ML20212M301

Insp Rept 70-0734/99-01 on 990802-06.Violations Noted. Major Areas Inspected:Emergency Preparedness,Environmental Protection,Radioactive Waste Mgt & Storage,Transportation & Validation of Portions of Final Radiological Survey Program

ML20212M301
Person / Time
Site:	07000734
Issue date:	10/20/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212M294	List: ML20212M290 ML20212M296 ML20212M301
References
70-0734-99-01, NUDOCS 9910270247
Download: ML20212M301 (15)

Text

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ENCLOSURE 2 -

U.S. NUCLEAR REG.ULATORY COMMISSION RE9lON IV Docket No.:

70-734 License No.:

SNM-696 Report No.:

70-734/99-01 Licensee:

General Atomics Facility:

Torrey Pines Mesa and Sorrento Valley Facilities Location:

San Diego, California Dates:

August 2-6,1999 Inspectors:

Julie Olivier, Chemical Engineer Wayne L. Britz, Fuel Cycle inspector Approved By:

D. Blair Spitzberg, Ph.D., Chief Fuel Cycle / Decommissioning Branch Division of Nuclear Materials Safety

Attachment:

SupplementalInformation a

9910270247 991020 PDR ADOCK 07000734 C

PDR

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' 1 EXECUTIVE

SUMMARY

General Atomics (GA)

NRC Inspection Report 70-734/99-01 This routine, announced inspection focused on emergency preparedness, environmental protection, radioactive waste management and storage, transportation and validation of portions of the licensee's final radiological survey program for site decommissioning activities.

Specific attention was given to decommissioning activities involving the Group 11 Laboratories in Building 2, Building 31-1, the former Building 31-3 ground area, the Sorrento Valley Central Land Area, and various materials to be shipped to a clean landfill.

Decommissionina inspection (88104)

Radioactive Waste Manaaement. Waste Generator Reauirements. & Low-Level Waste Storaas The licensee was adequately monitoring and controlling radioactive gaseous and liquid effluent releases, processing liquid and solid radioactive wastes, and transporting radioactive wastes. Effluents for the period reviewed were well below the limits specified in 10 CFR Part 20, indicating appropriate efforts by the licensee to maintain releases As Low As Reasonably Achievable (ALARA) (Section 2.1).

Emeraency Preoaredness The licerisees's emergency preparedness program was adequate for the remaining radiological facilities on the site; however, the Radiological Contingency Plan had not been updated to reflect the facilities that have been decommissioned and no longer serve functions as described in the current plan (Section 2.2).

Environmental Protection With the exception of the monthly gamma scans for the site air samplers, the licensee's environmental monitoring program was conducted in accordance with the license application and the licensee's implementing procedures. Precautions were taken by the licensee to prevent the spread of contamination to the environment during decommissioning (Section 2.3).

i A violation of the License Specification 6.1 was identified involving the licensee's failure to perform required monthly gamma scans of composite air filter samples (Section 2.3).

Closeout inspection and Survey (83890)

Based on the results of this inspection, activities conducted at the Torrey Pines Mesa and Sorrento Valley facilities were generally characterized by implementation of effective programs for decontamination and decommissioning (Section 3.3).

- NRC confirmatory surveys conducted at the Group 11 Laboratories in Building 2, Building 31-1, the former Building 31-3 ground area, the Sorrento Valley Central Land

' Area, and various materials to be shipped to a clean landfill were consistent with licensee measurements. The NRC's confirmatory measurements confirmed the licensee's determination that these areas and facilities met the criteria for unrestricted release (Section 3.3).

The results of NRC split soil sample confirmatory measurements from the former Building 31-3 land area were in good agreement with licensee results. The results of the soil samples taken from the area were less than the criteria established for unrestricted release. The licensee's final survey report for this area and the request for release for unrestricted use will be submitted later (Section 3.3).

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.- Report Details 1

Summary of Facility Status All production and research activities involving the use of special nuclear material (SNM) had been discontinued. The SNM facilities were being decommissioned according to the Hot Cell Facility Decommissioning Plan, Rev. 4, dated January 1998, and the Site Decommissioning Plan (SDP), dated September 1996.

