" committee planning for removing the roof of the HCF starting on January 5,1998.
Work authorizations were current and the associated operating procedures had been revised to reflect current operations at each facility. The procedures adequately addressed the criticality safety requirements for removal, assembly, and storage of equipment,
- c. Conclusion Licensee management controls and staffing appeared adequate for providing oversight of D&D activities. The licensee's audit program appeared effective in identifying and correcting program deficiencies. .
-12 3 Radiation Protection 3.1 Extemal and Internal Exoosure Control
- a. insoection Scone (88104 and 83822)
The inspector discussed extemal and intemal exposure controls with licensee personnel and toured Ikensee facilities to observe ongoing activities. The inspector reviewed selected records of air sampling data for the past 3 months and quarterly vendor thermoluminescent dosimeter results from January 1 through October 31,1997.
- b. Observations and Findinas Due to reduced site activities during the past 3 years, internal and external exposures continued to be minimal. The licensee's evaluations have determined that even without the use of respiratory protection, including the HCF, workers were unlikely to receive intakes of radioactive materials from D&D operations that would exceed 10 percent of the applicable annual limit of intake specified in Appendix B of 10 CFR Part 20. Other than the HCF, DAC-hours are not tracked. However, the HCF, where byproduct material is the dose contributor, continues to track DAC bours to ensure the adequacy of its evaluation.
Air sarnple data for combined NRC and state licensed materialindicated that airborne radioactive materials were normally well below 10 percent of the applicable limits listed in 10 CFR 20, Appendix B, Table 1, Column 3. T.he h!ghest cumulative internal exposure for any one individual at the HCF through August 1997 was O.5 DAC hours.
With increased activities in Building 39 in preparation for D&D, the licensee had re-implemented a monthly urine bloassay sampling and annuallung count program for uranium. Lung counts of nine workers on February 26-27,1997, evidenced no measurable uranium intakes Monthly urine sample data since March 1997 indicated no worker had received a measurable intake of uranium. Air sample data for Building 39 indicated that the alpha constituent consistency averaged less than 0.1 percent of the DAC limit for U 235.
Regarding external exposures, the maximum individual deep dose equivalent from external exposure through October 31,1997, was 0.420 rem. This exposure was associated with D&D activities at the HCF where the external exposure contributor is byproduct materiallicensed by the state. The maximum deep dose equivalent exposure for personnel at Building 39 was 0.03 rem.
The licensee's respiratory protection program was adequately addressed in licensee procedures. The licensee maintained procedures for cleaning, inspecting, and issuance of respiratory protection equipment. The inspector noted that respirators were primarify used only at the HCF. Training, medical qualification, and fit testing were consistent with licensee procedures and the requirements of 10 CFR 20.1703.
i
- c. Conclusions The licensee was adequately controlling and evaluating external and intomal exposures, and personnel exposures appeared Al. ARA.
3.2 Control of Radioactive Materials and Survevs
- a. Insoection Scone (88104 and 83822)
Work activities, radiation waming postings, and controls were observed during facility tours, independent NRC surveys were conducted of materials being released from Buildings 27 and 39 to evaluate the licensee's implementation of Annex C," Guidelines for Decontamination of Facilities and Equipment Prior to the Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material,"
Part il of the license. At the time of the inspection, the HCF did not have an accumulation of equipment being released for unrestricted use. The independent surveys were performed using the NRC survey equipment described in Section 1.1 above,
- b. Observations and Findinos Buildina 27 (Chemistrv Laboratories)
The licensee has been in the process of removing laboratory equipment and selected intemal structural items in preparation for final D&D activities. This material has either been packaged for radioactive waste disposal, transferred to authorized recipients, or released for disposal at a local landfill, A survey for loose and fixed surface beta and alpha radioactivity was performed of accessible items collected in a trash bin for ultimate disposal at a locallandfill. No residual radioactive contamination above NRC guidelines was detected during the j inspector's survey. s Buildino 39 Essentially no process equipment remained in the facility. Current activities continue to
- involve removal of nonessential equipment either for radioactive disposal, release for unrestricted use to other organnations, or disposal at a local landfill. The licensee's L survey data indicated that all of the general work areas in the facility were free of loose radioactive material.
