ML20195G960

Insp Rept 70-0025/88-02 on 880516-19 & 0601-07.Violations Noted.Major Areas Inspected:Mgt Organization & Controls, Training & Retraining,Criticality Safety,Operations Review, Transportation,Radiation Protection & Environ Programs

ML20195G960
Person / Time
Site:	07000025
Issue date:	06/23/1988
From:	Brock B, Jonathan Montgomery, Prendergast K, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195G950	List: ML20195G947 ML20195G954 ML20195G960
References
70-0025-88-02, 70-25-88-2, NUDOCS 8806280182
Download: ML20195G960 (13)

Text

___. .

U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-25/88-02 Docket No. 70-25 License No. SNM-21 Priority 0 Category II Safeguards Group II Licensee: Rockwell International Corporation Rocketdyne Division Atomics International 6633 Canoga Avenue Canoga Park, California 91304 Facility Name: Rockwell International Hot Laboratory Inspection at: Headquarters Site and Santa Susana Field Laboratory Inspection Conducted: May 16-19, June 1, and June 7, 1988 Inspector:

gB. L. Brock, Fuel Facilities Inspector b 8' D6te Signed Inspector: ffU M Jh.M.Prendergast,EmergencyPreparedness Ofte S'igned

(/ Analyst Inspector: , d 8 R. D. Thomas, Chief 06te <igned Nuclear Materials Safety Section Approved by: * -

Af W b/*AS E J. L. Montgomd h , Chief # Date ' Signed Nuclear Materials Safety and Safeguards Branch Summary:

Inspection on May 16-19, June 1, and June 7,1988 (Report No. 70-25/88-02)

Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls; training and retraining; criticality safety; operations review; transportation; radiation protection; emergency preparedness, and environmental programs.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 83822, 86840, 88050 and 88045 were covered.

8806280182 PDR 980623 C ADOCK 07000025 DCD

-g.

Results: Three violations were identified in two (radiation protection and emergency preparedness) of the eight areas inspected. Details on the violations are provided in the appropriate sections of the report.

I 1

l l

l l

i

1

}

l DETAILS

1. Perseas' Contacted A. Licensee Employees:

• D. C. Gibbs, Director, Atomics International

• M. E. Remley, Director, Nuclear Safety

• R. D. Barto,. Director, Security

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

• W. Greenwell, Captain,-ProtectiveLServices C. M. Bower, Captain, Protective Services - Training F. H. Badger, Health and Safety Engineer J. W. Rowles, Health and Safety Specialist J. D. Moore, Health and Safety Engineer

• L. E. Rodman, Senior Fire Protection Engineer (Emergency Coordinator)

J. A. Gump, Fire Protection Engineer D. Harrison, Staff Chemical Engineer F. C. Shrag, Member Technical Staff D. C. Parker, Shift Leader C. Forbes, Site Nurse F. E. Begley, Health and Safety Specialist, Respiratory Protection J. A. Chapman, Health and Environmental Safety Specialist E. Martini, Senior Instructor C. A. Giesler, AWC Contract Radiation Monitor

• Denotes those attending the exit meeting ,

2. Functional or Program Areas Inspected A. Management Organization and Controls' (88005)

(1) Organizational Structure A new director has beer, appointed to the Atomics International Division. The management structure continues to provide-the appropriate checks and balances regarding nuclear safety. The licensee has also selected an independent second party Criticality Safety Reviewer.  :

(2) Safety Committee Neither the licensee's Management Safety Committee nor the Nuclear Safety Review Panel identified the record and training violations discussed in Sections D.(4)(c) D.(5)(a) and F.(2).

The committees should be concerned not only with managements conduct of required internal audits but they should assure themselves of the adequacy of the scope and depth of the audits. Their support of the licensee safety policy should be very clear.

. _ _ ._ . ~ _ _ . __ _

_ _ _ _ _ ___ ~ _ - - _ _ _ . , _. ._.__l

2-The need for a review of the actions of these oversight committees is identified as an open item (88-02-01) and will be reviewed in a subsequent inspection.

(3) Procedure Contrc[g The licensee centinues to use reviewed and approved procedures in the conduct of operations. Due to_ changes in operations, the licensee thould examine their procedures to assure they-are representativa of current _ operations and they are being.

followed. Examples of problems identified in the implementation of plans and procedures are described in Sections D. and G. of this report.

No violations were identified in this program area; however, the open item identified indicates furthe,a review is needed.

