ML20202C296

Safety Insp Rept 70-0734/86-06 on 860602-06.Violation Noted: Acidic Solution from Thorium Processing Neutralized in Unspecified Tank,Causing Significant Potential for Personal Injury

ML20202C296
Person / Time
Site:	07000734
Issue date:	07/03/1986
From:	Brock B, Thomas R, Zurakowski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20202C270	List: ML20202C265 ML20202C281 ML20202C296
References
70-0734-86-06, 70-734-86-6, NUDOCS 8607110201
Download: ML20202C296 (11)

Text

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1 U. S. NUCLEAR REGULATORY COMMISSION REGION V l

i Report No. 70-734/86-06 Docket No.70-734 l License No. SNM-696 4

Safeguards Group 1 Licensee: -GA Technologies, Inc.

P. O. Box 85608 San Diego, California 92138 l

Facility Name: Torrey Pines Mesa and Sorrento Valley Sites W

Inspection at: San Diego, California Inspection Conducted: June 2-6, 1986 .

I Inspectors: . 73 1 B. L. Brock, Fuel Facilities Inspector Date Si ned

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. / 8 l P. R. Zurakowski, Radiation Specialist Q4t# Signed Approved by: 78 i R. D. Thomas, Chief D6 te' Signed ,

Nuclear Materials Safety Section

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Summary:

Inspection on June 2-6, 1986 (Report No. 70-734/86-06)

Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls, operator training and retraining, criticality safety, operations review, radiation protection, transportation of radioactive materials, radioactive waste management /10 CFR Part 61, and

emergency preparedness. During this inspection, the procedures covered were 88005, 88010, 88015, 88020, 83822, 86740, 88035/84850, and 88050.

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.Results: A violation was identified in one area (Section 5.A(4)). No violations were identified in the remaining areas inspected.

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l 8607110201 860707 4 PDR ADOCK 0700 i C l

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DETAILS

1. Person Contacted

• R. N. Rademacher, Director, Human Resources

• K. E. Asmussen, Manager, Licensing and Nuclear Compliance

• R. C. Noren, Director, Nuclear Fuel Fabrication

• R. P. Vanek, Manager, Fuel Production Department V. Malakhof, Manager, Nuclear Safety J. J. Saurwein, Manager, Fuel Quality Control C. Wisham, Manager, Nuclear Materials Accountability

*L. R. Quintana, Manager, Health Physics

• R. I. DeVelasco, Staff Engineer, Core Engineering

• A. L. Galli, Manager, Security R. J. Bott, Industrial Safety Engineer J. S. Greenwood, Senior Scientist, Hot Cells i

• R. K. Krueger, Supervisor, Triga Fuel Production  !

• J. C. Narvaez, Supervisor, Nuclear Waste Processing Facility P. T. Marshall, Emergency Services Technician M. B. Zacavich, Supervisor, Pilot Plant Technicians T. W. Keim, Senior Nuclear Fuel Waste Processor U. Overton, Senior Nuclear Fuel Waste Processor Ti. Evans, Nuclear Materials Coordinator E. L. Spencer, Environmental Technician

• 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 are reported to the NRC within sixte days after the change.

The licensee's organization structure was again revised as a result of recent retirements. The Director of Human Resources is now responsible for all compliance functions and reports directly to the corporation's president. New managers now replace the former Managers of Nuclear Safety, Health Physics and Material Control and Accountability. These managers, along with the Manager of Statistics and Measurement Control, report to the Manager, Licensing and Nuclear Compliance. Emergency Services was previously aligned with Health Physics but now reports separately to the Manager of q Security. These and other changes were reported to the NRC by

, letter dated May 23, 1986.

, 2 B. Procedure Controls Section 3.7.2 of Part II - License Specifications requires procedures for all activities in which materials subject to this license are physically handle.!, stored, and chemically or physically changed.

(1) The licensec's procedure,NWPF-2718, " Disposal of Liquid Waste to Sanitary Sewer," Issue A, October 23, 1985, addresses neutralization with sodium hydroxide or muriatic acid as appropriate. It appears that additional cautions for this l operation step are warranted (see Section 5.A.(4)).

(2) The licensee's action on open item 86-04-01 was reviewed by the  !

inspector. It was found that the licensee has implemented a program whereby all work authorizations are reviewed to insure that all persons listed are users of licensed material and they j receive any required training. This item is closed.

C. Internal Review and Audit i Section 3.6 of Part II - License Specifications requires that health physics inspections be conducted quarterly and nuclear safety l inspections (see Section 4.B(1)) be conducted at least annually for i all areas possessing SNM and at least quarterly for areas possessing ,

more than 500 grams of SNM.

(1) The inspector's review found the licensee's health physics and nuclear safety inspections were conducted as required. The inspections were appropriately documented.

