ML20236W519

Insp Rept 70-0734/98-02 on 980629-0701.No Violations Noted. Major Areas Inspected:Mgt & Organizational Changes,Radwaste Mgt Activities & Validation of Portions of Licensee Final Radiological Survey Program for Site Decommissioning

ML20236W519
Person / Time
Site:	07000734
Issue date:	07/31/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236W511	List: ML20236W509 ML20236W519
References
70-0734-98-02, 70-734-98-2, NUDOCS 9808060032
Download: ML20236W519 (11)

Text

- - _ - - _ _ _.

U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:

70-734 License No.:

SNM-696 Report No.:

70-734/98-02 Licensee:

General Atomics Facility:

Torrey Pines Mesa and Sorrento Valley Facilities Location:

San Diego, Califomia Dates:

June 29-July 1,1998 Inspectors:

H. Dean Chaney, Fuel Facility / Decommissioning Inspector Wayne L. Britz, Fuel Cycle inspector Accompanied by:

D. Blair Spitzberg, Ph.D., Chief, Nuclear Materials Safety Branch 3 Approved By:

D. Blair Spitzberg, Ph.D., Chief, Nuclear Materials Safety Branch 3 Division of Nuclear Materials Safety I

Attachment:

Supplemental Information 1

).

9908060032 983731 PDR ADOCK 07000734 C

pg I

L

. EXECUBVE

SUMMARY

General Atomics (GA)

NRC Inspection Report 70-734/98-02 This routine, announced inspection focused on management and organizational changes, radioactive waste managemen'.3ctivities and validation of portions of the licensee's final radiological survey program for site decommissioning activities. Specific attention was given to activities involving Building 23 (Hot Cell Facility), Building 22 (TRIGA Fuel Fabrication Facility-TFFF), Building 9 - Room 49 (former TRIGA fuel fabrication facility), Building 27/EA-1 (former radiochemistry research laboratories) and Building 39 (Sorrento Valley B).

.Manaoement Organization and Controls Licensee management controls and staffing appeared adequate for providing oversight of decontamination and decommissioning (D&D) activities. The licensee's audit program appeared effective in identifying and correcting program deficiencies (Section 1.1).

Radioactive Waste Manaoement Licensee handling, packaging and storage of contaminated and non-contaminated waste from D&D activities appeared adequate (Section 1.2).

Licensee Final Survevs and NRC Confirmatory Surveys Licensee preparations, survey plans, conduct of the surveys, and analysis of the results of the facilities inspected appeared adequate (Section 1.3).

Specific surveys conducted by the inspectors alongside the licensee indicated the licensee's surveys were adequate (Section 1.3b(7)).

l l

l l:

~

. Report Details i

Summarv of Facility Status All production and research activities involving use of special nuclear material (SNM) had been dismntinued. By letter dated September 30,1996, the licensee submitted a Site Decommissioning Plan (SDP), which is under NRC review. During a March 20,1998, meeting with the NRC Fuel Cycle Licensing Branch, GA ind:cated it had increased the tempo of decommissioning activities at the site.

At the time of the inspection, licensee activities consisted of D&D of various site buildings and structures as outlined in the GA/SDP. Following extensive site characterization, several site areas with little chance of being radiologically contaminated had been radiologically surveyed for release from the NRC and State of California radioactive materiallicenses.

Areas reviewed during this inspection involved NRC licensed activities associated with D&D at:

Building 9 - Room 49, (former TRIGA fuel fabrication facility) had been stripped of all equipment and the floor had been remediated where levels of radioactivity exceeded the residual radioactivity guideline values. At the time of this inspection, the licensee was still detecting residual radioactivity above its action limits (about 25% of the appropriate NRC residual radioactivity values for the isotope of concern). Soil sampling had been conducted beneath the cor, crete floor of the facility. No residual radioactivity above the appropriate criteria was detected in the sampled soil. The licensee did not consider this facility to have undergone a final status survey. Comparative radiological surveys of this facility, with the licensee, were accomplished during this inspection.