At the time of the inspection, licensee activities consisted of decontamination and j

decommissioning (D&D) of various site buildings and structures as outlined in the two plans. Following extensive site characterization, several site areas had been radiologically surveyed for release from the SNM license. D&D was also proceeding for radioactive byproduct materials licensed by the State of California.

The licensee's licensed activities and D&D program attributes were previously discussed in NRC Inspection Reports 70-734/98-03 (February 1999),70-734/98-02 (July 1998),70-734/98-01 (January 1998),70-734/97-05 (December 1997), and 70-734/97-02 (June 1997).

2 Decommissioning inspection (88104)

The D&D activities were inspected according to Decommissioning Inspection Procedure 88104 and Closeout inspection and Survey Procedure 83890. Portions of inspection procedures that were applicable during the licensee's operational program and that carry over to the licensee's decommissioning program were selectively used during this inspection as provided for in the Decommissioning inspection Procedure. The applicable portions of the procedures used were from the Emergency Preparedness Procedure 88050; Environmental Protection Procedure 88045; Radioactive Waste Management Procedure 88035; Waste Generator Requirements Procedure 84850; Low-Level Waste Storage Procedure 84900; and the Transportation Procedure 86740.

Areas reviewed during this inspection which involved D&D of NRC-licensed facilities included:

The Sorrento Valley Central Land Area categorized as an " unaffected area." The area was never used for work involving radioactive materials. However, the north half of the parking lot had been used for the temporary storage of radioactive waste boxes from the SVA Fuel Manufacturing Facility Decommissioning Project. These radioactive waste boxes had been packaged, sealed and the exteriors surveyed for removable contamination before being stored in this area. Surveying and sampling were performed by the licensee to demonstrate compliance with the approved criteria for release to unrestricted use. The licensee made surface and area measurements and collected

and analyzed soil samples to demonstrate compliance. Confirmatory surveys on this area were accomplished during this inspection.

.. The Building 2, Group 11 Laboratories, consisting of nine laboratories classified as

" unaffected area,"" suspect affected areas," and "non-suspect affected areas." The licensee had conducted surface and area measurements to demonstrate compliance with the release criteria. Confirmatory surveys were accomplished in these facilities by the NRC during this inspection.

. Building 31-1 housed offices, laboratories, storage vaults and a control room for a critical facility that was located in another building. The areas were classified as either e

"non-suspect affected" or " suspect affected areas." The licensee made surface and w

area measurements and analyses of the walls, floors, roof, and roof tar and gravel layers. Confirmatory surveys were accomplished in these areas by the NRC during this inspection.

. Several D&D building material storage areas had been surveyed by the licensee for disposal to a sanitary landfill. Confirmatory surveys were accomplished in these areas by the NRC during this inspection.

Building 31-3, a radioactive material storage and fuel element fab / assembly building, had been removed and the ground area had been remediated. As part of the ongoing decommissioning process, soil samples were obtained by the licensee and split with the NRC for confirmatory analysis.

2.1 Radioactive Waste Manaaement. Waste Generator Reauirements. & Low-level Waste Storaae (88104, 88035, 84850, and 84900)

a. Inspection Scone The inspectors reviewed the licensee's program for ensuring that release of liquid, airborne, solid wastes, the storage of radwaste, and the transportation of wastes met the requirements of the license and regulations. The review included facility tours and review of licensee procedures and selected records.

b. Observations and Findinas Responsibilities and controls required by Section 6.3, " Stack Monitoring," Part I of the license; Section 6/2, " Water Sar pling," Part ll of the license; and as further described in the ik,unsee's Health Physics Procedures HP-77, Environmental Air Sampling and HP-167, Disposalof Liquids into Sanitary Sewage System were reviewed. The monitoring, sampling, and analysis programs were being conducted as required. The instrumentation, calibrations, and procedures were adequate.

The effluent release records reviewed included radioactive gaseous effluent sampling and liquid releases to the sewer. The releases were well below the limits specified in 10 CFR Part 20 indicating appropriate efforts by the licensee to maintain releases ALARA. The inspectors had no concerns with the releases and records.