B. Criticality Safety (88015)

(1)' Nuclear Criticality Safety Analysis The licensee has not conducted any nuclear criticality safety analyses since the last inspection. As stated earlier a new criticality safety independent reviewer has been appointed.

The new independent reviewer's experience and qualifications appear extensive. However,.the individual does not appear to have any fuel fabrication experience. The applicability of the reviewer's experience to fuel decladding operation criticality safety analysis will be reviewed during the next inspection (88-02-02). l (2) Audits The routine criticality safety audits were formally suspended, by letter dated July 21, 1987, after completion of the Fermi

' rod separation' project. The above referenced letter also committed to conducting a preoperational criticality safety inspection prior to resumption of operations.

No violations were identified in this program area.

C. Operations Review (880201 (1) Building T020 Rockwell International Hot Laboratory (RIHL)

The licensee has analyzed their activities regarding the decommissioning of the facility and those activities that would be necessary for operations under a new contract with the i

Department of Energy (00E). Present activities appear to be directed towards maintenance, housekeeping, and those activities which are held in common with both the decommissioning of the facility and the potential contract with 00E.

, [' . 3' b

No violations were identified in this program area. <

D. Radiation Protection (83822)

(1) Radiation Protection Procedures The licensee has'sstablished a Radiation Safety Plan for Building T020. Minor revisions to the plan were made in September, 1987. Although the plan is revised annually, there were numerous instances where specific requirements contained i in the plan had not been performed. -Examples of these problems -

are described in sections D.(4) and D.(5). l (2) Audits '

The licensee conducts quarterly audits of the radiation safety- i program associated with Building T020. The audits evaluate the .

operational data relative to effluent releases, radiation ,

exposures, air sampling results, contamination surveys, area film badges, and incidents. j The inspector reviewed the audit reports for the 4th quarter of 1986, and the four quarters of 1987. All deficiencies noted had been corrected as shown in subsequent reports. The licensee's actions were acceptable.

• The inspector noted that physical radiation surveys were not  !

addressed in the quarterly audit plan of the Radiation Safety Program. The failure to address this area may have contributed i to the survey records violation discussed in Section D.(5)(a). 1 This was discussed with licensee management during the exit '

interview.

i The licensee's Radiation Safety Officer (R50) conducts an annual audit of the Radiation Safety Program with special emphasis on radiation exposures. The results of this audit are presented to the Radiation Safety Committee. The in,pector examined the results of the annual audits for the years 1986 and 1987. The licensee is meeting their projected exposure j goals identified in the ALARA program. '

(3) Exposure Controls (a) External Exposures The licensee utilizes NVLAP approved film badges, TLDs, finger ring badges and pocket dosimeters in their personnel dosimetry program. The film badges are processed on a quarterly exchange cycle. The TLDs and finger ring badges are processed by the licensee. These devices are used as a backup to the film badge service.

4 The inspector examined the film badge exposure records for the period of the 4th quarter of 1987 through the 1st quarter of 1988. The maximum exposure recorded was 1010 mrems.

The inspector noted the licensee had performed an evalustion of a film badge which had an exposure of 820 mrems for the 1st quarter of 1988. Tha licensee's evaluation determined the exposure to the film badge had been caused by a thermal effect' and did not constitute a vr. lid radiation exposure. A dose of-280 mrems was assigned to the film badge based upon the individual's pocket dosimeter data. The-280 mrems will be added to the individual's permanent exposure-record, and the 820 mrems will be deleted. The radiation exposure evaluation performed by the licensee was qLite acceptable.

The inspector examined the finger ring badge exposure records for the 3rd and 4th quarters of 1987, and the 1st quarter of 1988. The maximum exposure recorded was 1160 mrems.

All radiation exposures recorded were acceptable.

(b) Irternal Expos' ares The licensee conducts a bioassay program which utilizes urinalyses as a screening mechanism. Should the urinalysis be positive, the licensee has provisions for whole body and lung counting at nearby hospitals and universitier..

Bioassay data for the period of January 10, 1988 to April 21, 1988 were examined by the inspectors. All results were acceptable. l (c) Respiratory Protection i

The licensee has an active respiratory protection program which uses only equipment that is NIOSH/MSHA certified.

l The inspector attended a respiratory protection training class {

while on site. The course materials were presented in a '

professional manner. Audiovisual and verbal instructions covered the basic training and regulatory requirements. A written test followe.d tbo instruction, The results of the test were critiqued by the instructor. All individuals in the class -l were given "hands ore" training in the fitting and testing of I the respirators which they would be assigned. The overall training session was comprehensive.  !