Building 22 (TRIGA Fuel Fabrication Facility [TFFF]) had been stripped of all equipment and concrete floors had been decontaminated by surface abrasion / grinding. Subsurface coring and soil sampling of the building footprint (including outside areas) had been accomplished. Soil contamination consisting of enriched uranium above release limits was detected in several samples during remediation. Extensive concrete removal had been undertaken to expose the soil below the floor of TFFF for remediation and further sampling. The licensee had completed interior soil remediation and was conducting external soil sampling around the building perimeter. Interior and exterior surfaces of the TFFF were free of residual radioactivity above release limits. The licensee was just completing the final survey of the facility during this inspection. Cursory radiological surveys of the building with the licensee were accomplished during this inspection.

Building 23 (HCF) had ailinterior and exterior walls, and the roof removed. Some exterior walls were to be disposed of es non-radioactive material. The hot cells were in the process of being cut up into manageable pieces for disposal as radioactive waste.

The exterior building wall (concrete filled bui! ding blocks) was cut up into manageable slabs for handling and disposal.

. The licensee, by letter dated June 3,1998, informed the NRC that a significant amount of

" clean building debris" would be disposed of at a locallandfill. Cursory confirmatory radiological surveys of the staged debris (several tons of concrete building block walls) was accomplished by the inspectors during this inspection.

Building 27/EA-1 (former radiochemistry research laboratories) had been stripped of all equipment and remediation of floor surfaces and subfloor soil had been completed. A final survey had been completed for the facility prior to this inspection.

Most recently the licensee's Possession Only License activities and D&D program attributes were discussed in NRC Inspection Report Nos. 70-734/98-01 (January 1998),70-734/97-05 (December 1997), and 70-734/97-02 (June 1997).

1 Conduct of Decommissioning Activities 1.1 Manaoement Organization and Controls (88104 and 88005) a.

Insoection Scoce The inspector reviewed and discussed the current health physics organization structure, staffing, functional assignments, and audits to determine compliance with the description in Section 4 of the SDP.

b.

Observations and Findings The licensee's organization was being maintained as described in Section 4 of the SDP.

The replacement health physicist's qualifications for the HCF D&D were reviewed. e new health physicist met the qualification and experience criteria established in the W SNM License.

The review of the radiation protection program content and implemernation as required by 10 CFR Part 20.1101(c) was inspected. The Criticality and Radiation Safety Committee (CRSC) audit reports required by Safety Condition S-5 of the license were feviewed. The 1997 and 1998 semi-annual radiaiion safety inspection reoorts required by the licensee's procedures were reviewed. The licensee audits of the radiation protection program were found to have been adequately planned and executed. The licensee's review and closecut of the findings was reviewed and found to be adequate.

Overall, the licensee audits required by the regulations and the license conditions were found to be adequate.

The organization of the Quality Assurance (QA) groupwas reviewed. The QA oversight was proactive and effective. Safety Condition S-4 of the license states that the Director QACD has autnority for termination of certain activities. The inspector found that due to organizational changes, the licensee no longer had a position entitled " Director QACD."

i The inspectors noted that the Director, Licensing, Safety and Nuclear Compliance e-____

. currently performed in that function. The inspectors recommended that this change be i

reflected during a future license amendment.

c.

Conclusions The licensee effectively implemented a well documented and managed D&D program that conformed to regulatory requirements and the stipulations contained in the SDP.

1.2 Radioactive Waste Management (88Q35) a.

Insoection Scape The inspectors reviewed the areas of solid waste management and storage in relation to the decomrnissioning project. The inspection included tours of the licensee's solid waste generation and storage areas, b.