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. The facilities for treatment of liquid (Building 25, Liquid Waste Treatment Facility) and solid (Building 41, Nuclear Waste Processing Facility) radioactive wastes were reviewed. The processes were reviewed and discussed with the licensee. The facilities were inspected for radiological practices and good housekeeping. The inspectors found the facilities and processes adequate and had no concerns.

The procedures for the receipt and shipment of radioactive material as specified in the SDP, Section 4.9.1, Conformance to Requirements of 10 CFR 61,10 CFR 71, and 10 CFR 20.2006, were reviewed and discussed with the licensee. The training records for transportation personnel were reviewed. The inspectors found the transportation program and training met license requirements.

c. Conclusions The licensee was adequately monitoring and controlling radioactive gaseous and liquid effluent releases, processing liquid and solid radioactive wastes, and transporting radioactive wastes. Effluents for the period reviewed were well below the limits specified in 10 CFR Part 20 indicating appropriate efforts by the licensee to maintain releases ALARA.

2.2 Emeraency Preparedness (88104 and 88050)

a. Inspection Scope The inspecters reviewed the licensee's facilities for supporting the Radiological Contingency Plan and the changes resulting f tom the decommissioning of the site.

b. Observations and Findinas The inspectors reviewed the site facilities in place to support emergencies. The Emergency Support Center located in Building 1, Ror>m 103, was inspected. The station was manned by a security officer. The room is also designated as Security Station No.1.

The inspectors discussed the functions of the Emergency Support Center under certain emergency situations.

The inspectors reviewed the training provided to personnel as required by Section 10.2, Training of the Rad;ological Contingency Plan. The training records of the personnel were reviewed. It was noted that several personnel were overdue on their training requirements and were thus prohibited from responding to an emergency. These individuals had been notified of the overdue training by a memorandum.

The inspectors reviewed Health Physics Procedures #17, Emergency Vehicle Inventory and Maintenance Procedure; #149, Action to be Taken When Criticality Klaxon Horn Sounds; and #164, Classification and Assessment of Radiological Emergencies. The l

inspectors also reviewed the equipment and designated locations for emergency response equipment. It was noted that since the Radiological Contingency Plan was last updated, locations of some emergency facilities have been eliminated due to the site decommissioning in process. For example, the Building 27-1 decontamination facility is no I

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• longer in service due to decommissioning. The remaining decontamination facility is in the radwaste yard. Other equipment such as the meteorological system in Building 10 will be removed, leaving one system in Sorrento Valley. These facilities are currently referenced in the Radiological Contingency Plan. The licensee indicated that the Radiological Contingency Plan will be reviewed and revised during the annual plan review to refl~.t the current status of site decommissioning and needs.

The facilities and provisions for emergency preparedness were found to be adequate.

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c. Conclusions The licensees's emergency preparedness program was adequate for the remaining radiological facilities on the site; however, the Radiological Contingency Plan had not been updated to reflect the facilities that have been decommissioned and no longer serve functions as described in the current plan.

2.3 Environmental Protection (88104 ar.d 88045)

a. Inspection Scope The inspectors reviewed the licensee's implementation of the environmental protection program to determine compliance with the license. This included facility tours and review of licensee procedures, selected records of environmental sampling and internal audit results for the past year.

b. Observations and Findinas Responsibilities, controls, and the environmental surveillance program required by Section 6.1, " Air Sampling," of Part 11 of the license; Chapter 3 of the Hot Cell Decommissioning Plan; and the licensee's Health Physics Procedures HP-40, Environmental Monitoring Program - Alert Levels; HP-77 Environmental Air Sampling; HP-78, Environmental Radiation - Thermoluminescent Dosimeter; and HP-167, Disposal of Liquids into Sanitary Sewage System were reviewed.

The environmental records reviewed included:

. waste effluent monitoring and sampling for the wastes to the municipal sewage system;

. soil and vegetation samples;

. air sampling and analysis;

. water and sediment sampling and analysis;

. radiation level surveys (TLDs).

