ML20214J808
| ML20214J808 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 05/07/1987 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20214J775 | List: |
| References | |
| 696-1065, NUDOCS 8705280196 | |
| Download: ML20214J808 (25) | |
Text
-
4 rg G A Techrv*vjet GA Technologies Inc.
May 7, 1907 8
PO. BOX 65608 N
Ni/C[J p SAND CALIFORNIA 92138 Mr. James L. Montgomery, Chief Nuclear Materials Safety and Safeguards Branch U.S. Nuclear Regulatory Commission,. Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 945%
Subject:
Docket 70-734: Sl#HM; Responses-to Team Assessment Recommendations
Reference:
Montgomery, James L. letter to R. Graves, Jr.,
transmitting inspection Report No. 70-734/87-01, dated March 5, 1987
Dear Mr. Mcntgomery:
This refers to the assessment of operational safety conducted at GA Technologies Inc. (GA) by a NRC-sponsored team January 12-16, 1987.
The inspection report referenced above listed a large number of recommendations identified during the team assessment.
Enclosed are GA's responses to each of the recommendations.
In each case, the recommendation is given as it appeared in Section 3 of the inspection report ' folIowed by our corresponding response.
Upon review of the enclosed written responses, we trust you will find that, whlie we do not agree with every recommendation, we have given each recommendation serious consideration and have taken, initiated, or committed to many actions to further enhance safety and emergency preparedness at GA.
A few signifIcant specific exampies are:
a commitment to develop and implement, on a priority basis, a company hazardous materials / waste control program; the appointment of an Individual as the company's hazardous materials / waste manager who will coordinate this offort; the addition of another professional (analytical chemist) to our Industrial Safety staf f who will be devoted full-time to hazardous materials / waste control; the recruitment of an additional Emergency Services Technician; and the retention of a professional consultant quellfled in industrial hygiene and toxicology.
Should you have any questions concerning our responses to this inspection, please contact me at (619) 455-2823.
Very truly yours,
@ 2ggg g ygyg4 C
PDR Keith E. Asmussen, Manager Licensing, Safety and Nuclear Compliance
Enclosure:
Responses to Team Assessment Recommendations 10955 JOHN JAY HOPKINS DR., SAN DIEGO CALIFORNIA 92121
i Attachment to 6%-1065 i
May 7, 1987 A.
IstlTTEN PNEEIMIES Recommendation A1:
Prepare standard operating procedures for use with hazardous material work authorizations (WAs).
Resnonse Al t Standard operating procedures are written and approved for work involving radioactive materials and equipment emitting lonizing radiation. These procedures come under a Work Authorization (WA) which is controlled by the Manager of Health Physics.
In addition to Health Physics, alI WAs are routed to Nuclear Materials Management, Licensing, Nuclear (Criticality)
Safety, and when appropriate to the Criticality and Radiation Safety Committee for reviews and approvals.
Work involving hazards that are not of a nuclear / radioactive nature and are not covered by standard practices and procedure is covered under a Hazardous Work Authorization (HWA).
Hazardous Work Authoriza-tions are initiated in the operating organization, reviewed by line management and then forwarded to industrial Safety, Medical, Health Physics, Industrial Hygiene, and Emergency Services for review and approval.
Since all of this work is research and development, this review package serves as the operating procedure for:
general work procedures, specific safety, fire, and health requirements, and procedures for disposal of waste materials (including hazardous substances and chemicals).
Operating procedures for normal work operations are addressed in the GA Safety Manual (i.e. welding; crane /holst operations; handling, use, and disposal of hazardous materials; laser I
operation; etc.).
{ {
8.
OPERATOR TRAINING Recr-- ndation B1: Assure that all persons potentially exposed to hazardous materials participate in the Hazard Communication Training Program.
Resnonse B1:
GA is in the process of implementing a Hazard Communication and Training Program based on the new company organization implemented late in 1986.
The following actions have been taken to identify all work areas where employees may be exposed to hazardous substances so that proper training can be conducted.
A memo has been sent to each company employee mandating a.
attendance at a Hazard Communication / Hazardous Substance Labeling meeting.Lt they work with hazardous substances mid have not yet attended a class.
b.
Updates of existing inventory are being conducted through Plant Safety Committee representatives with the assistance of our industrial hygienist consultant and an analytical chemist.
