ML20244C041

Insp Rept 70-0025/89-03 on 890515-19.No Violations Noted. Major Areas Inspected:Followup of Licensee Action on Open Items,Operator Training & Retraining,Operations Review, Radwaste Mgt,Environ Protection & Emergency Preparedness

ML20244C041
Person / Time
Site:	07000025
Issue date:	06/06/1989
From:	Brock B, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20244C028	List: ML20244C025 ML20244C041
References
70-0025-89-03, 70-25-89-3, NUDOCS 8906140103
Download: ML20244C041 (10)

Text

- --

,, ,, ,v 4

> 4 ,i .

. v , 3 C y ,

, :yy y' - '

s  :

y , .3(, ,  ? ..

L , p. l r

, 3 3

Ls n.,p 3 *; M r ,y ;1

• 1g.

,' .IjQ:f . N. ./= ,

l-u

.. . U." S. NOCLEAR REGULATORY"COMM SSION '

'< , s.

p

.- 4 4

• ' . REGION V s , j

^

. Report-No.- 25/89-03

License No. SNM-21

.a : ,

~

Priority.0 Category II Safeguards ~ Group.II' Licensee: .Rockwell International Corporation Rocketdyne Division-Atomics: International 6633'Canoga Avenue Canoga Park, California 91304 g Facility 1Name: Rockwel1~' International Hot Laboratory Inspection at! Santa Susana Field Laboratory m . Inspection. Conducted: May-15-19, 1989 Inspector: Med 4t_ 6[$k9

.'B. L. Brock, Fu61 facilities Inspector Date Signed Approved by:

R. Fish, Chief Emergency Preparedness

, d Ddte'51gned b

Section Summary:

' AREAS INSPECTED: A routine unannounced inspection was conducted of follow-up of licensee action on open items, operator training and retraining, operations review,-radioactive waste management, environmental protection, emergency preparedness, and radiation protection.

During this inspection, Inspection Procedures 92701, 88010, 88020, 88035, 88045, 88050, and 83822 were covered.

RESULTS: .The licensee's performance in the program areas inspected had improved and appeared adequate to accomplish their safety objectives.

(, There were no violations. identified in:the seven areas 1.7spected.

l';

~ 8906140103 890606 g PDR ADOCK 07000025 3 C PNU [ .

- e "4 y 78' h:

[ ~i i s. , y

v. i 1 t

L ' DETAILS

1. Persons Contacted h A. Licensee Employees:

• R. A. Johnson, Acting Director, Atomics International Division

• L.-J. Auge, Chief Engineer.

• C.:J.'Rozas, Director, Health Safety and Environment

• J. P. Page, Manager,' Development and Test R.-T. Lancet, Director,-Nuclear Safety

• R. J. Tuttle, Manager, Radiation and. Nuclear Safety

• V. J. Schaubert, Manager, Nuclear Safety and Licensing

• W. R. McCurnin,' Manager, Nuclear Operations

• J. K. Clark, Manager, Protective Services.

• R. D. Barto, Director, ' Industrial Security M. G. Chavez, Manager Plant Services-SSFL

• W. I. Greenwell, Manager,SSFL Protective Services I. N. Stein, Medical Director J. A. Curry, Physicians Assistant L. Rodman, Emergency Coordinator

• J. Gump,. Fire Protection Engineer J. Moore, Human Resources Advisor R. P. Warren, Manager, Technical and Skills Development B. A. Davies, Training Instructor F. E. Bagley, Health, Safety, and Environmental Engineer-J. Roy, Member Technical Staff J. R. Lopez, Senior Training Specialist, Protective Services F. H. Badger Health And Safety Engineer J. W. Rowles, Human Resources Advisor D. Harrison, Staff Chemical Engineer a W. Himmons, Manager, Plant Services-Electrical C. A. Giesler, AWC Contract Radiation' Monitor .

S. Brown, Department Associate J. Curry, . Instruments Service Technician

• Denotesthoseattendingtheexitmeetingi/27/89.

2. Follow-upofLicenseeActiononOpenIAems(92701)tM ' '

r A. The following items are considered closed.