A survey for loose and fixed surface beta and alpha radioactivity was performed of two air conditioning units, a pre filter for one of the air conditioners, and a space heater that had been released from within the facility for unrestricted use or clean disposal. No i
residual radioactive contamlaation above NRC guidelines was detected during the inspector's survey. The inspector also took large area masslin cloth smears of what had
l l-
- 14 2
l been the major process area during fuel fabrication. No measurable beta or alpha activity was detected.
Other ObservatlQns A review of recent material release logs located at Buildings 27 and 39 indicated that adequate radiological surveys were performed on equipment removed from the facility.
The survey data indicated that items dispositioned for unrestricted use were well t.elow the release limits specified in Annex C, Part 11 of the license. ,
During facility tours, the inspector observed that personnel were dressed in appropriate protectivi clothing. Survey instruments in use appeared operational and within respective current calibration periods. The inspector also noted that radioactive materials and radiation areas were posted in accordance with 10 CFR Part 20.
- c. Conclusion The inspector concluded equipment being released for unrestricted use or landfill disposalwas in accordance with the requirements of Annex C, Part ll of the license, and the licensee was adequately controlling radioactive materials.
4 Personnel Training and Qualification
- a. insoection Scoce (88104 and 88010)
The inspector reviewed snd discussed the applicable licensee training programs with cognizant licensee personnel, reviewed records of training, observed ongoing activities, and held discussions with selected personnel,
- b. Observations and Fird!ngs New employee and refresher training had been provided to radiological workers commensurate with their assigned work areas in accordance with the requirements of 10 CFR 19.12,' Instruction to Workers,' and Section 3.3.5,' Training
- Part ll of the license. The training included applicable elements of RG 8.29, ' Instructions Concerning Risks From Occupational Radiatien Expose,' Revision 1, and Draft RG DG-8014,
' Instruction Concerning Prenatal Radiation Exposure." Personnel assigned to work .
where SNM is stored or may be handled during D&D had received initial and refresher l training in accordance with the requirements of Section 3.3.5, Part II, of the license and ,
the guidance provided in ANSI /ANS-8.20-1991, ' Nuclear Criticality Safety Training.' l Following each training class, all employees were tested to evaluate their knowledge of ;
the material presented. 1 Relative to the fire at the HCF described in Section 1.1 above, the inspector identified two issues related to training:
15 (1) The licensee's emergency response procedures describe an inciplent fire as the initial combustion of a fire occurrence, contrast with a ' free burning fire.' An incipient fire is a fire that is observed, by hot cell personnel, either at the start, or in its early stages. Occurational Safety and Health Administration requirements in 29 CFR 1910.155(c)(26) of Subpart L, Fire Protection, state that,
- incipient stage fire' meanti a fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire exthguishers ... without the need for protective clothing or breathing apparatus.'
The licensee's procedures describe combating only incipient fires. The inspector considered the fire watch's initial response to alert the worker on the scaffolding of the imminent danger and the attempt to extinguish the fire as being appropriate. However, the fire dr ig the reentry into the HLHC to extinguish it could be viewed as beyond the incipient stage. Although the fire watch was not ovetwhelmed by the smoke, the reentry into a sinoke filling atmosphere, without the use of adequate respiratory protection such as a self-contained breathing apparatus, provided the potential for such an event.
(2) In July 1997, the licensee hired and trained two individuals as General Atomics employees primarily to be fire watches for D&D activities. The torch cutting operation was being done by four workers (millwrights) supplied by a contract firm Due to changes 6 work hours, and to provide some relief from fatigue of continuous cutting operations, it became a practice of the cutters to alternate among themselves as fire watches and cutters. The two General Atomics employees hired as fire watches were assisting in other D&D activities.
Of the four millwrights, the inspector noted that the fire watch who initially responded to the fire and another individual had received fire protection training, including hands on training, during a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 'HAZWOPER' training course sponsored by the licensee within the past year. One of the individuals who started work onsite in September 1997 stated that he had received fire protection training, including hands on training, during the past year while working at a local nuclear power plant during an outage. However, the licensee did not maintain any documentation to substantiate the training. One worker who had been onsite at various frequencies during the past 2 years stated that he had not received any spec'alized fire protection training.