Labeling procedures are reviewed at this time with the appropriate hazardous material custodian, l
A memo was distributed to all GA employees explaining c.
what a Material Safety Data Sheet is and what training must be completed.
Safety training programs regarding the specific chemicals being used in the various work areas are conducted by the industrial hygienist.
Training is conducted at the request of the Plant Safety Committee representative based on the division's inventories.
The Hazard Communication Program wilI be reviewed by the Industrial Safety engineer and the industrial hygienist consultant on a routine basis.. -
r During 1986, GA conducted hazard communication classes for approximately 400 employees and contractors, including:
how to read MSDS's, record keeping, labeling, and examinations (specific to chemicals used).
Throughout 1986, the Plant Safety Committee emphasized the proper and safe handling, use and storage of hazardous materials.
By June,1987, a comprehensive Hazard Communication Program will be in effect.
Rece-- ndation B2:
Increase Interf acing frequency with the off-site medical support.
Resnonse B2: See response H4.
C.
M FAR CRITICAL ITY SAFETY Recommendation C1:
Senior management should assure that members of the Criticality and Radiation Safety Committee (CRSC) have time to perform essential CRSC functions.
Resnonse C1 Senior management is very much aware of the importance of the functions performed by the CRSC and will continue to take whatever action is appropriate to assure that CRSC members continue to be available to perform their essential functions in a timely manner.
Recc-- ndation c2: Enhance the status of the CRSC members.
Resnonse c2:
The importance of the work of members of this committee will continue to be emphasized.
The vital functions the members perform are well recognized and appreciated by all Concerned. ;
m.
Recommendation C3:
Assure only quellfled persons perform nuclear safety analyses and reviews.
Resoonse C3:
We continue to be committed to assuring only qualified persons perform nuclear safety analyses and reviews.
To emphasize the importance of, and increase the awareness of, this commitment, we took the following action which will also facilitate demonstration of compliance.
A large number of Individuals at GA have expertise in some or all aspects of nuclear safety evaluations.
The relevant fields of expertise are in core physics, computational methods, nuclear data base, critical experiments, etc.
In order to preclude a choice of less than well-rounded reviewers, several Individuals were selected who, by the nature of their formal education, training and experience in criticality safety, are fully quallfled to carry out nuclear safety evaluations or independent reviews.
The qualifications of these Individuals were reviewed and approved by the Manager of Nuclear Safety, the Manager of Licensing, Safety and Nuclear Compliance, and by the Chairperson of the Criticality and Radiation Safety Committee.
Recommendation C4:
Assure that nuclear safety analysts and reviewers understand nuclear safety criteria and SNM-6% license requirements.
Resoonse C4:
The Manager of Nuclear Safety is committed to assuring that all persons performing safety analyses or reviews are f amiliar with and understand nuclear safety criteria and SNM-696 license requirements.
Toward that end, the Manager of Nuclear Safety is preparing a guide of "how to" perform nuclear safety evaluations for GA f acilities.
As a complimentary effort, three Individuals at GA who are quellfled to perform those nuclear safety tasks have been identified (see Response C3). __ ___ __ _____ - _ - _ __-__ - ______ _________________________ _ _____ _ _
Additionally, GA's Manager of Nuclear Safety, or his deputy, will be attending the 1987 Nuclear Criticality Safety Short Course sponsored by the University of New Mexico (on June 1-5, 1987), and will subsequently Instruct other qualified Individuals on any new material or information.
Recommendation C5:
Assure that work station criticality limit signs are correct before use.
Resoonse CS:
The Manager of Nuclear Safety has issued a procedure for posting limits / restrictions for all new process stations.
The supervisors of fuel fabrication facilities were advised to folicw this procedure in the future.
The procedure requires them to submit a photocopy of each new sign for Nuclear Safety review and approval. They were also requested to provide Nuclear Safety with a complete list cf existing stations and their posted limits.
Nuclear Safety is in the process of verifying the accuracy of these station limits by reviewing the appropriate Nuclear Safety evaluation files.
Recommendation C6:
Adopt a standard work station criticality limit sign format.
Resoonse C6:
GA agrees that the adoption of standard station limit signs is a good practice and, therefore, desirable.
However, unless an old sign is in error, or not legible, its conversion for the sole purpose of conforming with the standard is not warranted at this time.
Instead, a new procedure has been Instituted that assures the validation and verification of all new station limit signs (see Response C5). For these signs, the standard format will be applied.
