ML20204B713
| ML20204B713 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 03/18/1999 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 696-3052, 70-0734-98-03, 70-734-98-3, NUDOCS 9903220217 | |
| Download: ML20204B713 (4) | |
Text
h GENERAL ATDnNCS March I8, I999 696-3052 1
VIA OVERNIGIIT EXPRESS SERVICE U.S._ Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Response to NRC Notice of Violation
Reference:
NRC Inspection Report 70-734/98-03 and Notice of Violation dated February 19,1999
Dear Sir or Madam:
Enclosed is General Atomics'(GA's) response to the Notice of Violation issued on February 19, 1999 (P.eference). This response was prepared pursuant to the provisions of 10 CFR 2.201.
GA trusts you will find its response and corrective action measures to be appropriate and satisfactory. If you should have any questions concerning this response please contact me at (619) 455-2823, or Mr. Brian Laney at (619) 455-4369.
Very truly yours, u
Dr. Keith E. Asmussen, Director Licensing, Safety, and Nuclear Compliance Enclosure - as above cc:
Regional Administrator, NRC Region IV Mr. Wayne Britz, NRC Region IV
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9903220217 990318 PDR ADOCK 07000734 C
PM 3550 GENERAL ATOMICS COURT, SAN DIEGo. CA 92121-1194 Po BOX 85608. SAN DIEGO. CA 92186 5608 4619)455 3000
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0 Attachment to GA Letter No. 696-3052 March 18,1999 - Page 1 of 3 l
General Atomics' Response to the Notice of Violation / Inspection Report 70-734/98-03 During the Nuclear Regulatory Commission (NRC) inspection conducted on December 7-11,1998 and January Il-15,1999, a violation of NRC requirements was identified. The violation is restated below, followed by the General Atomics'(GA's) response.
VIOLATION:
Safety Condition S-1 of License SNM-696 authorizes the use of the Site Decommissioning Plan dated October 11 and December 5,1996.; April 18,1997; and January 15,1998.
Safety Condition S-16 of License SNM-696 states: " Release of equipment, facilities, or packages to the unrestricted area os to uncontrolled areas onsite shall be in accordance with the attached " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of licenses for Byp:oduct Source, or Special Nuclear Material," dated April 1993. The guidelines for 2
decontamination of beta / gamma emitters in the attached document are 5,000 dpm/100 cm average,15,000 2
2 dpm/100 cm maximum and 1,( 00 dpm/100 cm removable.
Section 6.1.1," Release ofitems and Equipment," of the Site Decommissioning Plan states,in part: "If the potential exists for contamination on inaccessible surfaces, the equipment will be assumed to be intemally contaminated unless (1) the equipment is dismantled allowing access for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present,.." Section 6.1.3," Description of Final Radiation Survey Plan,"
states: "Once all identified affected areas are evaluated and cleaned up as necessary, a final radiation survey must be performed to demonstrate compliance with the release criteria."
By letter dated November 2,1998, the licensee requested the NRC to release office areas of Building 21 to unrestricted use and delete them from the license. To support this request, the licensee submitted with the letter the report," Final Radiological Survey Performed at General Atomics' Building 21 Unaffected Office Areas," dated November 1,1998. The November 2 letter stated in part, "The results of GA's extensive and comprehensive final radiation and contamination surveys, measurements, sampling, and analyses demonstrate conchmively that the unaffected office areas ofits Building 21 meet the NRC approved criteria for release to unrestricted use."
Contrary to the above, a confirmatory survey performed by the NRC inspectors on January 13,1999 identified contamination exceeding the release criteria in the office areas of Building 21 on an inaccessible surface with potential to be internally contaminated. The contamination consisted of a " hot particle"in the drain pipe of the Building 21 office areajanitor closet. The final survey report of the licensee showed no surveys were performed from within this pipe as required. The particle was later analyzed by the licensee to measure 100,000 counts per minute on contact and to consist principally of Cesium-137, a beta / gamma emitter.
