ML20236X877
| ML20236X877 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/04/1987 |
| From: | Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236X876 | List: |
| References | |
| 70-0734-87-12, 70-734-87-12, NUDOCS 8712100331 | |
| Download: ML20236X877 (11) | |
Text
,
9 l
r U. S. NUCLEAR REGULATORY COMMISSION REGION V i
Report ~No.'70-734/87-12 I
. Docket No.70-734 License No. SNM-696 q
l Safeguards Group:
1 j
t Licensee: GA Technologies, Inc.
P. O. Box 85608 San Diego, California 92138 Facility'Name:
Torrey. Pines.Nesa and Sorrento Valley Sites
. Inspection at:
San Diego, California Inspection Conducted:
Oc ober 20 through 23, 1987 i
_7
' Inspectors:
B. L. Brock, Fuel Facilitias Incpector Date Signed Approved-by:
/8 7
R. D. Thomas, Chief Date Signed Nuclear Materials Safety Section Summary:
Inspection on October 20 through 23, 1987 (Report No.-70-734j87-1?)
Areas Inspected:
A reutine unannounced safety inspection was conducted of
-management' organization and controls, operator training and retraining, i
criticality safety, ope'ratfuns review, transportation of radioactive j
materials,. emergency preparedness, environmental programs, and g
deactivation / decontamination activities.
During this inspe-tion, the s
i procedures covered were 88005, 88010, 88015', 88020, 86740, 88050, 68045, and
)
83890.
l
-)
Results:
No violations were identified in the areas inspected.
I uq l
8712100331 871207 PDR ADOCK 07000734 C
PDR i
I 4
1
)
I e
1
DETAILS 1.
Persons Contacted
- R. N. Rademacher, Director, Human Resources
- K. E. Asmussen, Manager, Licensing and Nuclear Compliance
- R. C. Noren, Director, Nuclear Fuel Fabrication
- V. Malakhof, Manager, Nuclear Safety
- K. L. Johnson,. Manager, Facilities Engineering C. Wisham, Manager, Nuclear Materials Accountability "L. R. Quintana, Manager, Health Physics
- A. L. Galli, Manager, Security
- R. J. Bott, Industrial Safety Engineer
- J. M. Brock, Supervisor Emergency Services H. J. Lomax, Construction Planner, Facility Engineering
- Denotes those attending the exit meeting.
2.
Management Organization and Control License Condition 9 of SNM-696 incorporates the statements, representations and conditions specified in Part II - License Specifications as part of the license.
A.
Organizational Structure Section 3.1 of Part II - License Specifications permits the licensee to change organizational responsibilities, reporting locations and names,-providing such changes do not adversely affect the implementation of license conditions and they aro reported to the NRC within sixty days after the change.
(1) The licensee's organizational responsibilities are unchanged since the January 1987 team assessment.
Some personnel assignments have been changed since the last inspection.
In particular, the Industrial Safety Engineer is now responsible for hazardous materials management.
The Supervisor of Emergency Services is now responsible for hazardous waste management.
This division of responsibility is an outgrowth of the recognition of the magnitude of the hazardous materials communication program and is responsive to the assessment team recommendation G.I.
B -.
Procedure Controls Section 3.7.2 of Part II - License Specifications requires procedurer for all activities in which materials subject to this license ar.e physically handled, stored, and chemically or physically changed.
(1) The licensee has assured that the Industrial Safety Engineer was included in the approval chain for the new procedure
2 NWPF-2718, " Disposal of Liquid Waste to Sanitary Sewer".
The review of the related chemical thermodynamic calculations made in support of the procedure had not been reviewed by the Industrial Safety Engineer at the time of the inspection.
This part of his evaluation of the procedure will be reviewed during the next inspection.
Item (87-06-01) will therefore remain open.
C.
Internal Review and Audit Section 3.6 of Part II - License Specifications requires that health physics inspections be conducted quarterly and nuclear safety inspections be conducted at least annually for all areas possessing SNM and at least quarterly for areas possessing more than 500 grams of SNM.
(1) The NRC inspector reviewed the licensee's health physics and nuclear safety inspections.
Sixteen facility inspections were conducted by the Manager of Health Physics in the past two quarters.
The inspections were of sufficient scope and depth.
The problems identified were corrected immediately or were included on a follow-up items list to assure their correction.