89-01-01 This item noted an inconsistency'betwee'n the license and the Radiological Contingency Plan (RCP) regarding the training frequency for emergency response personnel. The license indicated a 2 year training frequency while the RCP indicated a 1 year training frequency. During the current inspection the inspector noted that the licensee's training printout includes a letter "E"~ as a flag beside the name of members of the emergency. teams. This indicator identifies emergency response persons scheduled to receive annual training. The licensee issues a list of

g-_____ _ _ __

2 1

l persons due for retraining 60 days prior to expiration of their qualification. Thirty days after the training is given a list of persons delinquent because of missing or fr failing the training is prepared and a letter is sent to the supervisor removing them from the activity requiring the qualification. This item is considered closed.

89-01-02 The licensee's failure to conduct an annual exercise was cited in the previous inspection. No response to the citation was required because the licensee had conducted L the exercise prior to the inspection. The licensee stated

.during the previous. inspection and reiterated during the current inspection that exercises henceforth would be conducted as required. The licensee further agreed that weather would not again delay the conduct of an exercise.

This item is therefor closed.

89-01-04 The licensee had successfully demonstrated the calibration of the stationary air samplers during the

, previous inspection, However, a result of the

' demonstration was the identification of the need for a procedure to cover this infrequently executed operation.

The licensee prepared a procedure for accomplishing the calibration. This item is therefor closed.

3. Functional or Program Areas Inspected A. Operator Training and Retraining (88010)

-The licensee stated that the procedure he follows, described in Section 2A of this report, has been successful in achieving compliance with training requirements. In the area of respiratory protection training, the licensee has a four part form, Medical Surveillance Program Application, which is used to evaluate the need for respiratory protection by identifying the materials involved in the precess that require the use of respiratory protection. With regard to the medical examination, the training roster now displays the medical date to preclude the respiratory protection training from being given beyond a year after the medical examination.

Additionally, there is a Rocketdyne Medical Surveillance Master File which lists the prior and the next medical examination date. The medical director is notified when an employee has failed to take the required medical examination and follow-up involves coordination with the Department of Labor. The licensee indicated that a few situations involved such follow-up but there has been no recent need for this action.

Further improvements in training record processing are expected when the efforts to incorporate the current training records into another system, the Training Record System (TRS), are completed. The TRS system is said to be more versatile than the current system. A quality check of about two months duration, in which the old system will be run concurrently with the new system to verify the information provided by the new system, will be undertaken before

e +- ,

1; '

. 4- a 3' - -

p.q , # .-

Mt '

, e

, use.of the,old system'is discontinued. The licensee ex'pects:the u training-record incorporation in the TRS system will'be' completed  ;

,. within six months. , -

a .

~i3 a

s '3 ]

{4. ;;

Performance in this program area appeared to' meet current < license f Q@)

g

. requirements. No violations were identified.

a.,

r

.P

,J' y

_ B. Operations Review (88020) ,

3, =

1 , . ,

,c (1) Conduct of' Operations s

?

During the facility tour the inspector ,noted that the cleanup.

~

of the cell face ports had not progressed as much as anticipated. It appears that the In-Service Inspection.(ISI)L work undertaken by the: licensee requires use of,personnelJwho otherwise would be involved with completing the, Decontamination-

-and Decommissioning (D/D) work.- The tent which houses the Cell 1 face penetration cleanup work has not yet been moved to' Cell

2. .The current activities in Cell 1 included removing'the paint from the cell walls. Power tools were not sufficiently.

effective, therefore, the licensee resorted to a manual method.

Additionally, the licensee is ende woring to decontaminate the bottom of the cell door. ,The door weighs about,32,000 pounds, is larger than the doorway it closes, and was put in place' before the decontamination room, which it separates from the-cell, was completed. The door, therefore, can not be simply relocated or turned. It, therefore, requires significant preplanning and careful handling to safely complete its-cleanup. Safety practices appeared appropriate. Contamination control was less significant at this stage of the cleanup operation-because of the previous cleanup using rotating sanders and grinders. The licensee expects to move the cleanup operation to Cells 2, 3, and 4 in turn. It should be noted that the licensee has not concluded that the structure will necessarily be torn down. As of the' previous inspection it appeared clear that tear down was a viable option. During this inspection it became clear that 'other options (e.g. using the cleaned up building for other work) had also become potentially viable alternatives.