Observations and Findings The handling, packaging, and storage of contaminated and non-contaminated waste from the decommissioning project were reviewed. Waste storsge and surveys of debris determined to be non-contaminated were reviewed and surveyed as noted in Section 1.3 of this report. The handling, surveying, and packaging of contaminated waste was reviewed at the HCF. Large pieces of contaminated concrete were in the process of being removed, surveyed, packaged and stored for future shipment. Large pieces of non-contaminated concrete that had been surveyed by the "censee and stored for shipment to a landfill were inspected and surveyed.

c.

Conclusions The licensee's waste packaging and storage activities were consistent with the applicable regulatory requirements and licensee procedures.

1.3 Licensee Final Surveys and NRC Confirmatory Survevs (88104 and 83890) a.

Insoection Scooe The licensee's preparations, final survey plan, conduct of the final survey, and analysis of the resulto for selected areas within Building 9-Room 49, Building 22 (TFFF), Budding 23 (HCF exterior walls), and Building 27 (EA-1) were reviewed to determine their agreement with the methodologies contained in NUREG-5849, the licensee's SDP, and the requirements set forth in 10 CFR 70.38(j).

Limited scope confirmatory surveys (alpha, beta and gamma for fixed, looce and ambient gamma radiation exposure levels) of selected areas within the aforementioned buildings were conducted by the inspectors to determine the radiological status of the facuties being considered for release by the licensee. Based on a satisfactory review of the

6-licensee's soil sample collection, preparation, and analytical results, no soil samples were obtained for confirmatory analysis during this inspection. See Section 2.2 of this report for discussion of prev!ous NRC soil sample results.

b.

Observations and Findings (1)

Building 9, Room 49 Fixed and loose contamination surveys for alpha and beta radioactivity were conducted on walls and floort Side by side surveys with licensee personnel determined that areas of elevated residual contamination had been properly characterized.

(2)

Building 22 - TFFF During facility surveys, loose enriched uranium contamination was discovered in floor seams and some subsurfacc soil core samples. A cut approximately four-inches distance from the entire length of each side of the floor seams was made to expose the underlying fill and soil. Areas found contaminated in the initial sampling round were further sampled to depths up to 2 feet. All areas showing elevated results were remediated by removal of the soil to one foot or more below the bottom surface of the floor.

The licensee's soil sampling plans 7-10 were reviewed and found satisfactory. Soil j

Sampling Plan No.10 was for obtaining approximately 44 soil and asphalt samples

)

around the perimeter of the TFFF.

Fixed and loose contamination surveys for a!pha and beta radioactivity were conducted j

on walls and floors including drainage trenches located in the east side of the building, j

1 All areas were suitable for both alpha and beta contamination surveys.

j (3)

Building 23 - HCF Exterior Walls The NRC performed cursory radiological surveys (fixed alpha and beta / gamma radiation scans) of fourteen stacks of wall segments staged in an area located about 75 meters north of the HCF perimeter fence and behind the TFFF (Building 22). The wall segments were found to bc> suitable for unrestricted disposal.

l (4)

Building 27 (EA-1) l Fixed and loose contamination surveys for alpha and beta radioactivity were conducted on walls and floors (including areas excavated during remedisi:on).

All areas were suitable for both alpha and beta contamination surveys.

i

.. (5)

Building 39 (Sorento Valley B)

The inspectors reviewed the decontamination in progress in Building 39. The building was being stripped of contaminated material and areas above residual radioactivity guidelines were being remediated. Only one ventilation system was left intact for use during remediation activities.

(6)

General Licensee Survey Protocols The inspectors verified that the licensee routinely utilized large area gas flow proportional detectors for surface surveys involving alpha and beta radioactivity. The licensee also utilized alpha scintillation detectors for spot measurement of areas indicating elevated alpha contamination. Ambient gamma radiation exposure levels were routinely measured using sodium iodide microR type instruments.

(7)

NRC Radiological Surveys The inspectors performed limited scope surveys using the following NRC instrumentation:

Eberline E-600, NRC No. 063473, coupled to SHP-260 and SHP-380A detectors.

