ML20203P068
| ML20203P068 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 04/29/1986 |
| From: | Brock B, Ketzlach N, Pang J, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20203P060 | List: |
| References | |
| 70-0734-86-04, 70-734-86-4, NUDOCS 8605060312 | |
| Download: ML20203P068 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-734/86-04
. Docket No.70-734 License No. SNM-696 Safeguards Group 1 Licensee: GA Technologies, Inc.
P. O. Box 85608 San Diego, California-92138 Facility Name: Torrey Pines Mesa and Sorrento Valley Sites Inspection at:
San Diego, California Inspection Conducted: March 17-21 and March 31 - April 2, 1986 2
Inspectors:
B. L. Brock, Fuel Facilities Inspector Date Signed T. F. 9 4 -W-tc, J. F. PanfQ Radiation Specialist Date Signed
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. Ketzlach, Project Pfanager, NMSS l! fate Signed Approved by:
[f R. D. Th'omas, Chief Dat'e Si'gned Nuclear Materials Safety Section Summary:
Inspection on March 17-21 and March 31-April 2, 1986 (Report No. 70-734/86-04)
Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls, operator training and retraining, criticality safety, operations review, radiation' protection, transportation of radioactive materials / radioactive waste management and emergency preparedness.
During this inspection the procedures covered were 88005, 88010, 88015, 88020, 83322, 86740/88035, and 88050.
Results: A violation was identified in one area (Section 5.A.(6)).
No violations were identified in the remaining seven areas inspected.
Mr. Ketzlach participated in the inspection from ~ March 31 to. April 2,1986.
His emphasis was placed on criticality safety.(88015) with some attention
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directed towards criticality safety aspects of management organization (88005), operator training (88010), and operations review (88020).
8605060312 860430 PDR ADOCK 07000734 C
. DETAILS 1.
Persons Contacted
- R. A. Dean, Senior Vice President, Reactor Programs
- R. A. Wolf, Secretary, GA-Technologies
- J.
P. Hogan, Senior Counsel
- R. N. Rademacher, Director, Human Resources
- K. E. Asmussen, Manager, Licensing and Nuclear Material Control
- R. C. Noren, Director, Nuclear Fuel Fabrication F. O. Bold, Manager, Health Physics and Safety W. Whittemore, Physicist In-Charge, Triga Reactors A. Baxter, Manager, Core Nuclear Design and Analysis
- R. P. Vanek, Manager, Fuel Production Department
- V. Malakhof, Manager, Nuclear Safety (incoming)
- M. H. Merrill, Manager, Nuclear Safety (outgoing)
B. Pound, Consultant (former Manager, Nuclear Safety)
- L.
R. Quintana, Supervisor, Health Physics
- P.
L. Warner, Manager, Fuel Production and Inventory Control
- R.
I. DeVelasco, Staff Engineer, Core Engineering
- A.
L. Galli, Manager, Security T. Crockett, Staff Scientist H. O. Johnson, Manager, Hot Cells
- R.
K. Krueger, Supervisor, Triga Fuel Production J. M. Brock, Supervisor, Emergency Services J. M. Narvaez, Medical Coordinator R. J. Cockle, Health Physics Technician J. Keith, Health Physics Technician M. N. Johnson, Health Physics Technician K. Thompson, Health Physics Technician E. L. Spencer, Environmental Technician J. Tremble, Health Physicist W. Mowry, Consultant (former Licensing Administrator)
Denotes those attending at least one of the two exit meetings.
Denotes those attending both exit meetings. The second exit meeting developed from the followup inspection with the NRC's Project Manager (FCUF) for this licensee participating at Region V's request.
2.
Management Organization and Control License Condition 9 of SNM-696 incorporates the statements, representations and conditions specified in Part II - License
-Specifications as part of the license.
A.
Organizational Structure Section 3.1 of Part II - License Specifications permits the licensee to change organizational responsibilities, reporting locations and names, providing such changes do not adversely affect the
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implementation of license conditions and are reported to the NRC within sixty days after the change.
The licensee's organization structure and appointments approved by NRC on January 8,1986 have undergone significant revision since their implementation. Appointments were changed because several appointees decided to retire as a result of an improved retirement incentive recently offered by the licensee. The organization and personnel changes coupled with the Region V inspector's concern for a questionable criticality safety aspect of recent process planning (see Section 4.D.) warranted a followup inspection with the participation of the NRC's Project Manager for this licensee.