During the inspector's tour of building T-020, the licensee's Health and Safety Engineer pointed out that the remote manipulators had been decontaminated and were stored. They were in a state of readiness in the event they were needed for new hot cell work.

The licensee has encountered and successfully surmounted some problems in the insitu cleanup of a contaminated pipe. The current effort is making use of a contaminated pipe;that was removed from beneath one of the rooms which supports hot cell operation. The initial cleanup effort identified the need to 4 revise the procedure to remove an unexpected interference with

• = the process being used. The resumed cleanup then succeeded in ,

achieving a decontamination factor of about ten'for the process ~

V 6

y c

1 1 :J 4

i . .1 m

[

P , . -

1' L being evaluated. The. decontamination factor is preliminary L . because the measurements were made with a modified. pancake .  :;

l, -

probe!and not the special probe which will be used later when.

L methods to reduce the possibility of conta inating the new. )

y >

probe.have been improved. ,If the licensee is successful in .

L, using this insitu method,.the'NRC will need to develop a. method to confirm the licensee'stsurvey results of pipes imbedded in concrete if removal of the pipes is to be avoided. Oakridge.

m Associated Universities (0RAU) was informed'of the possible

. need for.them to. verify the licensee's insitu measurements.

t

. ORAU indicated they would be prepared to make such measurements

'if the need arose. ,

The licensee was actively engaged in scabbling the vertical side of the exterior base of the building's concrete slab that-

- showed evidence of contamination. The floors in the rooms

. - along the side being scabbled (rooms 153 and 155) had also been scabbled'to remove contamination that appeared.to follow cracks.

down into the concrete. This necessarily required chipping the concrete until no further. contamination above NRC release

~

limits.was identified. The licensee invisioned pouring new concrete on the floor to permit use of the rooms. The inspector suggested the. licensee clear such action with NRC because of.the complications such a move would make.on subsequent; verification of the adequacy of the licensee's-decontamination effort. The inspector apprised the NRC's project manager for this license of the licensee's need to discuss this item with him.

The licensee's next project involves evaluating the electro.

chemical separation efficiency of U, Np, Pu, and Am. A portion of the work is scheduled'to occur in building T-023. The inspector. toured building T-023'and interviewed one of the researchers. It appeared that. attention is being paid to the safety; aspects of the planned. operation. The researcher was knowledgeable about the safety significance of various parts of the proce'ss. The inspector cautioned thh researcher that procedures that. incorporate adequate safety precautions are effective only if-they are followed. .The inspector also apprised the. researcher of the licensee's previous experience wherein a' citation was issued because of an extremity over-exposure that resulted from a trained employee's failure to follow the procedure.in which he had been trained. The researcher indicated' appropriate attention would continue to be given to safety aspects;of operations.

The researcher indicated that the inert atmosphere would be i l

verified through use of an oxygen analyzer calibrated with a 25 parts per million (PPM) oxygen standard. Overtemperature protection is provided and additionally, a High Oxygen Protection System (HOPS) is scheduled to be added to the system. The project is currently about three months behind schedule.

e j 5

/

' ' ~

The Health an'd Safety Engineer indicated the part of the:

research project would make use oflthe smaller glovebox in, room 139 of building T-020. This' change will make. preparation of the glovebox easier because the smaller glovebox was found-to '

be.significantly cleaner.

The inspenor was informe'd that the C0-60 sources removed, from the' RocWell International Science Center's irradiator were stored in thk transfer. drawer between hot cells 3 and 4. The~

irradiator will be shipped to the University of Washington which wants the irradiator without the sources. The licensee:

.now has the problem of finding an organization in need of-such-sources. ,

All operations observed were considered to be accomplished.in:

accordar,ce with regulations, the: license,' the Safety Evaluation Report (SER) and applicable regulatory guides.