Victoreen 450P-DE, NRC No. 008596, Ion Chamber.

Background determinations using NRC instruments agreed with licensee values for similar type survey instruments. The majority of the inspectors' fixed radioactivity measurements were made using the 100 cnf Eberline SHP-260 detector (beta / gamma) and the SHP-380A (alpha) zinc sulfide scintillation detector. Loose radioactivity smears were field counted using both the SHP-260 and the SHP-380A (alpha) zinc sulfide scintillation detector.

instrument detection efficiencies and minimum detectable levels (MDLs) were established using traceable thorium-230, uranium 234/235, cesium-137, and technetium-99 calibration sources. MDLs were below the residual radioactivity criteria established by the NRC and those included in Table 6-1 of the licensee's SDP, revision dated April 18,1997.

The following residual radioactivity release guidelines (taken from NRC Policy and Guidance Directive FC 83-23) were used in analysis of the confirmatory survey results.

l

1 l

8-I Afoha and Beta Emitters:'

Total Activity (fixed & removable surface activity) 2 2

1,000 dpm/100 cm, averaged over 1 m 2

3,000 dpm/100 cm, maximum in 100 cnf Removable Activity 2

200 dpm/100 cm General Area Gamma Exoosure Rate Limit Less than 10 microRoentgen per hour ( R/h) above background when measured at approximately 1 meter (~3 feet) above surfaces / floors.

The 10 R/h value is authorized by the licensee's SDP.

Soecific Survey Areas Loose and fixed surface beta and alpha residual radioactivity measurements, and ambient gamma radiation exposure rates in uR/h, were obtained in the following areas:

(1)

Building 9, Room 49, (formerly TFFF): Residual radioactivity, enriched uranium, was detected in this portion of the building by the licensee and was still being remediated. Sueral side-by-side radiological surveys were conducted with the licensee and were found to be in agreement.

(2)

Building 22, TFFF: The licensee had detected elevated levels of residual enriched uranium in the soil below the main manufacturing area of the facility and had remediated it to less than the 30 picocurie per gram release criteria. The final survey for this facility was nearing completion during this inspection and several side-by-side surveys with the licensee were made. Several small areas on the concrete floor required remediation prior to the final survey.

(3)

Random surveys were performed on fourteen piles of structural walls from Building 23 demolition. This material had been radiologically surveyed by the licensee and cleared for disposal as non-radioactive material. This material was

'The above guideline for thorium (in equilibrium with radioactive progeny) is based on alpha activity and j

was selected as a conservative guideline value in lieu of the natural uranium or general beta / gamma radionuclides

{

guideline values, which are five times higher. Instrument senotivities were established at approximately 50 percent l

of the guidehne values with a 95 percent confidence value. During beta activity only surveys, the guideline value was reduced by approximately 33 percent to account for the reduced beta emission rate relative to the alpha emission rate for natural thorium. Beta surveys for enriched uranium took into account the lower residual radioactivity value for alpha emitters by restricting the minimum detectable activity limits for beta emitters.

1

.g.

located behind Building 22. The inspectors' survey found the s+ructural walls to

)

be suitable for unrestricted disposal.

(4)

Building 27, radiochemical research laboratories (AE-1): Residual enriched uranium, strontium-89, and cesium-137 contamination above release limits were identified in this facility by the licensee prior to remediation. Subfloor soil sampling and remediation had been undertaken in the building. The licensee had completed the final survey and was preparing the final survey repott. No ambient gamma exposure rates were obtained in this area due to instrument failure.

A review of the licensee's historical data on radioactive material use in the areas surveyed by the inspectors showed that enriched uranium, thorium, and cesium-137

)

were previously used in the areas. Approximately 10 -15 smears for loose beta and alpha radioactivity were taken in each area where surveys were performed by the inspector, excluding the Building 23 debris.

No residual radioactive contamination above NRC guidelines was detected during the inspectors' surveys. Detailed survey data and diagrams and will be placed in the Region IV license docket file.

c.