B.
Procedure Controls Section 3.7.2 of Part II - License Specifications requires procedures for all activities in which materials subject to this license are physically handled, stored, and chemically or physically changed.
The inspector reviewed the work authorization system used by the licensee. The licensee's practice is to list all individuals requiring access to a given facility on the work authorizations regardless of whether or not an individual uses licensed material.
The licensee was informed that the work authorization specifically permits all individuals listed to use licensed material and the use of these authorizations for any other purpose would defeat the effectiveness of such controls.
The licensee was requested to review all work authorizations and to revise the procedures so as to ensure that all persons listed are users of licensed material (86-04-01).
C.
Internal Review and Audit Section 3.6 of Part II - License Specifications requires that health physics inspections be conducted quarterly and nuclear safety inspections (see Section 4.B(1)) be conducted at least annually for all areas possessing SNM and at least quarterly for areas possessing more than 500 grams of SNM.
'(1) The inspector reviewed the licensee's health physics and nuclear safety inspections. The licensee's inspections were conducted as required and were appropriately documented.
(2) The licensee's documentation included an incident wherein during the normal course of collecting air sample filters the Health Physics Technician (HPT) in SV-A noted that repair work not covered by a radiation work permit had started in the south mezzanine area. The HPT notified the Supervisor, Health Physics who called the Manager, Equipment Engineering and arranged work stoppage until the required radiation work permit or work authorization had been submitted, reviewed, and approved. This violation was not cited by NRC because the
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licensee identified the viol'ation, responded expeditiously and-is currently meeting the guidance in Part 2, Appendix C, IV.A.
relative to licensee's actions following their identification
- of a violation. The effectiveness of the licensee's corrective L
action in precluding recurrence will be reviewed during the next inspection (86-04-02).
D.
Safety Committees Section 3.2.3 of Part II - License Specifications requires that the Criticality and Radiation Safety Committee (CRSC) report to the Office of the President via a designated Vice President. The CRSC shall~as a minimum:
(1) act in a radiological safety advisory capacity; (2) review policies and criteria established for safety of SNM operations; (3) provide second level of review for nuclear safety analysis; (4) audit work involving radioactive materials for conformance to and effectiveness of applicable procedures and practices including a review to determine how exposures might be reduced to meet ALARA.
The CRSC membership, formerly appointed by the CRSC Chairman, is now
- appointed by the Executive Committee. Three appointments, effective March 25, 1986, were made to replace committee members who recently retired. -The inspectors interviewed the appointee who replaced the CRSC's former second level reviewer of criticality safety analyses.
The second level reviewer must also meet the requirements for the position of Manager of Nuclear Safety. The interview indicated that the appointee appeared to meet the requirements for a second level reviewer; however, the NRC Project Manager is waiting for the formal
- submittal of the appointee's resume before completing his evaluation.
The chairman of the CRSC indicated that the second party reviewers visited the processing areas frequently during their second level reviews. However, the NRC Project Manager pointed out that he was concerned that the licensee's recent corrective actions were in response to the Region V inspector's identification of the potential problem and not in response to the licensee's internal quarterly criticality safety inspection, actually done monthly, or the pre-startup criticality safety inspection. He also indicated that during the inspection a criticality control limit sign (10,000 grams U-235) put up since the previous NRC inspection was mounted in a poor location. The sign applied to the two five inch diameter horizontal storage tanks mounted along the upper portion of the south wall of the SV-B building. However, the-sign's location was
-consistent with the sign also being applicable to a 55 gallon drum when it would be brought to the drum filling location which was adjacent to the sign. The NRC Project Manager voiced concern that the licensee appears to be losing depth in the ability to assess the practical aspects of the fuel fabrication process. Region V agrees that the licensee needs to increase the amount of attention given to the possibility of human errors being made while running the process. The adequacy of the licensee's criticality safety inspections will lue carried as an open item (86-04-03).
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No violations were identified.
3.
Operator Training Section 3.2.2.1 of Part II - License Specification states that on-site radiological safety training will be conducted.