Under this format, the sign will provide the station number, name, and applicable limits / restrictions.
1 Recommendation C7:
Prohibit the use of unsafe geometry waste containers at work stations.
(TRIGA) 4
7 Resnonse C7:
The use of specific containers, which are not "ever-safe" geometry containers, has been evaluated and approved for corresponding specific locations in various fuel fabrication facilities.
In particular, the nuclear safety evaluation of TRIGA Fuel Fabrication Facility ( SNM-6%, 1 3-164, 1 3-181) allows the use of containers of specific geometries. Scrap, in the form of chips and turnings, initially collects in the bed of the machine tool being used.
This scrap material is promp:ly removed to 5-gallon metal storage containers with the special nuclear material (SNM) amount per container limited to 350 g
/
U-235; this is established through gross weight and the nature of the alloy in process.
Due to the spring-like nature of this scrap, a 5-gallon container cannot hold the limiting amount of SNM.
In view of the verified nuclear safety justification for doing so, and the past history of usage of such containers, it is not reasonable or desirable for GA to institute a blanket ban on the use of "non-ever-safe" geometry containers.
One of the reasons for carrying out nuclear safety evaluations is to establish the limits of mass and/or volume for each process station; i.e.,
to establish what is and what is not allowed / safe.
Rec.
ndation C8:
Clearly label special nuclear material vault storage condition exceptions.
(TRIGA Fuel Fabrication Facility vault.)
Resnonse C8:
The supervision of TRIGA Fuel Fabrication imple-mented a procedure for labeling non-SNM ltems in the vault.
Nuclear Safety's inspection in March, 1987, verified the implementation of this procedure.
Ran-- ndation 09:
Improve the distribution of the CRSC audit reports.._
o O
Reznonse 09:
The Manager, Licensing, Safety and Nuclear Compliance will work with the Chairman of the CRSC to assure consistent and proper distribution of the audit reports.
The Managers of Nuclear Safety and Health Physics will certainly I
receive copies.
Re-ndation C10:
Improve the communication between successive
}
managers of Nuclear Safety.
Rannonse C10: The previous managers of Nuclear Safety have been consulted on numerous occasions.
Their services have been retained to assist Nuclear Safety as needed.
In addition, Nuclear Safety is planning to invite D. C. Pound to give a multi-session class on the background / specifics of nuclea-safety evaluations at GA in the second quarter of 1987.
Mr.
Pound resides in San Diego and is available to assist GA on short notice if necessary.
(A consulting agreement with Mr.
4 Pound is now in effect.)
Ran -
ndation C11:
Assure availability of documentation supporting work station limits and controls.
Resnonse C11:
Nuclear Safety maintains extensive documentation of nuclear safety evaluations.
Nearly 200 flies were created in support of SNM activities at various fuel fabrication facilities.
However, the search of these files for a given nuclear safety evaluation was not straightforward because of the Incompleteness of the file index.
The nuclear safety files were reviewed and The file index (NS File 500.0) was updated.
As soon as the process station limits in various fuel f abrication j
f acilities are compiled, they will be cross-referenced to their corresponding Nuclear Safety evaluation file index.
(The target completion date for this offort is August, 1987.)
As a result of this flie review, the nuclear safety evaluation i
of the liquid waste dump station in the SVA Fuel Fabrication.
- - - - - - - - - - - - - - l
Facility was located.
This evaluation was carried out in response to an NRC request in 1982.
Unfortunately, it was l
misfiled and could not be produced on short notice for the January, 1987, NRC audit of Nuclear Safety.
Recently, the nuclear safety evaluation of the SVA Fuel Fabrication Facility IIquid-waste dump station was expanded to include the restrictions that are administratively implemented in procedure FPD-802 that deals with operatloa of this station. Furthermore, In order to f acilitate access to nuclear safety evaluations of 1
all SNM-boaring liquid waste dumping stations, all of these evaluations are now grouped in Nuclear Safety File 528.0 (The SVA dump station was assigned Nuclear Safety File 528.2).
1 Ra..- -
ndation C12 Assure the availability and use of the latest criticality data, standards and guides.
Roanonne c12:
Nuclear Safety maintains an extensive library of publications on the subject of criticality safety.
Funds have been allocated to add to this library. Nuclear Safety, through membership in the Criticality Safety Division of the American Nuclear Society (ANS), keeps informed on new publications. The latest acquisitions are i
1.