(4) Posting, Labeling and Control (a) Posting of Notices The licensee is fulfilling the posting requirements specified in 10 CFR 19.11.

, . 5 (b) Posting of Areas The inspcctors had a discussior,with the radiological safety

. representatives.in Bu',lding T020,regarding the posting of: ,

radiation areas, hig's radiation . areas, and -irborne radiation v

-areas. It was obse',ved by the inspectors that several-areas within Building T020 were overposted since radiation areas or  ;

airborne radiatioi areas did not exist at,the time of the inspection. The point of the discussion'was to emphasize the~ ,

importance of a radiation sign so that it would have the significance intended by Part 20 of the regulations. This matter was discursed again during.the exit interview. This is a matter which the licensee should ra.-evaluate in order to maintain good health physics practices and meet the intent of ,

the regulation. l i

(c) Restricted Access Area Entry Permits (RAAEP) .

The licensee maintains administrative control cVer the areas of Building T020 which require _ personnel protection from radiation-nazards. This control system is administered by the use of a  ;

restricted access area entry permit (RAAEP).

This permit provides the worker with an understanding of what '

precautions are necessary for his personal protection. The radiation safety staff plays an important role in this matter since they prescribe the necessary protective equipment and authorize the entry into the work areas. -

Upon examination of the RAAEPs for the period of January 6, i 1988 through April 7,1988, by the inspectors, it was '

determined that permit numbers 30362, dated 4/8/88, and 30383, -

dated 1/19/88 had not been signed by a radiation safety representative and the completion time had not bee 7 entered on "

the permit. The inspectors verified that an entry had been  !

made based upon a dosimetry record for the workers listed on '

the permit.

The failure of to follow procedures, as outlined in Section i 3.1.1 of Pert I of the license application was identified as a i violation.  !

(5) Radiological Surveys 4

(a) Radiation Survays and Cont >ain, tion C..cks  ;

}

Section VII.C and G. of the Radiation Safety Plan for Building  :

T020 specifies the location and frequency of requir:d external )

radiation and contamination serveys. ,

I An examination of the survey records, by the inspectors, indicated tee required contamila; ion surveys were being conducted and recorded in accordance with the plan. However, 1 the records of the required external radiation surveys were not  !

i

. ~- , .. - - - , , , .we ,

4 6

being maintained. It should be noted that these surveys are conducted to'demonsteate compliance with 10 CFR 20,201(b).

Also, 10 CFR 20.401(b) requires that records be maintained for surveys conducted pursuant to 10 CFR 20.201(M. The failure to maintain records of the radiation surveys is considered a violation of 10 CFR Part 20 requirements.

(b) Leak Tests ,

The licensee's sealed sources are currently in storage and presently c'o not require leak testing for contamination.

(6) Notifications and Reports The licensee maintains a policy that all individuals who are terminated'from employment will be notified of their radiation exposure history within 90 days after termination. It should be noted that 10 CFR 19.13 requires notification of the terminated employee within 30 days after termination, if the information is requested. ,

(7) ALARA Program The licensee's management commitment to the ALARA concept is contained in Health Safety and Environmental Proceoure G-01, dated March 15, 1985. This document establishes goals relative to personnel exposures anct methods for controlling radiation exposures, in 1984, the licensee established a goal of 2.0 rem per year as the -

maximum permissible exposure level. In 1985, the maximum recorded exposure dropped to 1.8 rem. In 1986, the ALARA program contained in G-01 was implemented and the maximum recorded exposure was reduced to 1.2 rom for the year. The licensee has administrativelv reduced the ALARA goal for 1387 to 1.0 rem.

It was noted by the inspector that the licensee is practicing and fulfilling their commitment to the ALARA program.

The inspector did not review the implementing procedures for the ALARA program during this lnspection. This item (88-02-03) will be reviewed during the next inspection.

(8) Instruments and Equipment l

(a) Radiation Irstruments and Mcnitors j 1

(i) During a walk-through of the areas of Building T020, I several portable survey instruments and effluent monitors l were examined for current calibrations. All instruments and effluent monitors observed were in current. l calibration.

( i) The instrument calibration facility was visited. The purpose of this visit was to review the calibration

, procedures and determine how the instruments are rotated i

e . .

7_

a through the facility, when they are due for calibration.

The niethod of calibration-and associated records were acceptable.

(b) Alarm Settings 1 (i) The alarm settings on the sta:k monitor, and the gaseous effluent monitor in the bastn.ent of Building T020, were checked and found to be operational.