The authorized users listed on Work Authorizations No. 2647 and 2659 for the North Warning System (NWS) kernal fabrication and Triga Fuel Fabrication were reviewed to determine if they had received annual refresher training in 1985.
It was determined that two individuals from each group had not received annual refresher training. However, only one of the few individuals was an active user of licensed material. For this reason this was not cited as a violation. Never-the-less the inspector pointed out that the licensee should establish a management control procedure to ensure that all users requiring annual refresher training will receive such training (86-04-04).
No violations were identified.
4.
Criticality Safety Section 3.2.2.2 of Part II - License Specification requires assurance of nuclear criticality safety through review of proposed SNM activities and review of proposed changes in processing equipment and procedures.
It also requires frequent inspection and monitoring to assure adequate nuclear safety control.
Independent verification of all determinations of criticality limits are also required.
A.
Nuclear Criticality Safety Analyses The licensee's nuclear criticality safety analyses for the coating and rod manufacturing process are in the review process.
B.
Audits Of particular note is that the information developed by the inspectors during this inspection is consistent with a loss of depth by the licensee in experience needed for evaluating the practical aspects of the fuel fabrication process (Section 2.D.).
The information that the Manager of Nuclear Safety spent time reviewing the process in support of his second level reviews when he was a member of the CRSC underscores the need for a broader scope in reviewing the fuel fabrication process.
It appears that additional attention needs to be given to the practical aspects of the process to preclude oversight of human errors which in the past have contributed significantly to the historical criticality accidents.
C.
Criticality Monitoring System The Criticality Warning Alarm System (CWAS) procedures for scheduled maintenance and testing had been issued. The Building 37 CWAS is scheduled for a modification that will reduce channel interaction and the resultant nuisance alarms.
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5 D.
Procedures (1) The procedures prepared for the processing in Room 142 of SV-B Building have been reviewed and approved through the licensee's procedure approval process. A manual of procedures is maintained in Room 142 as well as in the project manager's office. The inspector noted, however, that a procedure had not been prepared for the low level liquid waste stream that was being accumulated in 11 liter favorable geometry bottles. The inspector became especially concerned about the lack of a procedure for this waste stream because other indistinguishable 11 liter bottles containing high level uranium feed solution were stored in the same area (along the east wall of Room 142).
The low level liquid waste disposal options discussed in response to the inspector's questions were not acceptable with regard to criticality safety. The inspector discussed the problem separately with the Director, Nuclear Fuel Fabrication, the licensee's Project Manager, the Manager Nuclear Safety, and the Manager, Licensing and Nuclear Material Control.
The problem was identified as an open item in the exit meeting held March 21, 1986.
It was emphasized during the exit meeting that handling the problem as an open item did not convey the high concern NRC had about the licensee's need to expeditiously assess the problem, correct it, and take steps to preclude its recurrence. The inspector pointed out that the licensee had not yet made a commitment to use the shielded facility and favorable geometry locked sink readily available in SV-A Building. The SV-A system had been designed and built to resolve a similar problem in that plant a few years earlier.
Procedures existed for the SV-A system although the plant had been inactive for the past year and restart was not planned for about another two years. When the Region V inspector returned a week later with the NRC Project Manager from Washington, D.C., the licensee had already implemented most of the corrective actions. The licensee had:
(a) commited to using the SV-A favorable geometry sink and shielded facility for the 11 liter waste bottle dumping, (b) distinctively color coded shoulders and caps of the 11 liter low level liquid waste bottles with black paint, (c) precluded dumping of 11 liter bottles into 55 gallon drums or the non-favorable geometry sink by administrative decision (a sign to this affect was being made for the sink),
(d) the procedure for transfer of the 11 liter waste bottles to SV-A was already in draft form and was being reviewed, and (e) the new criticality limit sign with a lower process limit of 200 grams U-235 for the horizontal 5 inch diameter waste storage tanks was ordered.
6 A second potential problem identified by the inspector involved the possible precipitation of ammonia diurinate (ADU) in the basic solution in the 5 inch diameter horizontal waste storage tanks. The licensee's corrective action of precluding the dumping of any 11 liter bottles in the sink. effectively eliminated the addition of any solutions containing significant uranium concentrations into the horizontal waste storage tank system.
