ML20210P106

Insp Rept 70-0734/97-04 on 970728-0801.No Violations Noted. Major Areas Inspected:Emergency Preparedness & Maintenance & Surveillance Testing Related to Licensees Possession Only License & Decommissioning Activities

ML20210P106
Person / Time
Site:	07000734
Issue date:	08/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210P102	List: ML20210P098 ML20210P106
References
70-0734-97-04, 70-734-97-4, NUDOCS 9708260371
Download: ML20210P106 (14)

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1 ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSIDN REGION IV Docket No.:

70 734 License No.:

SNM 696 Report No.:

70 734/97 04 Licensee: '

General Atomics (GA)

Facility:

Torrey Pines Mesa and Sorrento Valley Sites

~ Location:

San Diego, California Dates:

July 28 through August 1,1997 Inspector:

C. A. Hooker, Senior Fuel Facility inspector Approved By:

Frank A. Wenslawski, Chief Materials Branch :

Supplemental Inspection Information :

Confirmatory Radiation Survey Meaturements

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9708260371 970821 PDR ADOCK 07000734 C

POR-

2-EXECUTIVE

SUMMARY

General Atomics NRC Inspection Report 70 734/97 04 This inspection included a review of current operations, emergency peparedness, and maintenance and surveillance testing related to the licensee's possession-only license and decommissioning activities. The inspection also included an NRC confirmatory survey of non impacted areas the.t the licensee has requested approval to release for unrestricted use.

Onorations Revlow The licensee was adequately implementing the requirements of the license, associated procedures, and decommissioning plans (Section 1).

Adequate radiologict.1 controls had been implemented and security of radioactive materials was effective (Section 1).

Emernency Prenaredness The licensee's Radiological Contingency Plan (RCP) and facility emergency procedures were adequate (Section 2.1).

Emergency response personnel were knowledgeable of emergency response procedures and equipment (Section 2.2).

The licensee maintained adequate suppo.t from offsite agencies for responding or assisting during an emergency event, and evacuation drills were consistent with the requirements of the RCP (Section 2.3).

The licensee's emergency response facilities and equipment had been maintained in a state of operational readiness (Section 2.4).

Maintenance and Surveillance Testina The licensee had maintained testing systems important to safety (Sections 1 and 3).

ConfirmatoryJurvevs NRC confirmatory surveys were in agreement with the licensee's survey results, and none of the radiation measurements identified radiation levels above NRC guidelines in non impacted areas (Section 4).

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Rooort Details Summarv of Facility Statur 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 decontamination and decommissioning (D&D) of the Building 23 Hot Cell Facility (HCF) under an NRC approved decommissioning plan specific to the HCF. Activities in the TRIGA Fuel Fabrication Facility (TFFF) and Building 39 (modular helium reactor pilot f acility) in Sorrento Valley consisted of removing equipment for either waste disposal or disposhion to authorized recipients in preparation for D&D

activities.

1 Operations Review a.

Insoection Scooe (88104,88020,88025, and 83822)

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 and the current status of the licensee's site decommissioning program. Selected records and applicable procedures were also reviewed and discussed with licensee personnel, b.

Observations and Findinos Buildino 23 HCF The. inspector noted that D&D activities were consistent with the HCF decommissioning plan and licensee procedures. Personnel access to the facility continued to be well controlled. : Managt. ment and supervisory personnel had continued to be directly involved with D&D activities.

Alllead glass windows had been removed from the hot cells. With the exception of some ducting and remaining sections of underground drains, most of the rooms adjacent to the hot cells and service gallery had been cleaned. The licensee had excavated the underground ventilation line that extended from the operating gallery through Room 107. Current activities involved removal using a gas cutting torch of the outer steel casing from the face of the hot cells and preparation for removal of the low level hot cell door. The steelliners inside the hot cells are to be removed using the same method used for the face of the cells. The licensee expects to remove the roof of the f acility by the end of the year.

The licensee'h decontamination efforts had greatly reduced dose rates and contamination levels inside the hot cells. Licensee survey data indicated that the q

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j maximum contact dose rate of hot spots at the lips of the storage wells, which were grouted over in the high level hot cell ranged from approximately 30 millirem per hour (mrem /hr) to 120 mrom/hr (gamma). General dose rates in the high level

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hot cell ranged from 1.0 to approximately 5.0 mrem /hr. Removable contamination in the high level hot cell ranged from approximately 6,000 to 40,000 disintegrations per minute (dpm for beta gamma radiation for large area wipes with no detectable alpha contamination. Laboratory analyses of wipe tests continued to indicate that Co 60, Cs 134 and 137, and Sr 90 (alllicensed by the state of California) are the major contributors of radiation levels and loose contamination in the HCF.