The inspectors reviewed the type of equipment used, the type of samples collected, the type of analysis performed and the results, in addition, an example of a temporary proccdure for performing decommissioning type work (excavation of the hot cells) was examined.

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i 8-The license in Part II, " Licensee Specifications," Section 6.1, " Environmental Air Sampling,"

requires the licensee to collect air filters weekly from each of the 10 site air samplers, to analyze the weekly air sample filters for long-lived alpha and beta radioactivity and to composite the filters for a gamma scan monthly. A review of the air sampler data indicated there were no composited gamma scan data for the past year. The licensee stated that the monthly gamma analyses had been discontinued. An acceptable reason for this omission was not determined. The licensee's failure to comply with an analysis required by the licensee was identified as a violation of the License Specifications, Section 6.1,

" Environmental Air Sampling"(70-734/9901-01).

The licensee had a system in place to prevent the spread of contamination from temporary activities (including soil excavation) which support decommissioning. Temporary procedures for controlling and monitoring radioactive contamination were approved by the Radiation Safety Manager. Air samplers were strategically placed around the perimeter of the work area and samples were collected and analyzed weekly.

c. Conclusions A violation of the License Specifications, Section 6.1, " Environmental Air Sampling" was identified involving the licensee's failure to perform required monthly air filter sample composite gamma scans.

With the exception of the monthly gamma scans for the site filter air samples, the licensee's environmental monitoring program was conducted in accordance with the license application and the licensee's implementing procedures. Precautions were taken by the licensee to prevent the spread of contamination to the environment during.

decommissioning.

3 Closeout inspection and Survey (83890) 3.1 Scope The licensee's preparations, final survey plan, conduct of the final survey, and analysis of th0 results for selected areas within the Group 11 Laboratories in Building 2, Building 31-1, the Wmer Building 31-3 ground area, the Sorrento Valley Centra! Land Area, and various materials b be shipped to a clean landfill, were reviewed to determine their agreement with the methodongles contained in NUREG-5849, the licensee's SDP, and the requirements of 10 CFR 7J.38(j).

Confirmatory seweys for surface alpha, beta and gamma, and ambient gamma ra:

an exposure levels of =,6lwted areas within the aforementioned buildings and areas were conducted by the inspectors to determine the radiological status of the facilities being considered for release.

During the confirmatory surveys, NRC inspectors used the following radiation detection instruments:

. Eberline Model E-600 to measure for alpha, beta Ond gamma radiations with gas-proportional, Geiger-Mueller (GM) and alpha sch.tillation probes; and Ludlum Model 19 to measure low level gamma rays.

Model NRC Serial #

Calibration Due Eberline E-600 063472 2/05/00 Ludlum Model 19 015534 5/3/00 a

The inspectors performed operational checks of NRC radiation instrumerits with National institute of Standards and Technology (NIST) traceable radiation check sources.

Release Criteria for Unrestricted Release as approved in the licensee's SDP are shown below:

Alpha-and Beta / Gamma Emitters 2

5,000 dpm/100cm Fixed and removable natural uranium, U-235, U-238, j

and associated decay products

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2 1,000 dpm/100cm Removable natural uranium, U-235, U-238, and associated decay products General Area Gamma Exposure Rate Limit Less than 10 microRoentgen per hour ( R/hr) above background when measured at approximately 1 meter (~3 feet) above surfaces / floors.

3.2 Observations and Findinat

a. Building 2 Laboratories - Group 11 (nine laboratories)

The licensee's " Final Radiological Surveys of Selected Building 2 Laboratories for Release to Unrestricted Use," dated July 1999 was reviewed and found acceptable.

The inspectors performed a confirmatory survey of five of the nine laboratories using a gas-proportional counter and a sodium iodide micro-R meter. These five laboratories, Nos. 238,240,242,443 and 445 were the most likely to be contaminated due to prior use.

The beta readings ranged from 108 482 dpm/100 cm above background. The alpha 2

2 readings ranged from 0 to 10 dpm/100 cm above background. The gamma readings at one meter equal to or less than background. The results were consistent with the licensee's measurements which demonstrated that the area met the criteria for unrestricted release,

b. Building 31-1, Radiochemistry Labs / Radiography Building The licensee's " Final Radiological Survey Performed at General Atomics' Building 31-1,"

dated August 24,1999, was reviewed and found acceptable.