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Attachment to GA Letter No. 696-3052 March 18,1999 - Page 2 of 3 GA's RESPONSE:
- m The mason for the violation. or. if contested. the basis for disnutine the violation:
This violation is the result of: 1) it being wrongly assumed that there was no real potential for contamination on the inaccessible surfaces of the subject drain pipe, and 2) a single " hot particle" contained in crud inside the drain pipe not being detected during GA's final survey.
The drain pipe had been connected to a deep sink in ajanitor's closet located in the office area of GA's Building 21. The deep sink had been removed prior to the final survey. The person (s) conducting the final survey (s) of the subject drain pipe assumed that there was no real potential for contamination on the inaccessible inside surfaces of the pipe. This assumption seemed to be confirmed by the fact that no reading above background was observed when the survey instruments were placed up to the open end of the pipe extending from the wall. The detector was too large to be placed inside of the pipe. Subsequent to the final survey, a copper " cap" was installed on the end of the pipe. Considerable mechanical force 4
(including pounding) and heat was applied in the process of installing the cap. It is suspected that the physical action of installing the cap on the pipe caused the crud to be redistributed inside the pipe, leading to the particle being repositioned in a more detectable location within the pipe. The particle was subsequently detected by the NRC du-ing their confirmatory survey.
(2) The cormctive stens that have been taken and the results achieved:
On or about January 13,1998, the pipe section containing the contamination was removed, double bagged and moved to the radiation controlled area in Building 21. Radiation levels were at background levels after the pipe section was removed from the area.
On or about January 15,1999, GA's Director of Licensing, Safety and Nuclear Compliance assigned to Mr. Brian Laney, the task of investigating this incident and determining its cause. Mr. Laney issued a memo documenting his findings and conclusion on February 2,1999. A copy of Mr. Laney's memo was sent to Mr. Wayne Britz (NRC Region IV) by facsimile machine, and placed into the U.S. Mail, on
. February 5,1999. GA considers Mr. Laney's memo to be incorporated, by reference, into this response.
(The GA response to Item 1) above was based, in part, upon the findings documented in Mr. Laney's memo.)
4 The management and supervisory staff of GA's Licensing, Safety and Nuclear Compliance organization were reminded of the importance of maintaining the credibility of GA's final radiological survey reports by assuring that the necessary time and resources are committed to conducting thorough, accurate, and meaningful surveys.
1 All GA Health Physics personnel received a timely oral reminder of the importance of strictly followmg j
the commitment in GA's Site Decomrrissioning Plan which states, in part: "If the potential exists for
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contamination on inaccessible surface s, the equipment will be assumed to be internally contaminated unless (1) the equipment is dismantled dowing access for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present,.." This was again re-emphasized to all Health Physics Technicians in writing by a 4
i
e Attachment to GA Letter No. 696-3052 March 18,1999 - Page 3 of 3 memo from Mr$ Paul Maschka, Acting Manager of Health Physics, dated March 18,1999.
Mr. Maschka's memo included a brief discussion of various means of surveying and sampling in order to have the requisite confidence that the pipe, or any other item being considered for release, does indeed meet the approved release criteria.
See also GA's response to Item 1 above.
(3) The corrective steps that will be taken to avoid further violations:
GA believes this particular violation to be an isolated incident resulting from a unique set of circum-stances. However, GA understands the need to be constantly on the alert for " hot particles," or other forms of contamination, in unexpected places. Accoroingly, GA will continue to be aware of the potential for
" hot particles" to be encountered during decommissioning activities and during the performance of associated radiological surveys. GA will remain vigilant in monitoring / surveying for such particles.
l Similarly, General Atomics will exercise renewed vigilance toward meeting its commitment to assure that drain lines (as well as all other items) do indeed meet the criteria for release, or are removed and managed as low level waste.
i Finally, GA has placed an order to purchase a small 0.9-inch diameter Nal detector to supplement its current inventory of detectors (e.g. a 2-inch diameter Nal detector) that are available for use in surveying j
inside drain pipes and/or other small spaces.
(4) The date when full comoliance will be achieved:
I General Atomics is in full compliance.
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