" Nuclear Criticality Saf ety Experiments, Calculations, j
and Analyses," Vol. 1 & 11, UCRL-53369. 10/21/82.
2.
" Nuclear Criticality Safety Assessment Calculations,"
)
LLNL-M-164, Part 1, 6/17/85.
3.
" Nuclear Criticality Safety Assessment Calculations,"
i LLNL-M-164, Part 2, 8/5/86.
i 4
" Nuclear Criticality Safety - Theory and Practice," by R. Knief, 1985.
1 i 1
b 5.
" Criticality Safety in the Storage of Fissile Materials," ANS Proceedings, 9/11/85.
6.
" Criticality Safety," ANS Proceedings, 1986.
(On order.)
Nuclear Safety also maintains a file of applicable Regulatory Guldes and ANSl/ANS Standards. The Manager of Licensing, Safety and Nuclear Compilance updates Nuclear Saf ety with the latest developments in the regulatory ffeld.
The Manager of Nuclear Safety attendt.d the 1986 Criticality Saf ety Short Courso sponsored by the University of New Mexico and the Deputy Manager of Nuclear Safety will attend the 1987 Criticality Safety Short Course (in June,1987).
D.
FIRE PROTECTi(W Recommendation 01: Provide and assure the use of more lockers for storage of flammable liquids.
Rosconse D1:
A hazardous waste / hazardous material management program is being implemented at GA on a priority basis.
This program is aimed at properly controlling hazardous materials on a company-wide basis (soo response G2, G3, and G4).
This program will includo provisions to reduco flammablo Inventories, dispose of flammable liquids no longer needed, and assure proper storage of flammable liquids.
If additional flammable liquid lockers are nooded af ter the inventory reduction program has been implemented, they will be purchased.
Recommendation D2:
Make modifications as nocessary to assura a rollable sourco of water for firefighting.
g
Resnonse D2:
GA has continued to upgrade the underground water supply system throughout the facility.
In the last three years, GA has completed scheduled replacement of approximately 1,000 feet of underground water main and has Installed approximately eight additional sectional valves in existing pipe which improve availability and our capability to isolate and bypass defective sections of pipe until repairs are made.
In the event of a water main failure, GA Immediately implements the following compensatory measures:
l a.
Immediate isolation and call-in of repair crews.
b.
Dispatch Emergency Services Technician as fire watch in the area where fire protection service is Interrupted.
Installation of temporary service by one or more fire c.
hose bypass loops around the affacted area.
d.
Notify insurance carrier of failure.
In most Instances, repairs are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The single source of supply cited by the Inspector is the only l
source available from the City of San Diego.
However, the city is processing development plans for property near GA which may i
result in another source of supply in the f uture.
GA will continue to maintain and upgrade the existing system as opportunities appear.
)
Rece ndation D3: Upgrade Pre-Fire Plans to reflect location and type of fire suppression equipment available.
Enssanss_DI:
The subject plans are up-to-date and are revised i
periodically to keep them current.
3.
Rece ndation D4:
Improve the hazardous material locator list to reflect the types and the amounts of hazardous materials fire-fighters may encounter at spectfIc Iocations.
Resoonse D4:
An Inventory of hazardous materials and the!r location is submitted to the County Department of Health Services (DOHS) annually.
00HS reviewed our hazardous waste program during April,1987.
Additionally, during March and April of 1987, a representative of the City of San Diego Fire Department conducted an inspection of the entire GA f acility.
During this inspection, special attention was given to hazardous materials firefighters might encounter if they were called upon to fight a fire.
Recommandation D5:
Evaluate the adequacy of the size of the omergency services staff.
Resoonse D5:
The Emergency Services Department is adequately staffed to perform those duties for which they were organized.
The available staff were taxed by the department having assumed, out of necessity, additional work / responsibility. The addition-al responsibility is primarily associated with handling GA's hazardous waste.
GA is now in the process of formalizing a hazardous materials program which will provide relief to the Emergency Services Department.
Implementation of this program i
will include the immediate hiring of an additional Emergency Services Technician and a reduction in the Emergency Services Department's responsibilities in the area of hazardous materials.
(See also Response G2, G3, and G4.)
Rec-ndation D6:
Evaluate the adequacy of the propylene tank storage area.
(GA should evaluate storage areas around the propylene tank and move trash dumpsters to a different location.)