The inspectors performed a confirmatory survey of the building's five rooms using a gas-proportional counter and a sodium iodide micro-R meter. The beta readings ranged

. 2 from 154-672 dpm/100 cm above background. The alpha readings ranged from 2

0 to 34 dpm/100 cm above background. The gamma readings at one meter ranged from 0-5 R/hr above background. The results were consistent with the licensee's measurements which demonstrated that the area met the criteria for unrestricted release.

c. Sorrento Valley Central Land Area The licensee's report, " Final Radiological Survey Performed at General Atomics' Sorrento Valley Central Land Area," dated July 28,1999, was reviewed and found acceptable. The inspectors performed a confirmatory survey of the land area. The survey consisted of alpha, beta and gamma measurements over several portions of the land area. No soil 2

samples were taken. The beta readings ranged from 0-216 dpm/100 cm above 2

background. The alpha readings ranged from 0 to 4 dpm/100 cm above background. The gamma readings at 1 meter ranged from 0-2 uR/hr above background. The results were consistent with the licensee's measurements which demonstrated that the area met the criteria for unrestricted release.

d. Former Building 31-3 area Building 31-3 had been removed and the ground area remediated. The licensee will be submitting the final survey of the area and a request for unrestricted release later.

Four soil samples weia obtained and split for analysis by the licensee and the NRC as part of the confirmatory survey process during decommissioning. The comparison results of the licensee's analysis with the NRC's analysis of the soil samples, as presented in the following tables, were all in agreement when compared with the criteria in NRC Inspection Procedure 84525," Quality Assurance and Confirmatory Measurements."

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. Acceptance Criteria' Resolution

• Ratio'

<4 0.4 - 2.5 47 0.5 - 2.0 8 15 0.6 1.66 16 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.16

' Cnteria from inspection Procedure 84525, Quahty Assurance and Confirmatory Measurements for in-Plant Radiochemical Analysis Resolution is the NRC result divided by its associated 10 uncertainty.

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• Ratio is the licensee result divided by NRC result.

Soll Sample Analysis Comparison Site at Former Building 313 Sample # /

GA Analysis NRC Analysis Resolution' Rat!o' Agreement' lootope pCl/ gram

. pCL/ gram +/- 10 Status

1. B31-318 tocation 1 at Former Building 31-3 Site U 238 2.70 3.7+/-0.8 4.6 0.73 OK U-235 0.31 0.25+/-0.06 4.2 1.2 OK Am-241 Not Detected Not Detected

1. B31-3 2B Location 2 at Former Building 3.-J Site An U-238 2.32 2.7+/-0.5 5.4 0.86 OK g

U-235 0.25 0.15+/-0.07 2.1 1.7 OK Am 241 Not Detected Not Detected

1. R313 38 '

Location 3 et Former Building 31-3 Site U-238 2.25 2.6+/-0.47 5.5 0.86 OK U-235 0.31 0.27+/-0.06 4.5 1,1 OK Am-241 Not Detected Not Detected

1. B313 38 Location 4 at Former Building 313 Site U-238 2.24 2.1 +/-0.6 3.5 1.1 OK U-235 0.25 0.17+/-0.07 2.4 1.5 OK Am-241 Not Detected Not Detected '

' Resolution, ratio and agreement status determined f rom above enteria.

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e. Materials for Sanitary Landfill Disposal Several storage locations consisting of a variety of materials designated for disposal at a clean landfill were surveyed. Confirmatory surveys were performed on the following materials and location designations:

S-1,a,b, Building 27-1 concrete in dumpsters S-4, Building 30 concrete in dumpsters S-5, Building 39 concrete slabs T-5 and T-7, Building 27-1 concrete slabs T-13,14 & 15, gunite, concrete / soil, and steel T-17, Building 23 asphalt, concrete T-20, Building 30 concrete shield door and metal door i

T-24, Building 23 concrete blocks The alpha-beta-gamma readings on the various materials made with the HP 360 GM probe 8

ranged from 0-255 dpm/100 cm above background. The gamma readings at one meter R/hr above back round. The results were consistent with the licensee's ranged from 0-7 0

measuremer:ts which demonstrated that the area met the criteria for unrestricted release.