(ii) The Central Alarm Station was visited. - The inspectors observed the successful test of the RIHL Criticality Alarm System which was being conducted during the visit. The

~

inspectors learned the alarms had been interconnected '

since the last inspection to activate all alarms in'the RIHL when any of the individual detectors exceeds its setpoint. This change assures that all persons in the RIHL will be alerted simultaneously to all criticality alarms. It was'noted during the visit that one of the switches on the operations panel was covered by a piece of tape. The on duty security officer did not know the reason the tape was on the switch. It was subsequently learned the tape served to remind the security officer on duty that the normal amplifier had been removed for service and the switch was to be left in the current position which activated the alternate amplifier. The reason for the control of the switch position was not adequately passed between the different shifts. The licensee should assure that appropriate information is included as part of the information provided to each incoming shift.

Two violations were identified in Sections D.(4)(c) and 0.(5)(a).

These violations appear to indicata declining performance in this program area.

E. Transportation (86840)

(1) Disposal of Damaged Fermi Fuel Elements (a) The shipment of the damaged fuel elements depends upon the availability of the trailer on which the cask is transported. An empty trailer was damaged recently in an accident onsite and has been withheld from use pending correction of the cause of the accident. The licensee anticipates the use cf the repaired trailer for tne shipment of the undamaged fuel rods as we'l as the damaged fuel elements.

(?) Transportation The Manager, Nuclear Safety and Licensing ir,' .ted there has been no shipments of radioactive material unus NRC jurisdiction since the last inspection.

j ~

. 8 l

l No violations were identified in this program area.

F. Emergency Preparedness (8R050)

(1) Emergency Plans License Condition No. 24 requires the licen ee to maintain and execute the response measures of the Radiological Contingency _ '

Plan (RCP).

The inspection included an examination of the RCP, a tour of facilities, and discussions with licensee personnel. -Based upon information obtained during the inspection,.the licensee has not maintained the PCP. The current RCP dated March 3, 1982 was noted to be significantly out of date with the numerous cht,nges in equipment, facilities, and emergency organizations, which have occurred since 1982. The licensee has co ritted to providing the NRC, Region V Office, with a letter specifying their plans regarding the RCP and the time required to accomplish the task. The licensee's commitment to resolve this problem was discussed during the exit interview and is considered to be an appropriate method to resolve the problem of the outdated RCP due to the current special circumstances.

The Emergency call list was alsa examined and noted to have an incorrect number for one of the individuals on the Emergency Team for Building T020. Although a computerized list is maintained by Security on a monthly basis, Security stated, they would use the typed list provio,J to them quarterly from Building T020, which, as stated earlier, was noted to require changes. It is recommended the licensee examine this area to assure the response to an emergency is not delayed due to use ,

of incorrect phone numbers.

(2) Trai r.i ng Section 7.2 of the RCP, requires initial training on accident c hs*.ification, notification, procedures, responsibilities, communication equipment and annual retraining on radiation safety, criticality safety, fire extinguishment. The RCP further requin.s the training program to be audited by the Quaitty Assurance Department (QA) on an annual basis. The inspection of the licensee's training program disclosed the fcllowing:

(a) Thare were no records produced tu verify annual audits of I amcrgency response training Dy the Quality Assurance Department. I i

(b) There were no records produced to verify the annual training on the RCf. There has been no specific RCP training / performed since approximately 1933, based upon statements made by licensee personnel who were part of the l

, 9 emergency response organization and would be expected to respond to an accident at the site.

(c) Discussions with numerous personnel, who were part of the emergency response organization, revealed they were unfamiliar with the RCP. None of the individuals questioned were able to state the four emergency classes i.e., Unusual Event, Alert, Site Area Emergency, and General Emergency. This finding further reflects the' lack of annual training on the RCP.

During the examination of the RCP, it was also noted, the RCP was not specific with:regards to which emergency response positions require different emergency response courses. It is suggested that the licensee' review this area to assure that managers, coordinators, and personnel responding to an emergency receive' specific training commensurate with their responsibilites in the following areas: accident classification; notification and coordination with state, local, and federal agencies; accident assessment; dose assessment; and etc.

The licensee's failure to audit the RCP training program and provide specific RCP training are^two examples of one violation against Licensee Condition Number 24. (0 pen Item 88-02-04)

(3) Facilities and Equipment The inspection included a facility tour, an examination of inventory records, and an inspection of the emergency van, the first aid facility and the licensee's decontamination trailor, located at the Santa Susanna Field Station. The following observations were made:

(a) The emergency van was well equipped. The emergency I equipment in the van was operable and in calibration when cested. Records of inventories demonstrated timel, and complete inventories.