(2) The corrective action taken in response to a violation, the licensee identified, has apparently been adequate to preclude recurrence. No further incidents of repair work or modifications have occurred without appropriate documentation in place. This closes item (86-04-02).

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 of 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.

The licensee's CRSC membership has been changed by the replacement of a chemist with a nuclear engineer. The nuclear engineer is familiar with HTGR production operations as a result of several years extensive measurements of intermediate products and side -

3 streams by nondestructive assay (NDA) techniques. SOLNEW calculations are currently being reviewed by this new member of the CRSC.

The Manager of Nuclear Safety planned to conduct the nuclear safety audits during the week of June 9, 1986. He just completed the Nuclear Criticality Safety workshop sponsored by the University of New Mexico Department of Chemical and Nuclear Engineering. A second person will participate in the audits as part of a training program.

Additional attention will be given to human error aspects of operations. The evaluation of the adequacy of the licensee's criticality safety audits remains open (86-04-03).

No violations were identified.

3. Training Section 3.2.2.1 of Part II - License Specification states that on-site radiological safety. training will be condu'cted.

4 In response to open item (86-04-04), the licensee has reviewed all Work Authorizations and has given training or retraining to all individuals needing such training. In addition, the licensee has developed a program ,

whereby Work Authorizations are reviewed at least yearly to insure that all persons needing retraining will receive the required instruction.

This training for 1986 is scheduled for the months of July and August.

Open item (86-04-04) is closed.

Those persons selected to replace the four retiring HPTs have received 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of training in criticality' safety on May 20-21, 1986. Two of the retiring HPTs, with about 28 years experience each, returned for approximately 2 months to give on-the-job training to the replacements.

An initial formal class of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> has been given to the new HPTs in risks associated with occupational radiation exposure. They also have been given time to study the 110 Health Physics Procedures, the NRC license and regulations, and applicable Regulatory Guides. A formal class reviewing all of the above will be given by he Supervisor of Health Physics in late June and early July 1986. It was noted by the inspectors that each of the replacements has been employed by the licensee in various related technical jobs and have therefore received considerable prior training in radiation safety.

No violations were identified.

4. Criticality Safety Section 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.  !

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4 A. Nuclear Criticality Safety Analyses Three CRSC reviews of interaction calculations were completed. Two of the reviews involved no changes in equipment locations, but because of increased U-235 loading per fuel rod, posting modifications were recommended. Additionally, it was recommended by the committee that fuel rod storage trays that previously stored 800 rods be modified to preclude storage of more than the 350 rods. The third review involved equipment changes - a scrap and a waste handling station had been added. The calculated solid angles for the-added stations were less than the allowed solid angle and acceptance was recommended.

B. Audits The licensee's new Manager of Nuclear Safety was available during only part of the inspection because of his scheduled participation 4

in the University of New Mexico sponsored Nuclear Criticality Safety short course. The Manager of Nuclear Safety delayed the criticality a

safety audits for a ' week to permit using the course information in the audits. The licensee's measurement specialist will participate in.the audits as a trainee. Open item (86-04-03) will remain open

.until the audits reflect adequate concern for the human error potential and the' practical aspects of the processing operations.

C. Criticality Monitoring System The- modifications to 'the Criticality Warning Alarm System (CWAS) has reduced channel ' interactions and the resultant false alarms. The licensee indicated no false alarms have been experienced since the modification. The licensee's new inside storage area for queuing up j shipments was covered by the existing CWAS; therefore, no l . modification of the system was needed. This closes item (86-04-06).

t D. Procedures (1) The licensee has set up a computer program to track the status of procedures for the North Warning System (NWS) process. The output is a Work Authorization Status Report. This report is updated weekly if changes occur. The report tracks several attributes including the initiation of the procedure as well as revisions. The internal and external approvals are tracked as well as the Work Authorization approval date. It appears that this tracking method should preclude overlooking a needed procedure. The Manager of Nuclear Safety is on the distribution list of this report. The effectiveness of this tracking method will be reviewed during the next inspection.

Item (86-04-05) therefore remains open.

(2) The licensee reviewed the results of samples taken from the solution in the five-inch diameter horizontal storage tanks after mixing. The results, genera 11y'less than lg U/L, indicated the mixing action in the 100 foot long pipe was .not very effective. The results from the sample taken nearest to

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, the air sparge which is located at the lower end of the pipe (0.6g U/L) were higher when compared to samples taken further from the air sparge inlet point which were as low as 0.01g U/L. Though the concentrations were all low, the licensee is i reviewing what steps to take to correctly label the uranium content of the 55 gallon drums that get filled from the horizontal storage tanks. The actions taken by the licensee

will be reviewed during the next inspection (86-06-01).

• No violations were identified.