The licensee had maintained the fire sprinkler system, high-efficiency particulate air (HEPA) exhaust system, and the criticality monitoring system. The criticality monitoring system will remain operational until an appropriate assessment can be made of any potential SNM in non-accessible portions of the drain and ventilation systems. Housekeeping was generally adequate for ongoing activities.

flyildina 39 (Modular Helium Reactor Pilot Facility)

As discussed in previouc inspection reports, the process and associated auxiliary equipment had either been packaged for radioactive waste disposal or for transfer to authonzed recipients. Current activities involved the removal of electrical conduit for disposal inspection Report 70 734/97 03, dated June 11,1997, described an issue related to a lack of attention to detellin documenting survey data and other information on equipment release logs. The inspector noted that subsequent equipment release logs included all appropriate information delineated on the form.

The current GNM inventory is primarily limited to assay standards containing less than 350 grams of U 235. The quality control laboratory inventory of SNM had been reduced to less than 10 grams of U 235. The licensee had maintained an operable criticality system 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 also operable. Housekeeping appeared very good and the licensee was maintaining the general working areas in the facility free of any removable contamination.

TFFF The inspector observed by physical inspection that the licensee had transferred all of the remaining SNM from the TFFF fuel vault to the main site storage vault. The inspector also notud that the criticality monitoring system had been disconnected from the site main alarm system and the security monitoring system had been taken out of service. The only remaining SNM (approx mstely 51 grams) in the facility i

was confined to the exhaust ducting as determined from the licensee's characterization studies (NRC Inspection Report 70 734/96-02). Current ac'ivities involved removal of the ducting and conducting surveys of equipment in the fuel vault (storage racks) to support release for unrestricted use or disposal.

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The inspector observed that the licensee had used a glove bag technique for separating each section of ducting while the system was maintained under a negative pressure. The inspector considered this method a good practice for reducing the potential for any releases of radioactive material to the work area.

~ The inspector noted that decommissioning activities were consistent with the licensee's internal decommissioning plan for the f acility, PC 00470/0, " General Atomics TRIGA Fuel Fabrication Facility Decommissioning Plan," dated July 1997.

The licensee's objective is to obtain approval to release the facility for unrestrictive use without significant f acility dismantlement.

Main Site Storace Vault -

There were no ongoing activities in the main site SNM vault. The current predominate inventony of SNM consisted of TRIGA fuel rod shipping containers awaiting shipment to an authorized foreign recipient and the remaining TRIGA fuel from the TFFF. The inspector noted that SNM materials were stored in accordance with the licensee's criticality safety analysis and license requirements. No concerns were identified by the inspector.

Radioloalcal Controls During facility tours, the inspector observed that workers were dressed in protective clothing as specified by licensee procedures and radiation work permits. Survey instruments in use appeared operational and within the current calibration periods, Radioactive materials and radiation areas were posted in accordance with requirements specified in 10 CFR Part 20.

c.

Conclusions The licensee had adequately implemer,ted the requirements of its license, associated

procedures, and decommissioning plans.

Applicab'e safety systems were-operational and security of radioactive materials was adequate, Adequate radiological controls were being implemented. No safety concerns were identified.

2 Emergency Preparedness

" 2.1 RCP and lmolementina Procedures a.

Insoection Scope (88050)

The inspector reviewed and discussed the licensee's RCP (Emergency Plan),

applicable facility emergency. procedures, and organization and staffing with licensee personnel to determine if the licensee's emergency program was adequate to support site activities. The inspector also toured licensee facilities, as described

6-f

-in Section 1, above, to verify the maintenance of emergency procedures and equipment.

b.

Observations and Findinas The inspector noted specific emergency procedures, consistent with the licensee's RCP, that were maintained for each facility at the site. These were prepared by Emergency Response and Recovery Directors (ERRDs) who are the st.nior individuals responsible for directing emergency response actions at their respective facilities.