-(2) Housekeeping 1he licensee has continued'to make improvements in the, l# '

conditions'in the basement'of the Rockwell International _, Hot Laboratory (RIHL). The inspector noted that the-containerfin.

which anti-C. (protective) clothing wasideposited was apparently

~

receiving appropriate attention since>1t was not filled to' capac ty as it had been during the prev,ious1inspe,ction. 7 It was also noted duringfthe inspection that the ele'tr'onic's c repair shop reflected an improvementLin house, keeping. >'i j Performance in this program area appears satisfactory. No violations were identified. r+ 's '

5 C. Radioactive Waste Management (88035) 4

-(1) Calibration (a) The inspector checked the calibration stattis' of thirty-one survey instruments and found they~were'all1within their calibration period.

(b) The licensee is changing from the Calibration Recall l Inventory System (CRIS) to a new computer direct access j system, Property Management System (PMS), effective May 17, 1989. The CRIS provided a recalibration notice to equipment users two weeks before the recalibration was due. Since the CRIS was updated weekly, the calibration status report generated using it was not always current.

The PMS, however, will be updated at least daily and will provide a near real time equipment calibration status report as well as a'recalibration notice.

c-_____-__-_-_____

l 6

9 l . .'

(c) The calibration of the effluent monitors used sources traceable to the National Bureau of Standards (NBS). The l applicable certifications for the standards were on file.

l

~

(2) Radioactive Solid Waste The licensee ships vastes under Department of Energy (DOE) orders because the material that had been processed in building

.* T-020 was license exempt. The licensee's packaging of wastes has,been in accordance with Department of Transportation (DOT) requirements. Appropriate procedures were used for waste packaging before transfer of the packages to the contract operations for' shipment. Current decontamination efforts have not yet generated _ enough containers to comprise a cost l

3 effective shipment.

Performance in this program area appears satisfactory. No violations were identified. ,

D. i Env'ronmental'hrotection(88045)

(1) Management Controls The responsibility for the environmental protection program has not changed since the previous inspection.

(2) Quality Control of Analytical Measurements (a) The licensee's stack exhaust samples from three facilities (Radioactive Materials Disposal Facility, Rockwell International Hot Laboratory, and the De Soto avenue facility) were sent as a group (not as a composite) to the contract laboratory for analysis. The gamma spectral analyses were used for determining offsite doce estimates.

The results were incorporated in the May 12, 1989 annual review of radiological controls.

(b) Appropriate standards appear to be properly used to control measurement of environmental samples.

(3) Reports (a) The licensee conducted the required review of the environmental program as part of the review covering the radiological controls. The report indicated personnel exposures for 1988 in general were lower and airborne radioactivity releases from NRC licensed operations remained in the 4 micro curies range released in the previous year. The ambient onsite and offsite radiation exposure decreased in 1988. Additionally, the level of radioactivity in the water appeared to be essentially identical in the two onsite ponds, the upper part of Bell Creek and the water supplied to the site.

y I , j, g

b ,

, s 7

~_ '

m ,

7 j ^ ,

H  :(b) :The-licensee's' annual environmental monitoring and-

, cfacility effluent ^ report was'apparently completed during:

the. current. inspection. The distribution'of the report has been. delayed at the request'of,the DOE. It'was noted that the~'a local newspaper gav'e considerable attention to

the licensee's. facility. .'Although,most of the articles addressed 00E operations,'some. attention was'given to the

' violations the NRC had issued!

' Performance in this program area appears adequate.. H'owever, as the

. result of sampling questions raised by DOE, additional attention should be given'to the licensed activity sampling locations ind the basis for their selection.' No violations were identified.

E. Radiation' Protection ('83822)

(1) Radiation Protection Procedures During-the tour of the facility the inspector, observed that'the operators' practices. appeared to follow the procedures. The

' overfilled contaminated laundry hamper identified in the previous ' inspection report was apparently ' receiving closer

-attention..

"' The licensee's response to the suggestion that frisking and undressing procedures be' reexamined included preparing a script to be used for a training VCR tape. Five training tapes had i

recently-been completed and the allocateo funds were depleted, therefor the production of this sixth tape will require the allocation of additional funds. A portion of one of the training tapes prepared on site was. viewed by the inspector and was found to be informative and interesting.