The manager included the appropriate Health Physics Technicians (HPT) during the inspections to add to the breadth of problems they can identify.
This is responsive to recommendation I.1, and should be continued.
(2) Thirteen separate criticality safety inspections were conducted by the Manager Nuclear Safety or his deputy.
The inspections were conducted as required and were appropriately documented.
l The improvement in the scope and depth of the inspections warrants the closure of item (86-04-03).
The manager continues to appropriately follow-up identified items.
D.
Safety Committees Section 3.2.3 of Part II - License Specifications requires that the Criticality and Radiation Safety Committee (CRSC) report to the Office of the President via a designated Vice President.
The CRSC shall as a minimum:
(1) act in a radiological safety advisory capacity; (2) review policies and criteria established for safety of SNM operations; (3) provide second level review for nuclear safety analysis; and (4) audit work involving radioactive materials for conformance to and effectiveness of applicable procedures and practices including a review to determine how exposures might be reduced to meet ALARA.
(1) The Criticality and Radistion Safety Committee (CRSC) continues to carry out its review fur.ctions.
The annual ALARA review was completed as required and the final report was issued July 8, 1987.
The thorough review concluded that the tight rein held by Health Physics over several components has continued to result in an effective ALARA program.
The distribution of the individual reports to those audited, a change from previous
E 3
distributions, was responsive to the assessment team i
recommendation C.9.
(2) The licensee's monthly Hazardous Survey inspections (of a portion of the facility) are sufficiently broad that any item of safety significance is included in the report. The reports indicate the licensee is adequately responding to recommendation F.5.
(3) The licensee added safety administration as a performance rating area in the Supervision and Management category.
This responds adequately to recommendations F.3.and F.4.
(4) The licensee's responses in items (2) and (3) above along with their continuing high' interest in their safety program adequately responds to recommendation F.1.
(5) The licensee's use of' branch managers or above as the
.l chairperson of the organizational ccmmittees representing the operating divisions appears to satisfy recommendation F.2.
(6) The licensee's improved performance in the area of securing gas bottles satisfies recommendation F.6.
No violations were identified.
3.
Operator Training Section 3.2.2.1 of Part II - License Specification states that on-site radiological safety training will be conducted.
A.
The licensee's planned annual refresher training for 1987 was recently completed.
The course, three hours in duration, was given on three separate days with a makeup provided on a fourth day.
B.
Industrial Safety prepared a Hazardous Materials (HM) reference notebook for each of about twenty five areas.
The notebook included the licensee's Safety Newsletter addressing the Hazardous Materials Program elements.
It also listed the hazardous materials in the area and provided the required Material Safety Data Sheets (MSDS).
The notebooks were orovided in an area after completion of the required training of the affected employees.
The initial effort achieved about 85% participation and is continuing.
No violations were identified.
4.
Criticality Safety Saction 3.2.2.2 of Part II - License Specification requires assurance of nuclear criticality safety through review of proposed SNM activities and review of proposed changes in processing equipment and procedures.
It also requires frequent inspection and monitoring to assure adequate nuclear safety control.
Independent verification of all determinations of criticality limits are also required.
j C.
4 A.
Nuclear Criticality Safety Analyses (1) No Nuclear Safety Analyses (NSA) were undertaken since the last inspection.
(2) The files of NSAs are being reorganized including name
.)
clarification and tape backup.
These changes will improve access to the files and are responsive to recommendation C.11.
(3) The criticality limit sign review identified that dome modifications are needed.
The licensee indicated that signs needing replacement in deactivated areas will be replaced before operations. resume.
This action coupled with~the new procedure issued by the Manager of Nuclear Safety is responsive to recommendations C.5, and C.6.
(4) The guide that the Manager of Nuclear Safety prepared to assure the adequacy of nuclear safety evaluations is currently circulating for review.
The guide should prove.useful in precluding oversights during evaluations.
The guide and the reference materials gathered by the Manager of Nuclear Safety
)
are adequately responsive to recommendation and C.12.
l
)
(5).The licensee began the additional training planned for the three selectees scheduled to perform nuclear safety analysis j
reviews.
Instruction was provided on two d'ys with three additional sessions scheduled.
(6) The Deputy Manager of Nuclear Safety attended the Nuclear Criticality Safety Workshop in June 1987.