The inspector noted that the respective facility emergency procedures and listed emergency response personnel were current.

The inspector noted that the licensee had submitted an update in May 1996 of its RCP, emergency response organizational chart, and the emer0ency response organization names and telephone numbers to reflect the current site staffing and site activities. Personnel changes in the submittal involved replacement of individuals no longer on site with an alternate for certain functions, c.

Conclusions The inspector concluded that the licensee's RCP and facility emergency procedures were adequate for implementing its emergency preparedness program. Based on the current status of the site, staff levels appeared sufficient for implementing the program.

2,2 Emeroency Preoaredness Trainina a.

insoection Scope (88050)

The inspector interviewed selected emergency response personnel to evaluate their awareness of emergency procedures and reviewed records of emergency response training to verify that training requirements specified in the licensee's RCP and' facility implementing procedures were being effectively implemented, b.

Observations and Findinas s

The inspector determined that ERRDs, alternate ERRDs, security personnel, and persons listed as emergency responders had received training consistent with the RCP and licensee emergency procedures. From discussions with selected licensee personnel during facility tours, the inspector noted that these individuals were cognizant of the location of emergency equipment and emergency procedures, c.

Conclusion Emergency response personnel were knowledgeable of emergency response procedures and equipment.

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t 2.3 Offsite Suonoit Aoencies, Drills and Exerclues i

a.

jnsnection Scope (88104 and 88050)

The inspector evaluated the licensee's involvement with offsite support agencies as described in the RCP.

b.

Observations and Findinas The licensee's RCP plan contains no requirement for agreement letters with offsite agencies responding or assisting during emergencv events. Offsite agencies mentioned in the RCP are principally government organizations and have indicated to the licensee that they have statutory responsibility to respond in the event of an emergency at the site. The Scripps Memorial Hospital functions as the supporting hospital on the same basis.

Offsite response agencies are invited on an annual basis to participate in orientation training and emergency exercises sponsored by the licensee. Approximctely 30 members of the San Diego Fire Department visited the site for familiarization and overview of the licensee's facilities on January 16,1997. Scripps Memorial Hospital and a local paramedics service group last participated with the site during a radiation disaster drill on April 23,1996. The licensee was in the process of developing an exercise for 1997.

Although there was no event associated with NRC licensed activities requiring response from offsite agencies, the inspector noted that on June 16,1997,a San Diego Fire Department Hazardous Materials team responded to a small chemical incident in a tenant's laboratory in Building 2. The event involved an exothermic reaction, causing fuming from e waste container, which resulted from the addition of an acid / solvent to a containe' of incompatible mixed acids. The event was short lived and did not result in any personnel injury.

The licens6a's annual fire evacuation drills and semiannual criticality evacuation drills were held at each applicable facility. A critique was performed for each drill to evaluate the effectiveness of the evacuations. Deficiencies were adequately addressed.

c.

Conclusions The inspector concluded that the licensee maintained adequate support from offsite agencies responsible for responding or assisting during an emergency event, and evacuation drills were consistent with the requirements of the RCP.

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l 8-2.4 Emeraency Eautoment and Facilities a. --

Insoention Scoce (88104 and 88050)

The inspector toured the licensee's facilities to examine selected emergency kits and equipment, specified in the RCP and licensee procedures. The inspector also evaluated the licensee's posting of evacuation routes and examined emergency exits from fenced f acilities, b.

Observations and Findinas Emergency kits contained equipment as specified in the RCP and licensee procedures. Emergency response equipment maintained in the health physics response van and other locations as consistent with the licensee's RCP. Survey meters examined during the inspection were calibrated and operational. Acid showers and acid eyewash fountains were conveniently located where applicable.

Evacuation routes were vividly marked, and emergency exit gates from fenced facilities were operational. -

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Conclusions The licensee's emergency response facilities and equipment had been maintained in a state of operational readiness. Personnel evacuation routes were clearly defined throughout the licensee's facilities.

3 Maintenance ar.d Surveillance Testing a.

inspection Scope (88025 and 88050)

The inspector toured the licenseo's facilities to observe the status of applicable remaining safety systems. The inspector reviewed selected records and discussed with licensee personnel tests and inspections of the fire detection and suppression systems, the Building 1 emergency generator, and the criticality monitoring systems. Routine weekly and monthly maintenance inspections conducted by the

- HCF staff were also reviewed and discussed with the licensee, b..