3.3 Conclusion Based on the results of this inspection, D&D activities conducted at the Torrey Pines Mesa and Sorrento Valley facilities were generally characterized by implementation of effective programs for decontamination and decommissioning.

Confirmatory surveys conducted at the Group 11 Laboratories in Building 2, Building 31-1, the former Building 31-3 ground Lea, the Sorrento Valley Central Land Area, and various materials to be shipped to e clean landfill were consistent with licensee measurements. The NRC's confirmatory measuoments confirmed the licensee's determination that these areas l

and facilities met the critesia for unrestricted release, The results of NRC split soil sample confirmatory measurements from the former Buildir>g 31-3 land area were in good agreement with licensee results. The results of the soil samples taken from de area were less than the criteria established in Table 6-2, Soiland Concrete / Asphalt Rubble Release Criteria, of the SDP for unrestricted release. The licensee's final survey report for this area and the request for release for unrestricted use will be submitted later.

6 ' 4 Followup (92702)

_ 4.1 (Closed) Violation 70-734/9803-01. Contaminated material found in decontaminated area to be decommissioned. ' Reauired survev not performed.

The inspectors reviewed the licensees's " investigation of the Hot Pipe at B dg. 21" dated

.7 February 2,1999, the licensee's response to the Notice of Violation dated. March 18,1999, H

and the licensee's corrective actions to the violation. The licensee's corrective actions were

.,L to: 1) remove the pipe section,2) investigate the incident and determine the cause,3) issue f

an. oral and written reminder to all health physics technicians on survey techniques and the survey requirements of the SDP, and 4) purchase a small detector to use in surveying inside drain pipes and/or other small spaces.

The inspectors found that the iicansee had implemented the corrective actions identified.

The violation is closed.

5. Exit Meeting Summary The inspectors presented' the inspection results to members of licensee management at the conclusion of tne inspection period on August 6,1999. A talephonic followup exit briefing was conducted on September 9,1999, to discuss the results of the split soil sample.

confirmatory measurements performed as part of the inspection. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

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i ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licenree Keith Asmussen, Director, Licensing, Safety and Nuclear Compliance George Bramblett, Project Manager, GA D&D Fritz Dahms, Project Manager, GA D&D Laura Gonzales, GA Radiation Safety Officer / Health Physics Manager John Greenwood, Principal Investigator, TRIGA Barbara Hunter, Health Physics, Hot Cell Facility William LaBonte, Lead Health Physicist, Hot Cell Facility Brian Laney, Licensing and Compliance Paul Maschka, Senior Health Physicist Bob Noren, Manager, GA D&D John Tumer, Health Physics INSPECTION PROCEDURES USED IP 83890 Closecut inspection and Survey IP 84525 Quality Assurance and Confirmatory Measurements IP 84850 Waste Generator Regsirements l

.lP 84900 Low-Level Waste Storage

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IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 88050 Emergency Preparedness IP 88104 Decommissioning Inspection ITEMS OPENED, CLOSED AND DISCUSSED Opened 70-734/9901-01 VIO Required environmental sample analysis not performed.

Closed 70-734/9803-01 VIO Contaminated material found in decontaminated area to be decommissioned. Required survey not performed.

Discussed None

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LIST OF ACRONYMS USED f

ALARA. as low as reasonably achievable 2

cm square centimeters cpm -

~ counts per minute dpm cisintegrations per minute-D&D decontamination and decommissioning

- GA General Atomics GM Geiger Mueller -

HP health physics NIST-Nationallnstitute of Standards and Technology.

1a-one standard deviation pCi/ gram pico Curies per gram-PDR' Public Document Room '-

SDP.

Site Decommissioning Plan

.SNM l special nuclear material

' SVA-Sorrento Valley "A" Building

,TLD' thermoluminescent dosimeter R/hr microRoentgen per hour

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