5. Operations Review

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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, and i company policy, criteria and established practices.

i A. Conduct of Operations (1) North Warning System (NWS)  ;

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i (a) The NWS process in SV-B was in normal operation. The  ;

inspectors noted the presence of two stainless steel  !

-buckets of non-safe geometry. The Manager of Nuclear j Safety had reviewed their use and storage recently af ter  !

being alerted by a Health Physics Technician. He found [

, the conditions surrounding their use (in a mass limited ,

! work station) and storage beneath the work stations table '

j or hood acceptable. The NWS now has a designated storage location for the 55 gallon dry waste storage drum. This ,

closes item (85-16-01). '

(2) Triga Fuel Fabrication (TFF) (

I The inspectors' observations of operations noted no poor health physics practices.

(3) Hot Cells

, The licensee completed the Post Irradiation Examination (PIE)  ;

of the cured-in place HTGR fuel block. The next project, PIE of Triga fuel elements with very high burnup, does not require some of the equipment currently in the hot cell. The hot cell cleanup is currently being planned. The Senior Scientist in

! charge of the hot cell had participated in the previous (1978)  ;

major decontamination and refurbishing of the hot cells. The licensee indicated appropriate attention would be given to ALARA considerations. ,

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1 (4) Low Level Radioactive Liquid Waste Treatment System (Building

25) '

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The inspectors observed the operation of the low level radioactive liquid waste treatment system in Building 25. The operators were neutralizing an acidic solution from thorium processing with soda ash. The 500 gallon onsite mobile transfer tank in which the neutralization was occurring was noticeably warm. The inspectors reviewed the procedure and noted the procedure required the neutralization be done in the neutralization tank of the newly constructed system. The neutralization was to be done in 60 gallon increments in the much smaller tank. The smaller neutralization batches inherently involve the addition of smaller quantities of the neutralizing agent. This reduces the potential for adding a large quantity of strong chemical reagents all at once. This step of the procedure was not being followed. The use of the larger tank was therefore identified as a violation. The inspectors also noted that although the industrial safety review had been made within the fuel production department, the i company's industrial hygienist did not have an opportunity to make a review. The licensee's changes to assure that the industrial safety hygienist reviews procedures with significant potential for personnel injury will be reviewed during the next inspection (86-06-02).

I (5) Nuclear Waste Processing Facility (NWPF)

The NWPF has acquired additional indoor space in which to store packages prepared for shipment. Recent activities included solidifying contaminated waste oil by absorption.

Additionally, 55 gallon drums of liquid radioactive waste from the NWS process are being packaged in wooden boxes for shipment to the Los Alamos National Laboratory (LANL) (see Section 7).

(6) The inspectors reviewed the licensee's response to the Notice of Violation wherein the licensee had not sealed all f ventilation ducts and enclosures that did not have an airflow 1 of 25 LFM. The licensee had sealed ventilation ducts and enclosures and was thus in compliance with this requirement of License Condition 29c.

(7) Upon review of open item (86-04-07), it was found that the adequacy of the nozzles in place for isokinetic sampling of exhaust stacks had been. reviewed by the licensee at the Triga fabrication facility. However, review at other facilities have not yet been completed. This-item will therefore remain open.

r One violation was identified.

6. Radiation Protection Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.

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A. External Exposures The inspector _ reviewed the licensee's records of radiation exposure for 1986 through May. No Part 20 exposure limits were exceeded.

The maximum exposure for the first quarter was 700 mrem. Because of the 240 persons who elected retirement during the first quarter, i' many reports required by 10 CFR 20.408 were sent by the licensee.

All reports.were sent in a timely manner.

B. Lung Counts

No lung counts were conducted since the last inspection. The semi-annual lung counts will be conducted in August 1986. These records will be reviewed during the next inspection.

C. Bioassay Results The inspector reviewed urinalyses results for 1986 through May.

Only one positive result of 4.8% MPL was noted. The minimum level of detection is 4.0%.

D. Surveys The licensee's response to open item (86-04-08) was reviewed by the inspectors. It was observed that the Manager of Health Physics

, is crosstraining all HPTs to do all required surveys. This closes item (86-04-08).

E. Portable Monitoring Instruments Survey instruments and area alarms were checked by the inspectors during the tour of the licensee's facilities. All instruments were in calibration.

F. Leak Tests Compliance with leak test requirements was reviewed by the inspector. It was found that all thirty-one sealed sources were j leak tested in a timely manner.