Occupational Safety and Health Administration requirements in 29 CFR 1910.252(a)(iii)(B) of Subpart Q, Welding, Cutting and Brazing, requires that fire watches shall have fire extinguisher equipment readily available and be .
trained in its use 29 CFR 1910.155(c)(41) of Subpart L, Fire Protection,. states that ' training" means the process of making proficient through instruction and hands-on practice in the operatien of equipment, including respiratory protection equipment, that is expected to be used and in the performance of assigned duties. 29 CFR 1910.157(g)(1) and (2) of Subpart L, Fire Protection - Portable Fire Suppression Equipment, requires that where employers provide portable fire extinguishers for employee use in the workplace, the employer shall also provide
an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting upon initial employment and at least annually thereafter.
Relative to the above issues, on November 6,1997, the HCF industrial safety engineer conducted a fire safety class for the four workers and scheduled a hands on training session for November 12,1997. Elements of the training class included: a review of the requirements of welding-burning-grinding permits used at the HCF, how fires start, how ;
fires are classified, how to prevent fires, when not to fight fires, fire extinguisher types and use, and other basic elements of personal safety during a fire.
With the exception of the above issues concerning the fire watches, personnel assigned to a facility under a work authorization received training commensurate with their work assignment. This training included, but was not limited to, general operating and safety requirements, materials and equipment removal, radioactive and hazardous waste handling and packaging, waste shipping requirements, and facility emergency I procedures.
At the HCF, the inspector observed a hazard communication training class provided by the HCF industrial safety engineer for personnel expected to be involved with removal of lead shot from shield plugs. The training included a review of a hazardous work authorization permit which provided a description of the procedure for the task, health hazards associated with lead, and precautions for handling the material. The training adequately covered the work instructions and safety requirements for the task.
Based on discussions held with operators / technicians and observations during facility tours, the inspector did not identify any cause to suspect the qualification of personnel performing their assigned task.
- c. Conclusion The issues related to incipient fire fighting and training of fire watches appeared to be an isolated matter. Overall, the license was implementing an effective training program and personnel were knowledgeable of the safety requirements of their assigned tasks.
Exit Maeting Summary 1he inspector presented the inspection results to members of licensee management at the conclusion of the inspection on November 7,1997. The licenses acknowledged the findings presented.
Although proprietary information was reviewed during this inspection, such inform ation is not knowingly described in this report.
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1 ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee L. K. Alfonso, Corporate Industrial Hygiene and Environmental Science i K. E. Asmussen, Director, Licent,ing, Safety and Nuclear Compliance V. J. Barbat, Manger, Engineering and Maintenance, Hot Cell Decommissioning G. C. Bramlett, Manager, D&D Project
, L. R. Gonzales, Manager, Health Physics J. S. Greenwood, Principallnvestigator, Hot Cell Facility H. A. Kleinsorge, Security Administrator
- B. Laney, Licensing Engineer
- P. R. Maschka, Supervisor, Health Physics j R. Rao, Manager, Corporate Safety j J. M. Sills, Manger, Health Physics, Decommissioning Project l C. L. Wisham, Manager, Nuclear Materials Accountability 1 J. Yi, Manager, Nuclear Safety
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-lNSPECTION PROCEDURES USED
, IP 83822: Radiation Protection i IP 88005: Management Organization and Controls IP 88010: Operator Training / Retraining j IP 88020: Operation Review IP 93702: Prompt Onsite Respon:e to Events at Operating Power Reactors IP 88104: Decommissioning Inspection Procedure for Fuel Cycle Facilities
$ ITEMS OPENED AND DISCUSSED Ooened
. 70 734/9705-01 VIO Failure to actuate a manual fire alarm 70-731/9705-02 IFl Review of licensee's investigation of a fire in the HLHC
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- . 2 I 1 LIST OF ACRONYMS USED !
.' Al. ARA - as low as is reasonably achievable ,
CRSC Criticality and Radiation Safety Committee
-CSA_ criticality safety analysis DAC- derived air concentration
, D&D decontamination and decommissioning i DP differential pressure 4 HCF Hot Cell Facility
, HEPA high-efficiency particulate air HLHC high level hot cell ;
i ~ health physics
- HP LLHC low level hot cell
, QA- quality assurance j RCP Radiological Contingency Plan ;
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