Observations and Findinas The inspector noted that the licensee conducted monthly inspections and tested applicable fire alarm systems monthly. Inspection and testing of the fire sprinkler systems were conducted quarterly by a certified contractor. - The Building 1 emergency generator that supplies emergency power to Security Station 1 (primary emergency support center) was tested weekly for auto start and load transfer.-

The criticality r.ionitoring systems were tested monthly to verify each detector's response and the effectiveness of the audible alarm Wstem, and t<., verify that the

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Security Station 1 alarm indicator panel was operational. Each detection unit was calibrated annually in accordance with established procedures.

Weekly and monthly maintenance inspections of the HCF were consistent with facility procedure, "GA Hot Cell D&D Project Hot Cell Maintenance inspection," to assure that applicable safety systems were operational, c.

Cpnclusions The licensee was adequately maintaining and testing systems important to safety.

4 Confirmatory Surveys of Non Impacted Facilities By letter dated April 10,1997, the licensee submitted to the NRC a request for release of non impacted GA facilities and surrounding land areas for unrestricted use. The request provided a listing of buildings where radioactive materials had never been used. The buildings were isolated from areas where activities involving use of radioactive material had been conducted. Maps showing the non impacted areas were also provided with the licensee's letters. The non impacted buildings and associated land areas include structures and land located at the main site (Torrey Pines Mesa) and some undeveloped land located adjacent to the Sorrento Valley facility. At the request of NRC, the licensee provided, by letter dated July 2, 1997, data from radiation measurements and analyses of soil samples taken sfong the boundary separating the non-impacted area and the remainder of the Sorrento Valley site. The licensee also redefined the boundary of land requested for release near approximately 45 feet further away from the building. Also, the licensee had recently taken radiation measurements and analyzed soil samples of selected land areas requested for release at the Torrey Pines Mesa site. This additional data with updated maps were expected to be provided to the NRC shortly after this inspection, a.

Inspection Scoce (88104 and 8389.QJ The inspector performed a limited confirmatory radiation survey of approximately 50 selected locations using the maps provided by the licensee. The radiation measurements were obtained utilizing a Victoreen Model 450P DE pressurized ion chamber, NRC No. 063309, due for calibration on August 9,1997. The licensee also took measurements at several of the locations in conjunction with the NRC measurements. The licensee utilized a Ludlum. Model 19 micro R Meter, S/N 101758, coupled to a Nal detector, due for calibration on September 29,1997.

b.

Observations and Findinos Background determinations made during the inspection agreed with the licensee's values. Radiation measurements obtained at ground level and 1 meter above ground did not identify any readings exceeding the NRC guideline of 5.0

10-microRoentgens per hour (gR/hr) above background for areas where measurements sre obtained. Attachment 2 provides the survey measurement locations and a

survey data, c.

Conclusions NRC radiation measurements agreed with the licensce's results, None of the radiation measurements represented values above NRC guidelines The inspector's survey data has been provided to the NRC Fuel Cycle Licensing Branch for review and final evaluation of the licensee's request for approval to release the non-irnpacted f acilities and land areas.

Exit Meeting Summary The inspector presented the inspection results to members of licenseo management at the conclusion of the inspection (,n August 1,1997. The licensee acknowledged the findings presented.

Although proprietary information was reviewed during this inspection, such information is not knowingly described in this report.

ATTACHMENT 1 SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licenseg L. K. Alfonso, Corporate Industrial Hygiene and Environmental Science K. E. Asmussen, Director, Licensing,-Safety and Nuclear Compilance V. J. Barbet, Manger, Engineering and Maintenance, Hot Cell Decommissioning G. C. Bramlett, Manager, D&D Project F. C. Dahms, Manager, Fuel Fabrication Equipment L. R. Gonzales, Manager, Health Physics H. A. Kleinsorge, Security Administrator B. Laney, Licensing Engineer P. R. Maschka, Supervisor, Health Physics R. Rao, Manager, Corporate Safety -

J. M. Sills, Manger, Health Physics, Decommissioning Project C. L. Wisham, Manager, Nuclear Materials Accountability J. Yi, Manager, Nuclear Safety NEC C. Ley, Summer Technical Intern, Licensing Branch, Division of Fuel Cycle Safety, NMSS INSPECTION PROCEDURES USED IP 83822: Radiation Ptotection IP 88020: Management Organization and Controls IP 88025: Maintenance and Surveillance Testing IP 88050: Emergency Preparedness

- IP 88104: Decommissioning Inspection Procedure for Fuel Cycle Facilities IP 83890: Closcout inspection and Survey LIST OF ACRONYMS USED cm' square centimeters

-D&D decontamination and decommissioning dpm disintegrations per minute ERRDs Emergency Response and Recovery Directors GA General Atomics HCP.