Basponse D6:
The flammable materials stored in the northeast corner of the gas pad have been removed. The area has been.
marked with yellow striping as a " keep clear" area and the waste receptacles that were in that area have been moved.
The propylene tank storage area was reviewed during the facility inspection conducted by the City of San Diego Fire Department in April, 1987.
No violations were identified. Additionally, the tank was inspected by American Nuclear insurers and a renewal permit issued on January 28, 1987.
Race - ndation D7:
Provide signs and storage of flammable materials in accordance with applicable National Fire Protectica Association (NFPA) codes.
Resnonse D7:
GA is providing signs and storage for oxidizing materials and flammable materials as appropriate in accordance with application National Fire Protection Association Codes. As inventories of hazardous materials are identified, the corresponding Material Safety Data Sheets and the proper NFPA labeling procedures are collected and placed in a loose leaf binder.
This binder is then Identified by listing the name of the custodian and the location of hazardous materials on the cover.
Proper labeling procedures and the contents of the Material Safety Data Sheets are reviewed with or explained to the appropriate employees when the binder is placed in the work area.
a Rec.
ndation D8:
Renew, paint, and relabel pipes that transfer hazardous materials.
(Refers to SVA/SVD gas pad.)
Response D8:
Excess piping has been removed from the Building 37/39 gas pad and pipes have been painted and relabeled.
Rec.
ndation D9:
Assure that safety-related valves and gauges receive preventative maintenance.
(Refers to SVA/SVD gas pad.) -
=-
o s
l Ramnanna 09:
Corroded valves and gauges have been cleaned and painted, or removed and replaced, where appropriate.
l Rec.-- r.dation D10:
Assure that storage tanks are properly grounded.
Rannonna D10:
GA will properly ground storage tanks as appropriate in accordance with applicable codes / regulations.
The gas pad acetylene trailer grounding hardware has been replaced.
Recommandation D11:
Consider reducing the hazardous material Inventory.
Rannonna D11:
Reducing hazardous material Inventories whenever and wherever appropriate will be an Integral part of the i
hazardous materials control program that is being implemented at GA.
Regarding the propylene Inventory:
In view of the high price of this material, the probable increase in cost in the future and the projected start-up of fuel operations in one-two years, it was decided that the propylene inventory will remain.
The propylene tank will, of course, continue to be inspected periodically to assure safe storage.
Rae.
ndation D12:
Consider use of an Independent expert for evaluation of the site fire potential and the preventative and mitigating methodology In place.
Fannonsa D12:
Fire potentials and preventative mitigating 1
methodology is routinely reviewed by American Nuclear insurers.
Inspections conducted at GA by American Nuclear Insurers since January,1986, have included those performed by the followings (1) Senior Staf f Engineer, Technical Review Section; (2)
Director, Administrative Section of the Property Engineering Department; (3) Regional Field Engineer, Fire Protections and
l.
l (4) Senior Staff Engineer, Nuclear Engineering Department.
E.
SYSTER EaullREERIMB i
Rac---
,dation E1 :
Consolidate scattered information related to original designs or perform analyses where the original safety analyses and design bases are no longer available.
Ra<nonna Ett An ef fort will be made to accumulate existing documents containing information pertaining to the equipment design bases or saf ety and performance analyses.
As equipment is replaced or new equipment added, appropriate documentation wlll be collected.
R= - -
dation E2:
Maintain up-to-date "as built" drawings for each process system.
Ramannma E2:
GA's Nuclear Fuel Tabrication Division maintains drawings of process equipment (but not of process systems). The benefit to be gained by developing an up-to-date library of i
drawings for each process system at this time would not justify the enormous expense of so doing.
Ra -
ndation E3:
Assure reliability of the criticality alarm system through surveillance and testing at the current level - as a minimum.
Rannonna E3:
The criticality alarm systems at GA meet the requirements of 10 CFR 70.24(a).
Each system is tested monthly using Internal check sources or portable sources - as a minimum.
Continued surveillance and testing is and will continue to be done at the current level to assure reliability of these systems.
Rae-ndations E4 and E5:
Fully test all safety features on the TRIGA Fuel Facility Fines Furnace Control System prior to
' 1
o operation of the system.
Periodically test equipment safety functions during operations to assure their readiness.
(TRIGA)
Resnonse E4 and E5:
The fines furnace relay ladder logic control system has been replaced with a programmable logic controller (PC).