3 No violations were identified.

7. Transportation Licensee'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).

During this inspection, the transportation problems associated with the proposed shipment by the licensee of ten boxes each containing five polyethylene DOT Specification-34 type drums of low level liquid scrap from the North Warning Project were reviewed. The boxes containing from 7.2 to 14.6 grams of U-235 will be shipped to LANL for appropriate

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processing and eventual disposal. Each box containing five bags of "superfine" absorbant will be packaged and marked according to 49 CFR 173.421. This section of the regulations is entitled " limited quantities of radioactive material." After discussions with NRC's Transportation Representative in Headquarters, the NRC inspector concluded that the licensee's interpretation of the regulations was essentially correct with the exception of 10 CFR 421(d) which requires the marking " Radioactive" on the outside of the inner packaging. The licensee agreed to comply with the above requirement prior to shipment of the ten boxes. The licensee's actions associated with the actual shipment of the ten boxes will be reviewed during the next inspection (86-06-03).

8. Waste Disposal /Part 61

! Annex "C" of the current license-incorporates guidelines for release of equipment and facilities to unrestricted use. 10 CFR Part 20.301 to Part

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20.401 regulates the disposal of waste. 10 CFR Part 61 requires that all radioactive waste prepared for disposal is classified in accordance with Section 61.55 and meet the waste requirements in Section 61.66.

A. The inspectors were informed by the licensee that no licensed

material has been set to a commercial waste disposal facility since the last inspection. It was further learned that a load was being readied for shipment to the commercial disposal site near Richland, Washington later this month or early July.

The open item involving the disposal of a drum reading 0.75 R/hr at the surface (85-09-01) will remain open. The licensee has not yet taken steps to classify and dispose of the item. A second drum reading 1.5 R/hr at the surface, which is being stored in the same yard, will also be tracked during subsequent inspections in order to l better evaluate the licensee's classification and QA procedures.

l The second drum will also be tracked under open item (85-09-01).

1 B. A hot cell clean up with the accompanying health physics and waste disposal problems will be undertaken during the next quarter. The effects of this clean up on licensee personnel exposure with the accompanying waste disposal problems will be reviewed during the next inspection (86-06-04).

No violations were identified.

9. Emergency Preparedness

License Condition 23, of SNM-696, requires the licensee to imp'lement,'

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.

l A. Emergency Plan The licensee's emergency plan was updated in March 1985. The plan indicates the area sapervisors and sponsors of visitors are 1

9 responsible for accounting for them. Further, an L Building evacuation would involve.only a small fraction of the building's occupants. This closes item (86-04-09).

B. Fire Protection Seventy-seven fire extinguishers were checked during the course of the inspection and all were found current with regard to their monthly inspections.

No violations were identified.

10. Deactivation / Decontamination Activities License Condition 24 requires that at the tend of plant life, the licensee shall decontaminate the site and facilities authorized as a place of use for special nuclear materials.

The licensee is continuing preparations for the shipment of the contaminated soil. Consideration is being given to sorting the contaminated soil and the possible alternatives. The licensee plans to submit a revision to the.NRC approved decontamination plan if the alternatives being considered appear feasible. The licensee has located a container which appears to be suitable for the planned shipments.

Consideration is being given.to sheltering the container during loading to minimize its contamination;during:the loading operation. The licensee currently ~ plans to make the shipments between July 1986 and November 1987. NRC requested to be notified of the licensee's planned dry run (loading the container with' clean dirt) to permit NRC observation of this system.

No violations were identified.

11. Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1. The topics included:

The areas inspected; The status of the previous violation (failure to seal enclosures with less than 25 LFM);

The NRC identified violation (failure to use the waste water treatment system neutralization tank);

The need to have the industrial hygienist review this and similar procedures; The closure of seven open items:

• 85-16-01 Unfavorable geometry container control in SV-B

• 86-04-01 Work authorization authorized user lists

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• 86-04-02 Adequacy of violation corrective action

• 86-04-04 Adequacy of retraining control

• 86-04-06 New waste handling area safety systems review

• 86-04-08 Assurance of HPT backup

• 86-04-09 Personnel accounting during drills

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Continuing open items:

• 84-04-08 Review grinder holdup study conclusion (requires HTGR plant restart)

• 85-09-01 Review hot cell waste drum classification

• 86-04-03 Adequacy of nuclear safety inspections

• 86-04-05 Review licensee's controls to assure needed procedures are prepared in a timely manner New open items:

• 86-06-01 Review measurements of effluent from the SV-B horizontal storage tanks l *86-06-02 Review licensee's changes that assure the industrial hygienist reviews procedures with safety significance

• 86-06-03 Review the licensee's actions in shipment of boxed drums of NWS liquid scrap

• 86-06-04 Review the personnel exposures and waste packaging from the hot cell cleanup The attendance of the Criticality Safety. Training Course by the Manger of Nuclear Safety; and NRC interest in observation of the soil packaging dry run.

Licensee's comments included:

Agrees that the presence of NRC during the soil packaging dry ,

runalong with the other interested parties may facilitate correcting unexpected problems collegially.

Agreed that it was preferable to err on the side of conservatism by having the industrial safety engineer review more procedures than necessary rather than miss one needing review.

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