The workshop is
)
sponsored by the Department of Chemical and Nuclear Engineering of the University of New Mexico.
-(7) The licensee's plans are that the Manager or the Deputy Manager of Nuclear Safety will perform the independent reviews of NSAs made by the other analysts.
This plan along with the actions taken in items (5) and (6) above are adequately responsive to recommendations C.3, C.4, and C.10.
I (8) The licensee ir.dicated there were no transfers from the horizontal storage tanks on Building 39 (SV-B) because of the cessation of operations as the project ended.
The tanks would be used again when another operation commenced in the facility.
j Item 86-06-01 will remain open pending review of the dumping procedure controls.
(9) The licensee's attention to evaluation and control of the use of non-safe geometry containers is responsive to recommendation C.7.
(10) The licensee revised the criticality limit sign in the Triga vault to accommodate the changing coatainer types and J
restricted the vault to the storage of special nuclear material 1
(SNM).
This action is responsive to recommendation C.8.
l.
t i
o
5 J
No violations were identified.
5.
Operations Review
.Section 3.2.1 of Part II - License Specification requires that the
' licensee's organization conduct their respective activities within federal, state, and local rules and regulations, license criteria, arid company policy, criteria and established practices.
A.
Conduct of Operations (1) Hot Cells The low level hot cell new inlet metal piping has been nodified 3
to reduce the number of joints and right angle berds.
The final configuration, which was a significant improvement, removed all but the last right angle bend.
The manipulators, necessary for the conduct of operations, precluded the removal of the last right angle' bend.
Item (87-01-05) is therefore closed.
(2) Nuclear Waste Processing Facility (NWPF)
Some of the liquid scrap packaged for shipment to the Los Alamos National Laboratory is still stored on site (see Section 6.A.).
(3) Facility Exhaust Stacks The licensee has not completed the review of the adequacy of nozzles in place for isokinetic sampling of exhaust stacks.
The licensee's plan is to complete the review of all the facilities before taking appropriate corrective action.
This item (86-04-07) therefore remains open.
Additionally, the licensee has ordered stainless steel tubing for the stack sampling lines but has not yet installed it.
Item (87-01-06) remains open.
(4) Experimental Building The licensee had recently completed a cleanup and survey of
' portions of the Experimental Building which were under joint State of California and NRC jurisdiction.
These portions were each independently overchecked by the appropriate agency.
The NRC overcheck was the subject of inspection report l
70-734/87-11.
A third portion of the building, also under NRC i
jurisdiction,- has been scheduled for a resurvey by the licensee.
The results of the resurvey must be reported to the NRC prior to an independent NRC overcheck.
(5)
Laboratory Building The licensee had undertaken cleanup of the laboratories in a section of the Laboratory Building in which radioactive I
L L
1
l 6
materials had been used.
The licensee's report of the survey
.esults was recently received in the regional office.
Five of g
the twenty laboratories in this section had not been used for radioactive materials.
The. licensee indicated that fifteen of the laboratories were found clean after removal of the contained sources and contaminated equipment.
The remaining five laboratories required an additional cleaning effort to reduce the contamination found during the surveys.
An independent NRC overcheck will be scheduled as other commitments permit.
B.
Hazardous Materials Control (1) The licensee acquired two additional lockers for storage of hazardous materials.
A list of the stored hazardous materials i
is available to the purchasing department to facilitate the use j
of the hazardous materials already in stock before purchasing more.
This acquisition of the additional lockers is responsive to recommendation D.1.
(2) Additionally, the licensee had set up a satellite station for classification of. materials gathered during the laboratory consolidations.
About twenty 55 gallon drums of hazardous wastes were subsequently shipped to a disposal site as a result of this effort.
The review of other areas for hazardous materials that may need to be classified as waste and expeditiously shipped to a disposal site is continuing.
No violations were identified.
6.
Transportation Licensse's transportation activities are regulated by 49 CFR 100-177, 10 CFR 71, and 20.311.
In addition, an NRC issued Certificate of Compliance regulates the use of shipping casks used to transport fuel and components to and from Fort Saint Vrain (FSVR).
A.
Several shipments of the boxed drums of North Warning System (NWS) liquid scrap have been made by the licensee.
Some of the liquid scrap is still stored on-site pending approval to ship. This item (86-06-03) remains open.