This unit provides exactly the same control logic as the obsolete mechanical timer system, but it does not include the reset and power loss problems associated with the older motorized components. This new responsiveness in turn has allowed a self-test of the redundant components to be included in the initial stage of a burn-back run.
The PC compares each pair of sensors and each pair of accuators to insure that all components are functional before proceeding into the actual burn process.
Elther test f ailure (the test itself) or equipment failure shuts the system down. This system provides 100 percent verification that the redundancy designed into the system is operational.
A new maintenance schedule is being prepared to include hardware calibration intervals which will place the detectors on an appropriate confidence level.
Thesa Intervals will be directly from the GA Quality Assurance Manual.
This plan will be implemented within 90 days.
One point of Interest--this system does not have to be
" scrammed."
It was designed to be in the " scram" modo unless some activo device "Ilf ts" It out.
Each start-up verifles that the scram system works.
The operator then activates devices to lift it to the level required for burn-back.
If anything falls, it drops to the " scram" state.
Rece ndation E6:
Implement a scheduled preventative maintenance program for process equipment.
(SVA)
Easgonsa_Efi A preventative maintenance program for Nuclear Fuel Fabrication process equipment has been in operation since -
l the plant was shut down in April, 1985.
This program will be reevaluated and modified as appropriate when the facility restarts.
Rec m ndation E7:
Evaluate the QA program and expand its appil-cability to the process equipment.
I Resoonse E7:
We have evaluated our current QA program of process Instrumentation and equipment calibration coupled with periodic checking and determined that it is adequate.
I F.
.llE11STRIAL SAFETY Reena=andation F1 Continue to provide strong leadership to the plant safety committeo.
Resoonso F1: GA management romains committed to providing and supporting strong leadership to the plant safety committee.
Recommendation F2:
Considor using sito area managers on the com-mitteo to enhanco lino management involvement and responsibility for safety in those same areas.
l Rosoons d e The Plant Safety Committeo consists of a I
chairperson and a vice chairperson appointed by the Prostdont, members representing the operating divisions appointed by the Senior Vice Presidents of the operating divisions, and the Industrial Safety Engineer.
The Vico Chairperson serves on the committee for two years; the first year as Vico Chairperson and Recording Socrotary, the second year as Chairperson.
Members representing the operating divisions are, in turn, the chairpersons of organizational safety committoos appointed by the Senior Vico Presidents of iho l
operating divlslons. Chairpersons of the organizational i
l l i
1 committees are at a level of branch manager or above.
The industrial Safety Engineer is a permanent member.
Race-ndation F3:
Consider various means of grading safety performance by area.
l l
1 Rannonne F3:
This is achieved to some extent by the monthly accident report and annual safety performance report.
The monthly accident reports list reportable accidents and identify the responsible GA organizational unit.
The annual safety performance report summarizes the recordable injuries for the year and graphically displays the number of cases for each senior vice president.
For each senior vice president's area of responsibility, the number of cases per manager / director is also given (in graphical and tabular form).
Race ndation F4:
Consider area safety performance when assessing performance of the respective area manager.
Ratoonsa F4:
" Safety administraticn" has been added to the list of supervision / management performanco attributes which are rated l
annually as part of an Individual's job performance appraisal.
Race-ndation F5:
The Saf ety Committee should review the adequacy of Inspections of the smaller laboratories.
Response F3: The GA Plant Safety Committee will place increased emphasis on its review of the adequacy of the organizational inspection programs for the many small laboratories.
Race-ndation F6:
Assure that gas bottles and gas bottle carts are proper 1y immobilized.
Responia_f6:
High pressure gas bottles are to be handled according to Company Proceduro 14
" Handling and Use of Compressed Cases." This includes a requirement that " cylinders
' 1 E-- - -- -----------
should be secured to keep them from f alling over." This pro-cedure is enforced by inspection teams from the divisional safety committees.
"Six-packs" will be tethered to prevent excessive movement during earthquakes.
Liquid nitrogen dewers are not considered high pressure gas bottles and are not required to be secured under GA policy.
General practice is to secure large devers to a low level welding cart with a wide wheel base.
In 1979, an engineering review of the stability of this system was conducted.
G.
HERETRIAL HVRID E D= --
,dattan Q1: Develop clear lines of authority and responsi-bility for a systematic Saf ety and Health Management System.