Conclusions Side-by-side readings taken with NRC and licensee instrumentation were consistent and no anomalous readings were noted in the survey results from Building 22, the Building 23 (HCF) demolition debris behind Building 22, or Building 27 (AE-1),

The licensee's final survey plan and final survey results for Buildings 22 (Phase 2) and Building 27 (AE-1) were suitable for determining the final status of the subject areas and their suitability for release to unrestricted use status. Building 23 debris (wall segments) located behind Building 22 was found to be suitable for unrestricted disposal.

2 Followup (92702) 2.1 (Closed) VIO 70-734/9705-01: Failure to actuate a manual fire alarm; and (Closed) IFl 70-734/9705-02: Review of licensee's investigation of a fire in the HLHC NRC Inspection Report 70-734/97-05, Section 1.1b, described the events surrounding the failure to actuate a manual fire alarm when personnel became aware of an ongoing fire in the Hot Cell Facility. Violation 97-05-01 was cited. IFl 70-734/9705-02 was opened pending complefon of the licensee's corrective actions and inspector's review.

The licensee provided a written response to the NRC on December 18,1997, describing corrective actions to avoid further violations.

The inspectors reviewed the corrective actions taken which included: (1) training records i

documenting the corrective action training, (2) a memo to personnel regarding the f

violation details, (3) a procedure revision, and (4) the occurrence report. The corrective 1

i

, I accions were orientated only toward the hot cell. The inspectors asked if there were generic implications to other facilities. Licensee personnel responded that they did not believe that there were other manual fire alarm facilities, but they would review other facilities to determine if the corrective actions should be applied to them. The inspectors verified the implementation of the corrective actions and had no further questions related to this issue.

2.2 Results of Previous Soilt Soil Samoles NRC Inspection Report 70-734/98-01, Section 1.5a reported that seven soil samples from the TFFF, which was under remediation, were collected and shipped to Region 111 for analysis. The comparison of the NRC and licensee results resulted in 12 f

agreements, one marginal agreement, and seven non-agreements. The results determinations were made from the criteria in IP 84525, " Quality Assurance and Confirmatory Measurements." The licensee provided the inspectors with explanations for the differences which included long versus short laboratory counting times, use of different gamma peaks for determination and analysis, and the low-level contamination in some of the samples. The inspectors agreed with these explanations and determined the soil comparison was acceptabis.

3 Exit Meeting Summary l

l The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 1' 1998. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

i i

l l

{.

[

j

ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee K. Asmussen, Director, Licensing, Safety and Nuclear Compliance L. Gonzales, GA Radiation Safety Officer / Health Physics Manager P. Maschka, Senior Health Physicist G. Branbiett, Project Manager, GA D&D S. Cowan, Senior Health Physics Technician J. Turner, Building 27. Project Leader W. Labonte, Hot Cell Facility (Building 23), Lead Health Physicist (Contractor)

D. Keesling, GA Health Physicist INSPECTION PROCEDURES USED IP 88005 Management Organization and Controls IP 88035 Radioactive Waste Management IP 88104 Decommissioning inspection Procedure for Fuel Cycle Facilities IP 83890 Closeout inspection and Survey IP 92702 Followup on Corrective Actions for Violations and Deviations 1

ITEMS OPENED, CLOSED AND DISCUSSED Opened None Closed 70-734/9705-01 VIO Failure to actuate a manual fire alarm 70-734/9705-02 IFl Review of licensee's investigation of a fire in the HLHC Discussed None LIST OF ACRONYMS USED D&D decontamination and decommissioning dpm disintegrations per minute GA General Atomics HCF Hot Cell Facility uR/h micro Roentgen per hour QA Quality Assurance l

QC Quality Control SDP Site Oc : commissioning Plan SNM special nuclear material 2

cm square centimeter 2

m square meter TFFF Triga Fuel Fabrication Facility I

,