(2) Posting, Labeling and Control The inadequately installed high radiation area sign that came loose.during the previous inspection was checked and found to be adequately secured to eye t'olts that had been imbedded in the concrete wall Performance in this program area appears to be adequate. No violations were identified. l F. Emergency Preparedness (88050)

It was previously identified that the licensee should include an evaluation of. event classification in the exercises. The licensee agreed to address this area in future exercises.

Following the previous inspection, the inspector contacted the NRC Office.of. Nuclear Materials Safety and Safeguards (NMSS) and verified that the licensee's revision to the Radiological Contingency' Plan, submitted July 25, 1988, would be reviewed to

y

{

s 8

determine the effect of the changes on the RCP. The Region will be l advised of the results of the review.

The licensee's revision to the RCP to eliminate an inconsistency identified during the previous inspection was not considered to be fully adequate. The inadequacy stems from the licensee's selection of a non-conservative change from the two available. This was discussed with the NRC license reviewer for the facility. The reviewer indicated the matter will be discussed further with the inspector who identified the problem before reaching a solution.

This item, open item 89-01-03, therefore remains-open.

The issue of the maintenance of the offsite agreement letters identified during the previous inspection is still in the process of.

^

being completely resolved. The licensee was in the midst of formulating a response that will include a change of the custodian'

~

of the letters and possibly the frequency of the renewal of'the, ,

letters. 3 During the inspection, the inspector again checked the conten'ts of i ,

the emergency equipment box at the perimeter fence of building T-020 a and found that the outdated. emergency. plan, identified.during the-previous inspection, had been removed. The, licensee's r'esponse~ '

h,' , appears'to be adequate and closes this matter.

~ '

The licensee's medical director indicated that additional attention ,

is being given to earthquake safety. Towards this end the licensee .

I has compiled a list of all ham operators on the staff. Additionally there is a closer relationship with the Northridge Hospital which has appropriate radio communications equipment which is'a' viable option to lost telephone service resulting from downed power.-lines.

The inspector was also informed that the increase inithe; company staff appears to warrant an additional nurse. The nurse on staff at the Santa Susanna site has not taken the REACT /S course given by Oak Ridge Associated Universities (ORAU). The training given in the course is essential for medical emergencies.

Fifteen fire extinguishers checked by the inspector had received the required monthly inspections. As the result of observation and a records check, one fire extinguisher was identified as not having received its required monthly inspection. This fire extinguisher was located in building T-020 just outside of the diesel generator room. It appears that additional emphasis is needed to assure that all of the fire extinguishers are checked as required. Additional follow-up of fire extinguisher inspections and the related records, will be made as a result of this open item (89-03-01) during the next inspection.

Performance in this program area warrants further review. No violations wcre identified.

, q 1

4 j g, x < , .j

. 1

. H. Exit Meeting (30703) i ..

The results of.the inspection were discussed with the licensee's '

staff identified in Section,1. The topics included a review of the-x findings in each area' inspected and the status of the open items reviewed.

o The licensee was informed that no violations resulted from this inspection. ,

o The status of open items was reviewed.

Closed 3 Remaining open 1 (89-01-03)

New 1 o The licensee was reminded that contact should be made with NRC/

NMSS before filling the holes in the concrete floor.

o The language used excusing instructors from taking the training-they teach appeared to need clarification.

o . The inspector noted the_need for funding to complete preparation of the training tapes.

o The inspector encouraged the licensee to be on the alert for hot particles since their ISI work could result in exposure to them.

o The inspector reminded the licensee of the need to assure that the trained operators follow the approved procedures to preclude recurrence of their previous experience with an overexposure.

o The inspector informed the licensee of the ORAU position that they would be prepared to overcheck the licensee's cleanup of piping insitu.

o The possible participation of the NRC in the environmental-sampling scheduled to occur beginning July 10, 1989.

'o Noted the completion of the required annual audit of the radiological control program.

o The completed Environmental Report would be expected to arrive through normal channels soon.

o The, arrangements for earthquake response were noted.

o Replacement of the CRIS system as well as'the planned use of the TRS was noted.

1 i

)

_ - _ _ _ _ _ _ _ _