To prevent recurrence of this kind of problem the Manager of Nuclear Safety is considering asking that requests for nuclear criticality safety analyses for processes include an outline of the process including all waste streams. The licensee's action to preclude recurrence will be reviewed during the next inspection (86-04-05).
(2) The inspector reviewed the licensee's controls to preclude back flow of uranium bearing solutions to non-favorable geometry containers. The back flow paths were controlled by check valves, ball flow meters, and metering pumps. These devices plus the 2000 micron particle size preclude accumulation of the uranium bearing particles in the non-favorable geometry l
containers.
1 (3) The new larger feed tank was installed on the first floor rather than the elevated platform. The tank is effectively isolated from the processing columns by distances greater than the required twelve inches. The feed tank is heated through use of a non-favorable geometry tank. A cover on the tank protects it against the accidental entrance of uranium solution. The constant temperature baths in the process involve coil wrapped vessels where the controlled temperature solution traverses coils to perform its function. The solution is heated in a covered reservoir of non-favorable geometry.
No violations were identified.
5.
Operations Review Section 3.2.1 of Part II - License Specification requires that the licensee's organization conduct their respective activities within federal, state, and local rules and regulations, license criteria, and company e.licy, criteria and established practices.
c A.
Conduct of Operations (1) The SV-B fuel production started in the first quarter of 1986.
Prior to startup, the licensee had corrected seven of the ten open items. One of the three remaining open items involved 11 liter bottle control in SV-B operations (see Section 5.D.).
The other two items related to holdup in the grinder in SV-A (84-04-08) and classification of a hot cell waste drum (85-09-01). The first phase of the SV-B production is expected now to run through July 1986. The next phase would run
7 considerably longer. The licensee stated that a license amendment application would be submitted for review and approval by NRC because the development level' process would have moved up to a production level process. The licensee stated that this project had been discussed with licensing and inspection and enforcement representatives of the NRC in Washington D.C. in June 1985. Of note also was the licensee's actions on SV-B open items as follows:
(a) The licensee's surveys of the SV-B processing area resulted in setting up a controlled area boundary within Room 142 and adding a stepoff pad including equipment for self monitoring on an adjacent table. This action closes item 85-16-07.
(b) The licensee's inert bottle filling station incorporates an inline pressure gauge that would facilitate identifying a leak in the valve on an inert container. This system is equivalent to the upgraded system put in place in SV-A after the violent rupture of a container of uranium thorium dicarbide which had not been adequately inerted.
The use of this upgraded system closes item 85-16-02.
(c) The inspector observed that the licensee had repaired the exhaust system flexible connectors thus closing item 85-16-03.
(d) The licensee also improved the exhaust system sample tubing. This action closes item 85-16-04.
(e) The inspector observed that the East filter bank magnehelic gauge confirmed that the licensee had also completed the East filter bank HEPA filter replacement.
This closes item 85-16-05.
(f) The inspector's interview with the Director, Nuclear Fuel Fabrication clarified that incident investigations are required for serious events in operations. The loss of vacuum in the induction furnace from a small coolant leak was considered a minor problem incidental to operations.
Item 85-16-06 is therefore closed.
(2) The Triga fuel production operations are still at a low level.
(3) The Hot Cell is currently operating. A post irradiation examinations (PIE) is being made on an HTGR fuel block containing cured-in place rods.
(4) The Sr-90 bunker, outfitted with shielded glove boxes, is used to separate Y-90 for medical research. This project is under the jurisdiction of the State of California.
(5) The Nuclear Waste Processing Center (NWPC) has processed little waste for shipment since shipping out the waste backlog prior
8 to the last inspection. Recently, liquid vaste disposal activities have been directed toward preparation of oils for disposal by absorption on various materials. Additionally, a portion of Building 41 is being prepared for use by the NWPC for waste processing. The safety systems put in place for the new waste processing area will be reviewed during the next inspection (86-04-06).
(6) The licensee has reduced activities at various locations in the facility. To accomodate the licensee's reduction of sctivities, License Condition 29.c authorizes the licensee to reduce the radiation safety requirements subject to the provision that all openings of ventilation ducts and enclosures which are not completely sealed shall be maintained with a minimum air flow of 25 LFM. The licensee shall determine at least on a semi annual basis, that this minimum air flow is maintained. During the tour of the facility it was observed that the licensee was not in compliance with this license condition. This was cited as a violation.