Hot Cell Facility itEPA high efficiency particulate air pR/hr microRoentgen per hour mrem /hr -

millirem'per hour RCP Radiological Contingency Plan SNM-special nuclear material

.. TFFF TRIGA Fuel Fabrication Facility

e ATTACHMENT 2 Main Site Measurements in R/hr.

Map Location NRC ground NRC 1 meter GA ground GA 1 meter P24 13 20 11 18 18 18 19 P25 13 18 13 18 16 17 16 17 P26 13 17 13 17 14 15 P27 11 18 11 18 NA NA P2B 10 17 8 14 NA NA P29 12 18 12 18 11 13 11 13 P30 11 19 11 19 13 13 P31 9 13 9 13 12 12 P32 12 19 12 19 12 12 P33 11 15 11 15 13 13 P34 11 17 11 17 11 12 11 12 Bldg 9 test Entrance 11 16 11 16 17 15 Between P24 & P25 13 16 13-16 15 15 Yard South of Tennis 7 12 7 12 NA NA Court Yard South of Pool 7 17 7 17 NA NA Parking lot No.31 1st 2 Rows Near Bldg 2 13 25 13 16 NA NA NA 10-16 NA NA NA 9 20 NA NA NA 9-18 NA NA NA 11 20 NA NA Next 2 rows 10-15 10-14 NA NA 14 19 13 16 N/A N/A N/A 11 23 N/A N/\\

NA: No measureinents taken Survey Points: Shown on mhps provided by licensee's letter to NRC dated August 13,1997.

NRC range of measurements reflects normal fluctuation of the instrument used.

NRC background measurements at several nearby offsite locations ranged from 1118 uR/hr.

2-Main Site Measurements in uR/hr Map Location NRC Ground NRC 1 Meter GA Ground GA 1 Meter Bldg 16 ist Level North NA 9 16 NA NA-Bldg 16 ist Level East NA 10-17 NA NA Bldg 161st Level South NA 11 17 NA NA Bldg 1b ist Level Center NA 10 18 NA NA Bldg 16 2nd ! evel North NA 6 13 NA NA Bldg 16 2nd Level East-NA 10-13 NA NA Bldg 16 2nd Level South NA 7 12 NA NA Bldg 16 2nd Level West NA 10 13 NA NA Bldo 141st Level East NA 10-13 NA NA Bldg 14 ist Level South NA --

9 16 NA NA Building 141st Level West NA 10 14 NA NA Bldg 141st Level Center -

NA 7 13 NA NA Parking lot North West of NA 10 21 NA NA Bldg 14 Property boundary actoss -

15 25-

-- 9 15 NA NA from P28.

Bldg 13 Dividing Hall 10-15 14 17 NA-NA NA: No measurements taken Survey Points: Shown on maps provided by the licensee's letter to NRC dated t.ugust 13,1997.

NRC range of measurements reflects normal fluctuation of the instrument used.

. NRC background measurements at several nearby offsite locations ranged from 11 18 uR/hr.

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3 Sorrento Valley Site Measurements in uR/hr.

Sample Location NRC ground NRC 1 meter GA ground GA 1 meter P1 14 20 14 20 15 15 P2 13 15 13 15 17 18 17 18 P11 11 19 11 19 14 14 P16 11 17 14 18 15 15 P18 11 18 11 18 NA NA P19 11 18 14 19 NA NA P20 12 17 12 17 NA 18 (concrete)

P22 14 20 14 18 16 NA P23 11 18 14 20 NA NA Parking lot Between 17 24 17 20 16 16 P22 & P20 NA: No measurements taken Survey Points: Shown on maps provided by the licensee's letter to NRC dated August 13,1997 NRC range of measurements reflects normal fluctuation of the instrument used.

NRC background measurements at several nearby offsite locations ranged from 11 18 uR/hr.

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