(b) The licensee's first aid facility appeared to have ample i supplies and equipment for the treatment of minor i emergencies.  !

(c) The licensee's decontamination facility, located in Trailer No. 114 appeared to have adequate facilities for decontamination. However, the first aid supplies were I sparse and appearei old and the decontamination kit sas  !

missing some supplies. In addition, the decontamination kit contained one bottle of unidentified liquid. It is recommended the licensee examine their emergency supplies to assure necessary supplies are well maintained and readily available. (0 pan Item 88-02-05)

-- ,- e - -a vp ---,-e-- c, w tre ~- , -

.. . 10 (d) The emergency phone box, located outside of Building T020 contained an operable telephone for emergency use and two radiation survey instruments, which were operable and in calibration. The box also contained a full face respirator without a cartridge and an outdated (1982) version of the Building T020 Eme.gency Plan. The outdated emergency plan was replaced prior to the conclusion _of the inspection. The licensee should assure that equiptent in the emergency phone box is complete _and operable.

(e) Numerous fire extinguishers were iilspected during the facilities tour and all were notei to have been inspected at monthly intervals. Housekeepi.ig also showed improvement.

^

(4) Tests and Drills Records of the annual 1987 exercise, reepireJ by the RCP, were examined and appeared adequate. The receeds were well maintained and also included the exercise scenario and the critique, which was held immediately after the exercise. Based upon our review of the Drill / Exercise Program, the following suggestions are offered for consideration, as a method of improving your program.

(a) Examine records of previous exercises to determine if there are portions of the'RCP.that have not been exercised, such as accident classification, notification to state, local and federal a0encies, dose assessment, participation in a fire drill by affsite fire fighting resources, a hazardous materials release and etc., and give these areas preference when preparing the objectives for upcoming drills / exercises. This will assure that at some point in time all portions of the RCP will have been exerci;ed and assessed for adequacy.

(b) Improve the timeliness of corrective action for items identified during exercises. The annual exercise was conducted Mid-July, 1987 and three of the exercise findings are still incomplete with respect to corrective action.

A violation was identified in Section F.(2). The findings in the area of emergency preparedness indicate declining performance. It appears the lack of management oversite and attent:on have lead to numerous deficiencies in the Emergency Preparedness Program. These deficiencies ir F ded the failure to maintain the RCP, the failure to perform RCP

• training, and numerous items where improvements are warranted.

G. Environmental Protection (88045)

The licensee has submitted the required Semi-Annual Effluent Reports and the Annual Environmental Monitoring Report. The Semi-Annual Effluent Reports indicate the effluent releases are within 10 CFR Part 90 limits.

a . 11 The Annual Environmental Monitoring Report indicated the licensee's operations contribute very little to the radioactivity around the site.

The shut down of the fuel fabrication operations at the De Soto site have resulted in a downward trend at the site boundary for both external and internal exposures. However, the annual ambient radiation data does not reflect this trend, and this area will be reviewed during the next inspection as an open item (88-02-06).

No violations were identified in this program area, however the open item identified requires further review.

H. Exit Meeting The findings of the inspection were discussed with the licentse's staff.

on May 19, 1988. The attendees are denoted in Section 1.

The tcpics addressed included the inspection subject areas, the open items, the violations and other concerns warranting the licensee's attention.

The licensee committed to provide the Regional Office with a letter delineating the actions to be taken to update the Radiological Contingency Plan and the time by which the updating would be :ompleted.

The Region V Office received the letter on June 6, 1988. The licensee's commitments for updating the RCP ware reviewed with the Directnr of Atomics International by telephono on June 15, 1988 by the '.nief of the Nuclear Materials Safety and Safeguards Branch - Region V.

The licensee was informed that the violations raised concerns about the adequacy of the performance of the management oversight committees. Of particular note was the failure of the Quality Assurance component to identify the RCP training failure. Additionally the internal radiation safety audits did not identify the failure to prepare requ'ved survey reports at the RIHL.

2 The licensee indicated in a telephone call to the Region V Office on May 25, 1988 that additional training records for the contract Radiation Monitor had been located. The licensee explained that the previous update of the Master Training File did not include dat preceeding 105/

and it was therefore necessary to retrieve the earlie. data from the training file for the individual which is maintained at the Santa Susana work site. The records confirmed that the Radiation Monitor had received the required training and retraining in radiation safety. The documentation resulted in the deletion of the radiation safety training violation.

No opea items were closed during this inspection and six new open items were ic'entified.

,