(7) The inspector reviewed the licensee's isokinetic sampling of stack effluents during the inspection. There are sixteen stack effluent discharge points from the licensee's facilities. The in place isokinetic sampling nozzles at these discharge points had been sized based on discharge rates associated with past activities. Since the activities at the various facilities have changed, the licensee was requested to verify that the-current discharge flow rates do not differ significantly from the flow rates for which the sampling nozzles had been designed (86-04-07).
The inspector's review of the weekly stack effluent monitoring results, collected since the last inspection, found that the stack effluents are approximately 1-2% of the maximum permissible concentrations (MPC).
One violation was identified.
6.
Radiation Protection Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.
A.
External Exposures The inspector reviewed the licensee's records of radiation exposure for the 4th quarter of 1985. No Part 20 exposure limits had been exceeded. The maximum annual whole body and extremity exposure under this license were 1240 mrem and 2000 mrem respectively. The average radiation exposure received in 1985 is approximately 750 mrem. The licensee had also complied with the reporting requirements of 10 CFR 20.407 in a timely manner.
B.
Lung Counts
9 The inspector also reviewed the semi-annual lung counts that were conducted during February, 1986.
All employees counted had non-detectable lung burdens. The only person showing a positive lung count was a former employee who had retired in July,1985.
He had been called back to repeat a lung scan.
He had a lung burden of approximately 25% of the maximum permissible lung burden (MPLB).
C.
Bioassay Results The inspector reviewed urinalyses results for the fourth quarter.
All urinalyses results for this period were negative.
D.
Surveys Records of contamination surveys conducted at the Sorrento Valley facilities, were reviewed by the inspector.
Daily contamination surveys had not been conducted on Feburary 14 and 17th, 1986 when the health physics technician (HPT), assigned to that area, had taken leave on those days. The HPT had forgotten to make arrangements to have someone conduct the routine surveys during his absence.
Since this appeared to be an isolated occurrence, it was not cited as a violation.
However, the licensee was requested to establish management controls / procedures to ensure that scheduled tasks will be carried out as required (86-04-08).
E.
Portable Monitoring Instruments Calibration of survey and alarm systems are the responsibility of the Facilities Maintenance Division. Survey instruments and area alarms were checked by the inspector during the tour of the licensee's facilities. The instruments were all noted to be in current calibration.
F.
Leak Tests The licensee has an inventory of thirty-one sealed sources. The inspector's review of the records indicate that leak tests had been conducted.
No violations were identified.
7.
Transportation / Radioactive Waste Management Licensee transportation activities are regulated by 49 CFR 100-177, 10 CFR 71, and 20.311.
Annex "C" of the current license incorporates guidelines for release of equipment and facilities for unrestricted use.
10 CFR Part 20.301 to Part 20.401 regulates the disposal of waste.
All transportation activities are handled by the licensee's Nuclear Waste Processing Group. This group was not on site during the inspection.
According to licensee representatives there had been no shipment of radioactive materials made since the date of the last inspection. A tour was made of the licensee's radioactive waste handling and storage facilities.
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10 No violations were identified.
8.
Emergency Preparedness License Condition 23, of SNM-696, requires the licensee to implement, maintain and execute the response measures of the Radiological Contingency Plan submitted to the Commission on May 25, 1984 as supplemented on August 22, 1984.
It also requires that the licensee shall maintain implementing procedures for the Radiological Contingency Plan.
The inspector verified that the licensee's Central Alarm Station (CAS) had the correct telephone number for reaching the NRC's Washington D.C.
Incident Response Center (IRC). The licensee's instructions in the emergency plan directs employees to call the CAS which then calls the NRC's IRC. The CAS's first effort to call the IRC would be by the emergency phone direct line.
If that failed, they would then use a commercial line. The correct telephone number was verified by the inspector.
The inspector checked the fire extinguishers on the van and found them to have been inspected as required. This closes item 85-16-08.
The eight selfcontained breathing apparatus (SCBA) units were checked for tank pressure and were found to be at 1500 psig. The radiation monitoring equipment was stored in sealed kits. The seals on the kits were intact.
The fire extinguisher inspection program continues to improve. One fire extinguisher in the Sr-90 Bunker area had not been inspected as required.