No violations were identified.
' 7.
_Energency Preparedness License Condition 23, of SNM-696, requires the licensee to implement, maintain and execute the response measures of the Radiological Contingency Plan submitted to the Commission on May 25, 1984 and supplemented on August 22, 1984.
The licensee shall also maintain implementing procedures for the Radiological Contingency Plan.
A.
)
i
-- J
7
.(1) The licensee is continuing the effort to consolidate the I
several different emergency plans into a single plan with cross l
referencing and indexing.
The consolidated plan will include, according to the Emergency Coordinator, a section on hazardous materials emergencies and a section on terrorist emergencies.
This is responsive to recommendations H.6, H.7, and H.8.
(2) The licensee has arranged for the appropriate radiation safety l
training records to be provided to the Supervisor of Emergency Services. This is to facilitate providing training to the appropriate emergency response team members.
A list reflecting successful course completion will be provided to' emergency services.
A copy will be retained by the Health Physics Office.
This is responsive to recommendation H.1.
(3) The licensee has close contact with the San Diego County Office of Disaster Preparedness and the Radiological Manager, County Department of Health Services.
The cooperation that exists achieves the goal of recommendation H.2.
(4) The licensee expressed the opinion that the recommended drill frequency of every two years, including patient transfer, was too frequent.
A prefere.'ce of a four year interval was preferred by the licensee.
The fact that the licensee's plants were operating at lower than normal throughput were, in their view, justification for a lower drill frequency.
The licensee's plant for production of fuel for the Fort Saint Vrain Reactor has not processed fissile fuel for essentially two years.
The licensee's view, in general, is that reduced activities correlate with reduced risks.
The licensee also indicated that an objective analysis of the additional training benefits that may be gained from a two year cycle versus a four year cycle shows the increased frequency is not warranted.
The need for drills was not in question, the licensee agreed they serve a very useful purpose and the concern is only with the drill frequency that incorporates outside support agencies.
It is noted that NUREG-0762, " Standard Format and Content for Radiological Contingency Plans for Fuel Cycle and Matt. rials Facilities",in Section 7.3, recommends that outside observers and support agencies be involved every five years.
The licensee indicated that the revised plan will contain a specific drill frequency _the adequacy of which will be reviewed when the licensee has issued the revised plan.
Currently, the licensee has not taken action that meets the recommendation H.4.
(5) The licensee indicated that medical emergency trips to the Scripps Memorial Hospital are made about twice a month.
The J
hospital is notified by the licensee as soon as a decision is made to transport the patient.
However, this does not appear i
to meet the goal of recommendation H.S.
It fails to involve the level of contamination control envisioned as being practiced in a full scale drill wherein the hospital would need
)
as much advance notice as possible for the purpose of setting i
j s
s d'
g
]
s
]
'in operation its' contamination control processes.- It appears I
1that these frequent. trips to the hospital, because of,their l
principally medical' nature, precludes crediting the licensee-with meeting the intent of recommendation H.5.
Item (87-01-08) remains open.
i
.(6). The licensee indicated a' willingness to review the City'of San Diego's Radiological Response Plan in response to recommendation H.12.
However, the licensee' notes that the resolution of any differences cannot be taken as~their E,..
responsibility when the plan of an independent regulatory body is involved.
That regulatory body is responsible for its plan.
4 The: discrepancies between.the plans and the progress-made in u4 -
resolving them will be reviewed in a subsequent inspection.
' (,.
Similarly, the licensee is not in a leadership role. in establishing consonance regarding various jurisdictions and their roles and responsibilities.
It would be beneficial to know that the various. roles and responsibilities of the.several jurisdictions are not in' conflict.
The licensee's efforts'in' this' area, responding to recommendation H.14, will be reviewed
~in.a subsequent inspection.
B.
Fire Protection (1) 'The licensee continues'to make< modifications that upgrade the
,g
. fire suppression system.
A.recent change was the addition of 200 feet of water pipe and two' additional section valves.
The.-
additional valves facilitate bypassing' defective sections of pipe.
A new water supply has neither been developed for this site, nor has a secondary source, such as stored water, been developed.
The information the licensee obtains on the possibility of an additional water supply from the city will be reviewed during subsequent inspections.
The development of an alternate reliable water source, recommendation D.2, will be followed if.it develops.