Ramnanaa Q1:
GA provides a comprehensive safety and health program implemented through line management.
Assistance is provided by Medical, Emergency Services, Health Phybics, and Industrial Saf ety.
Employees are responsible for working in a safe manner in accordance with established operating procedures and practices.
The Manager of Health Physics, the industrial
$afety Engineer, the Medical Coordinator, and the Supervisor of Emergency Services report through their respective managers to the Director of Human Resources.
Further assistance is provided through the Plant Safety Committee whose chairman reports directly to the President.
Rac--- ndatlann Q2. Q3. and QA:
Fill the recently vacated Industrial hygienist position, eliminate incompatible chemical storage, and consider Installation of toxic gas monitors where appropriate.
Ramanna Q2. Q3. and ad:
Dr. R. V. Challam, an Industrial hygienist with experience in toxicology, analytical chemistry, epidemoology, and teaching has been retained by GA for two days.
t l
(or more, if necessary) per week.
His duties include a) hazard communication training; b) Industrial hygiene surveys: c) evaluation of chemical laboratory procedures; d) analysis of reports; e) hazardous materfal/ waste Identification, l
neutralization, and disposal training; f) risk assessment of hazardous materials used in-house; and g) evaluation of the use of alternative materials for potentially hazardous and/or toxic materials.
l l
GA is now in the process of developing and implementing a hazardous materials / waste control program.
Mr. R. J. Bott (Industrial Safety) has been appointed Hazardous Materials Manager and will be responsible for coordinating this ef fort.
Ms. L. K. Alfonso (Analytical Chemistry) is transferring to the industrial Safety organization to serve as deputy manager of this program.
Ms. Alfonso will be devoted f ull-time to hazardous motorial/wasto control.
Additionally, Emergency Services is hiring an additional Emergency Services Technician in order to increase their capability to provide support as noodod.
The program outilno includes provisions for the ollmination of incompatibio chemical storage through a more I
vl orous training program accompanied by an overall company 0
Inventory program.
Support for the hazardous materials /
hazardous wasto mana0cmont program includes the Industrial hyglonist consultant who reviews requirements for toxic gas monitors based on inventories submitted by divisional safety representativos.
H.
IMEDCY.fEPNIGESS Raccamem:AllDA lll.
Consider combining ihn Radiation Safety Courso training Information in the Health Physics computer f flo with the trainin0 Informatic.) in the computer fIlo administered by the Superviso of Emergency Services to f acilitato assessing trainin0 noods.
The Health Physics computer file trainin0 records should also be mulntained.
l 1
1.
.,o*
i Basgonna H1:
The radiation safety training records for applicable emergency team membe.*s have been given to the Supervisor of Emergency Services.
Prior to the annual radiation safety ref resher training class each year, an updated list of emergency team members will be provided to Health Physics by l
Emergency Services so that the appropriate members can be
)
scheduled for 'he course.
Af ter the course, the Information will be given to Emergency Services for incorporation into their computer file.
Health Physics will continue to keep a separate computer ffle of training records.
Race-- ndation H2:
Consider establishing contact with the San Diego County Emergency Response Office.
Rannonna H2:
This of fico could not be Identified; however, there is a County Office of Disaster Preparedness which has the responsibility of coordinating radiological incidents in conjunction with the Radiological Manager, County Department of Health Services.
GA has very close coordination with both of these of fices and the key figures are well known to us.
In f act, Frank Bold, a former GA employee, who was GA's Manager of Health Physics and Safaty Services, is the Radiological Manager.
Race-- ndation H3:
Consider use of the State of Callfornia l
Protective Action Guides (PAG) rather than that of the EPA in the GA Technologies Radiological Contin 0ency Plan.
Easponsa_Eli The use of the State of California Protective Action Guides rather than those of the EPA will be considered, and used if deemed more appropriate.
Bacosmandation_li(
Increase interfacing frequency with Scripps Memorial Hospital and include a " patient" transfer to them, at two-year Intervals at most, in exercises. l l
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Rannonna H4:
GA's approved Radiological Contingency Plan, May, 1984, does not establish specific frequencies for the conduct of training drills.
However, the plan is being revised and a specific time frequency will be established.
Revision of the plan should be completed by October I,1987.
The recommended frequency of two years for drills, including transfer of patients, is considered by us to be too frequent.