The licensee immediately arranged for it's inspection. The licensee's powder extinguishers had just been tested.
Sixteen powder extinguishers were loaned to the licensee to replace powder extinguishers during servicing.
CO and pressurized water fire extinguishers are scheduled to 2
be serviced this year.
The licensee's emergency drills conducted at six months intervals were discussed. The licensee indicated that during evacuations the CAS can facilitate personnel accounting by providing a computer listing of personnel tho were in the controlled area of SV-A at the time of the evacuation.
The Triga Fuel Fabrication Facility, the AE-1 Building, and the Triga Reactors each have small numbers of occupants thus making personnel accounting during a drill relatively simple.
SV-A and SV-B buildings have several people in offices. The licensee's method of accounting for these persons during a drill, as well as those in L Building, will be reviewed during the next inspection (86-04-09).
No violations were identified.
9.
Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1.
The topics included:
The areas inspected,
11 The violation identified by NRC (failure to comply with' License Condition 29.c.),
The violation identified by the licensee (see open item 86-04-02),
The closure of seven open items:
85-16-02 Inert container valve testing 85-16-03 Exhaust system flexible connector repair 85-16-04 Effluent sample tubing replacement 85-16-05 SV-B East filter bank HEPA filter replacement 85-16-07 SV-B Stepoff pad and monitoring instrument relocation 85-16-06 Incident investigation review policy 85-16-08 Emergency van fire extinguisher inspections Continuing open items:
84-04-08 Review grinder holdup study conclusion (requires HTGR plant restart) 85-09-01 Review hotofell waste drum classification 85-16-01 Review control of non-favorable geometry containers in SV-B (55 gallon drums of dry waste are stored temporarily during the bimonthly physical inventories)
New open items:
86-04-01 Review procedure revision regarding persons listed on work authorizations 86-04-02 Review the effectiveness of the licensee's effort to preclude recurrence of an adequately corrected violation 86-04-03 Review the adequacy of the inspections by nuclear safety of.the human error aspects of operations (Special emphasis was made for this open item (86-04-03) to assure that the licensee understood that the NRC was very concerned about precluding the kind of potential problem the 11 liter bottles represented) 86-04-04 Review the management control procedure developed to assure those requiring retraining receive it 86-04-05 Review the licensee's changes designed to preclude repetition of not adequately addressing waste streams in a process in a timely manner 86-04-06 Review the safety system put in place for the new waste handling area in the NWPC 86-04-07 Review the results of the licensee's reevaluation of the adequacy of the nozzles in place for isokinetic sampling of exhaust stacks at the current flow rates 86-04-08 Review the results of the licensee's efforts to assure HPT's are available to carry out scheduled tasks during absences 86-04-09 Review the licensee's effectiveness in accounting for persons during drills at SV-A, SV-B and L Building
12 The licensee's response to the retirement of the experienced HPT's appeared to be consistent with earlier assurance that the new organization would not dilute the radiation safety program, The question of whether the SV-B operation is currently at a development level or a production level was raised. This item would be discussed with NRC Licensing, The licensee's need to decide to use equipment developed for a similar 11 liter bottle problem which was addressed about three years ago at the recommendation of the NRC Project Manager, Loss of practical experience at the management level in nuclear safety and technical experience at the management level in radiological safety, Steps taken recently by the licensee regarding the 11 liter bottle problem:
Color coding the bottles Prohibiting dumping of any 11 liter bottles in SV-B 1 reparation of a procedure for transfer of 11 liter waste bottles to SV-A A committment to use the SV-A dumping facility Ordering a sign for the sink to remind operators of the sink dumping prohibition Importance of reviewing the criticality accident history, The need for criticality control limit signs to clearly convey correct information regarding specific containers and locations, Utilization of safety glasses, Management demonstration of positive attitude towards safety through compliance with procedures, The licensee's comments included:
Will retain the resources necessary to maintain the quality of the nuclear and radiological safety program through extensions or retention of consultants for appropriate training and transition
- periods, IIPT's were extended Managers of Nuclear Safety have been routinely retained as consultants Managers are encouraged to have employees attend safety meetings, i
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- 13 The importance of the proper use of safety glasses is recognized.
The program will be reviewed and where they are required, they will be worn.
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