(2) Significant progress has been made on the licensee's hazardous materials locater list.
The area emergency plans include the hazardous materials list and the actions to be taken during emergencies.
The Hazardous Material Work Authorizations list activities and chemicals in the.Various locations.
Emergency Services Technicians (ESTs) can call up. laboratory specific hazardous material information from a computer for use by firefighters.
Establishing this capability met recommendation D.4.
j (3) The licensee is now making full use of both the Industrial Hygienist, who has-been appointed Deputy Manager Hazardous Materials, and the consultant toxicologi t. They are supporting
'the Industrial Safety Engineer in the management of hazardeus j
materials stocks.
Further, they are assisting the Supervisor of Emergency Services in hczardous waste classification and packaging at the satellite station.
The new Emergency Services Technician (EST), recently added to the Emergency Services
__A
9 staff, is also assisting.
The presence of the EST is a
indicative of the licensee's effort to maintain an adequate emergency services staff in response to recommendation D.5.
The' licensee's completion of the incompatible chemical storage review and correction closes item (87-01-03).
l~
(4) The licensee cleaned up the gas storage pad area, serviced the l
associated piping, the associated grounding, and the associated l
valves.
This was responsive to recommendations D.6, D.8, 0.9, and D.10.
I (5) TheLlicensee reviewed the propylene inventory for possible reduction in response to recommendation D.11.
However, the l
conclusion was to keep the current inventory because of its I
value and probability of use.
The licensee plans periodic l'
inspections to assure the continued safe storage of the propylene.
No violations were identified.
8.
Environmental Programs
.Section 6 of Part II - Lice:'se Specifications requires that an environmental surveillance program shall be maintained to evaluate the-effectiveness of the radiological safety program and to provide information to assist in timely corrective action in the event of accidental releases.
A.
The inspector noted that the licensee's summary records of effluent releases could be improved by providing the concentration of releases as well as the totals released as report backup.
The licensee indicated consideration would be given to having the described information compiled as backup.
B.
In response to NRC Temporary Instruction 2800/9 " Reconcentration of Radionuclides In Sanitary Sewerage Systems," sludge samples had been taken from the Fiesta Island piles of drying sludge during the previous inspection (70-734/86-06).
During the same inspection soil samples were collected at the abandoned Callon Ponds Sewage Treatment Plant incorporated within the licensee's site. The Fiesta Island sludge analytical results, which were all <12 pico curies uranium per gram (pCi U/g) were below the Option I limits (30 pCi U/g) of the Branch Technical Position (SECY 81-576).
The two samples from the abandoned Callon Ponds Plant were higher than the Option 1 limits.
The digester sample result was 56 pCi U/g.
The dry pond value was 100 pCi U/g.
The associated thorium values were less than the Option 1 limits of 10 pCi Th/g.
No violations were identified.
9.
Deactivation / Decontamination Activities i
i 10
)
l b
License' Condition 24 requires that at the end of plant life, the licensee i
shall decontaminate the site and facilities authorized as a place of use for special nuclear materials.
A.
The licensee's shipments of low specific activity (LSA) soil shipments to the DOE Nevada Test Site burial ground were completed during the summer.
The independent overcheck of the waste yard and the surrounding 78 acres has been completed by Oak Ridge Associated Universities (0 EAU) for the NRC.
The ORAU report, for Phases I and II is scheduled to be provided, in draft, in January,1988.
The Phase III operation will encompass about 185 of the remaining 215 acres planned for release.
The remaining 30 acres will constitute a Phase IV because of required additional planning.
The planning-includes redesign and relocation of the sewage pump house as well as rimpletion of the cleanup and dismantling of the abandoned City of San Diego Callon Ponds Sewage Treatment Plant.
No violations were identified.
l 10.
Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1.
The topics included:
The areas inspected.
Sampling of the sludge output from two sewage treatment plants.
Status of open ; ass.
Closed items 3 Open items (old) 10 Open items (new) 0 Assessment team recommendations review.
Adequate response 28 Some progress 7 Unresolved 1 (H.14., Section 7.A.(6) of this report)
Other topics.
i The licensee expressed the opinion that the recommended drill
)
frequency of every two years, including patient transfer, was J
too frequent.
A preference of a four year interval was preferred by the licensee.
This matter is to be resolved by NRC.
_ _ __ _____ a