We acknowledge the fact that, when viewed in isolation, it would seem like a very viable programs however, the time and expense involved (by both GA and the hospital) In coordinating and conducting drills represents a major expenditure of assets.
When the additional training benefits that may be gained from a two-year cycle versus a four-year cycle are objectively analyzed, the increased frequency is not merited.
This is especially true when consideration is given to the fact that the number of medical emergencies that we must evacuate to the hospital has averaged two per month, and, except for the radiological aspect, the procedures followed are basically the same in all emergencies (preparation for transporting, notification of medical facilities, delivery and contamination control).
Also, the need for such frequency la further negated by the f act that we oro in a shutdown mode and chances of a redlological incident is very remote.
Our position is also based upon observations of other inspectors, including the NRC, who have suggested that a four-year cycle is a more realistic time period for conducting such exercises.
This observation is especially valid when i
considered in conjunction with the other trainin0 and coordination activltles such as the Information program outilned in the following paragraph.
The revised plan will provide for invitin0 members of participating of f aslte support groups to GA, at a point in time - -
,0
- about mid-way between exercises, for discussion of any changes, planned or actual, to the emergency plan and an update of ongoing programs.
Race-ndation 115: Plan earliest possible notification of Scripps Memorial Hospital whenever a decision has been made to transport a patient there.
Rannonse H5: This is standard practice and it is done everytime GA transports or sends a patient to the hospital.
Race-ndation in:
Consider consolidation of the separate emergency plans into a set of plans that are cross-referenced and indexed.
Raanonsa_15:
A yet undetermined number of GA emergency plans will be consolldated and Indexed.
Olstribution of these combined sets will be made only to those select activities having a need for all the plans.
Recommendation lf7:
Incorporate a section on hazardous materials emergencies into the plan.
Responia_1fI When the Radiological Contingency Plan and General Emergency Plan are updated, a section relating to hazardous materials omorgencies will be included.
Encommendadon.12: Consider including a terrorist based emer0ency section.
Rasaanta_lia: When the Radiological Contin 0ency Plan and General Emergency Plan are updated, a section relatin0 to terrorism will be included.
RecommendallsnJ12:
C1erIfy the idontIfy of ihe Emergency Coordinator (EC). - - - -
- 6' Rannonte H9:
Any confusion that may have existed in this area resulted from GA organizational changes and the f act that the plans have not as yet been updated.
Internal GA Information/
training sessions have now resolved this.
Updating of the plan will further clarify this area.
Rae.
ndation H10 Improve documentation regarding planning and execution of drills and exercises.
Retoonse H10:
Present instructions directing this action will be expanded upon when the emergency plans are updcted.
Recormandation H11:
Conduct independent audits of plans, dellis, and exercises.
Estnonso H11:
While we believe the current system of having those persons most knowledgeable of the plans and appropelate actions perf orm the critiques is adequate, consideration is being given to also including other GA staf f members as reviewers.
Race-- ndation 111 2 :
Resolve inconsistencies between GA Technologies' plans and the City of San Diego's Radiological l
Response Plan.
1 i
Responta.Jil2:
The city's plan will be reviewed and if Inconsistencies exist, they will be noted and, when possible, discussed, but not necessarily resolved as the final content of the plans are governed by difforent regulatory bodies.
l Recommandat.lonJ111:
Describe space and equipment functional allocations for the control center.
EaspanaaJ111:
A more detailed description and allocation, to the extent po:sible, will be included in the updated plans. 1
2
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Recommandation H14:
Review the various of f-site plans for consonance regarding the various jurisdictions and their roles and responsibilities.
Raannnam H14:
GA wili endeavor to become knowledgeable of the various plans, but is not prepared to, nor do we believe we I
should, act as a leader in the formation of a forum to address and resolve differences.
1.
AnnlatosiCR SMETY D=. ----- ndat i on 11:
Assure that continued training of Health j
Physics technicians will include participation in the audits that assess the adequacy of the condition of site radiological safety support systems.
Ramnanna 11 :
Health Physics technicians now accompany the Manager of Health Physics during inspections at the various facilities.
Current activities in the f acility being inspected are discussed with the technicians as well as operations, prob-lems, license and regulatory requirements, and contamination /
radiation levels.
Items reviewed are documented and reports are distributed to the appropriate personnel.
Future training will continue to include participation in the audits as well as Individual inspections by the technicians themselves.
t I
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